Accessibility Has A Deadline

The clock is officially ticking.

In April 2024, the U.S. Department of Justice (DOJ) published a final rule updating Title II of the Americans with Disabilities Act (ADA).

Digital accessibility isn’t optional under the ADA, but the 2024 Title II rule removes ambiguity.

It defines the standard, sets deadlines, and increases the consequences for noncompliance.

For state and local governments, this marks the end of vague intent and the beginning of measurable obligation.

There is a lot of noise surrounding these terms. Let’s simplify.

The Best Time To Start Accessibility Is Now

You may not be obligated for this specific deadline, but that doesn’t mean you should keep ignoring accessibility.

The ADA is the law. It’s the promise of equal access.
WCAG and Section 508 is the map to start your accessibility journey.

The Who and When of Accessibility Deadlines

Compliance is no longer a “someday” project. The Department of Justice has set firm deadlines based on the population you serve. Compliance deadlines are:

• Population / Entity Type — Compliance Deadline
• 50,000+ residents — April 24, 2026
• Under 50,000 residents — April 26, 2027
• Special district governments — April 26, 2027

Two years may feel like plenty of time, but in digital accessibility, it passes quickly.

Audits require automated scanning, manual testing, and cross-checks across websites, apps, PDFs, videos, and forms.

Remediation often involves teams of developers, content creators, accessibility specialists, and quality assurance reviewers.

Coordinating all these steps within the timeline can be challenging — especially when legacy content and complex services are involved.

State and Local Governments: First Steps Toward Complying with the Americans with Disabilities Act Title II Web and Mobile Application Accessibility Rule

What Digital Content Must be Revised?

• Websites and web pages
• Mobile applications
• Documents and PDFs
• Multimedia (videos and audio)
• Forms and online services
• New social media posts after compliance deadlines
• Exceptions are narrow. Archival or legacy content may have limited grace, but essential service must always be accessible.

Conformance Principles POUR

To comply with WCAG 2.2 Level AA, your digital content must adhere to the four foundational principles — Perceivable, Operable, Understandable, and Robust (sometimes called POUR) but let’s be specific about what that looks in action.

Perceivable Means Users Can Detect the Content
Content must be rendered in ways that users can see, hear, or otherwise perceive. This includes:

• Alt text for images
• Captions for video and audio
• Sufficient contrast between text and backgrounds

Meeting these technical criteria is necessary, but not always sufficient. A page may technically conform to WCAG, but if a user can’t meaningfully understand or interact with the content, it isn’t truly accessible.

Actual user experience must guide the implementation, so
audits should include testing with assistive technologies and real users.

Operable Means Users Can Navigate and Use It
Your site and apps must work with key accessibility modalities. This includes:

• Keyboard navigation (no keyboard traps)
• Clear focus indicators
• Avoidance of seizure-inducing flashes or motion

Users should encounter minimal barriers, but some limitations may persist. That’s why accessibility requires ongoing testing and adjustment.

Understandable Means It Makes Sense
Content and interactions must be logical and predictable.

• Navigation consistency
• Clear instructions
• Helpful feedback for forms, including clear error messages and confirmation of successful actions

Robust Means It Works Across Tech
Accessibility isn’t conditional on a specific browser or assistive tool. WCAG compliance demands:

• Well-formed, valid code
• Compatibility with screen readers and other assistive technology
• Regular testing as browsers and tools evolve

This isn’t a one-time check. It’s an ongoing evolutionary process of access and inclusion.

Many organizations hope that automated tools will “solve” accessibility issues. They won’t.

Automated tools can detect roughly 30% of accessibility issues — things like missing alt text or obvious contrast problems.

But the remaining 70% issues like keyboard focus, accessible labeling accuracy, and meaningful content structure can only be detected through manual testing and human validation.

If you aren’t testing with humans, you aren’t truly testing for accessibility.

Common Myths Accessibility Overlays Don’t Replace Compliance

There’s a persistent myth that adding an accessibility widget or automated overlay makes a site or app compliant.

It does not.

Accessibility professionals regularly confirm that overlays do not fix underlying structural issues, do not address cognitive barriers, and do not substitute for manual testing.

You remain exposed if you rely on them. Automated solutions can help identify some barriers, but they do not make you compliant on
their own.

Real accessibility comes from testing with people, listening to their experiences, and making adjustments based on how disabled users actually navigate and interact with your services.

If you need guidance or support to get started with your baseline audit, accessibility specialists (like myself) can help ensure your digital services meet WCAG 2.1 AA requirements while centering real user experiences.