How to Become Compliant with New ADA Title II Website Accessibility Rule

Many state and law governments covered by Title II are unfamiliar with digital accessibility. In this guide, we’ll cover the important considerations and steps to take to become compliant with the recently published ADA Title II Website Accessibility Rule.


Under the new ADA Title II, all digital assets and content must conform with WCAG 2.1 AA standards to ensure accessibility for all users, including those with disabilities. There are five content exceptions to be aware of before taking inventory, but the biggest take away from the new rule is that the Department of Justice (DOJ) adopted the Web Content Accessibility Guidelines (WCAG) as the legal standard for compliance under Title II of the Americans with Disabilities Act (ADA).

Understanding Compliance Requirements

First, you need to understand exactly what is required from the source material. The DOJ’s ADA Title II Web Fact Sheet is the best source of information because it’s the DOJ’s summary of the new web rule. Be sure to note all five content exceptions as these exceptions can save you time and money.

Form Compliance Team

It’s important to create a team who will be dedicated to ADA Title II digital compliance. Here are three key bullet points to keep in mind as you are forming your Title II team:

  • Appoint an accessibility coordinator to lead the project.
  • Include members from various departments IT, legal, and finance departments, if possible.
  • Create an accessibility policy that outlines roles and what the responsibilities are for each role.

What’s extremely helpful is this committee will bring diverse knowledge and skillsets which will help in ensuring WCAG 2.1 AA conformance across your digital assets and content.

Initiate Training and Assessment

Immediate training on web content accessibility guidelines is essential for everyone involved in the project. This training is vital as it helps us make more informed decisions and it permeates everything. Knowledge of the web content accessibility guidelines is crucial for developing a better accessibility policy and a more realistic timeline. It helps us create a better and more realistic timeline, and it will also help us with procuring different services.

Training on these guidelines provides the foundation for understanding what it takes to make our digital assets accessible. This foundational knowledge ensures that all team members are equipped to handle the requirements of the project efficiently and effectively. The key here is to start WCAG 2.1 AA training immediately to ensure that all team members have the necessary understanding to proceed with the project effectively.

Inventory and Prioritization of Digital Assets

Take inventory of your digital assets to ensure compliance with WCAG 2.1 AA. This process involves identifying all digital assets including websites, mobile apps, web content documents, and social media channels. Once identified, determine which assets need to be made WCAG 2.1 AA conformant.

Key Steps for Inventory and Prioritization:

  • Identify All Digital Assets: Catalog everything from websites to social media channels.
  • Assess Conformance Needs: Determine which assets are not yet WCAG 2.1 AA conformant.
  • Prioritize Based on Use and Importance: Decide which assets to update first, focusing on the most used and important ones, as not all can be updated at once.

This prioritization is crucial because you need to know what we need to work on first. We need to prioritize and we need to have an inventory list so that we can prioritize effectively.

Budget and Resource Allocation

Set an approximate budget to cover all aspects of making your digital assets WCAG 2.1 AA conformant. This budgeting is not just about initial compliance but also encompasses the ongoing effort required to maintain WCAG conformance over multiple years.

Key Steps for Budgeting:

  • Consider the Services Needed: Include costs for external audits, remediation services, and any technology or tools required for compliance.
  • Account for Staff Hours: Estimate the hours your staff will dedicate to this project, including planning, implementation, and monitoring efforts.
  • Include Ongoing Training Costs: Factor in the cost of continuous training to keep your team updated on WCAG 2.1 AA standards and best practices.

Remember, setting a budget requires keeping in mind the services that we need, our staff work, and the ongoing training necessary to maintain conformance. This budget should be for multiple years, as maintaining WCAG conformance is an ongoing effort.

Creating a Timeline and Executing the Plan

Develop a timeline to manage the process of making your digital assets WCAG 2.1 AA conformant. This timeline should plan the stages for compliance, including provisions for concurrent processes such as external audits and internal updates. Ensure that this structured timeline accommodates all phases of the accessibility project, from initial assessment through to full compliance, allowing for effective management and timely completion of each milestone.

This approach will ensure that the different phases of the accessibility project are managed effectively and that milestones are reached on schedule. By meticulously following this structured plan, organizations can begin the necessary work to comply with the new ADA Title II web accessibility rule. This systematic approach not only helps in meeting legal requirements but also enhances the accessibility of digital environments, making them usable for all individuals.