By: Jameson Miller, CPA, CISA, CISSP, CCP, CCA
The U.S. Department of Justice has updated Title II of the Americans with Disabilities Act (ADA) to make Web Content Accessibility Guidelines (WCAG 2.1 Level AA) the law for state and local governments, effective April 24, 2026, for many public entities. With less than three months left to comply, it’s essential that governmental leaders understand the new rules and take necessary steps to prepare. Here’s what you need to know.
What is Title II of the ADA?
The ADA is a sweeping piece of legislation designed to promote inclusion across governmental functions at every level, with the goal of establishing full accessibility for people of all abilities. Title II of the ADA requires state and local governments to make sure all of their programs and services are accessible to those with disabilities.
In practice, that means ensuring that everyone has physical and digital access to information and programs as well as the ability to participate, regardless of disability status. Title II includes things like accessible facilities and restrooms, effective communications, reasonable policy modifications and other accommodations to permit equal access and participation.
What are Web Content Accessibility Guidelines?
Web Content Accessibility Guidelines, more specifically WCAG 2.1 Level AA, is a set of rules to ensure that individuals with disabilities can fully access online content. Developed by the World Wide Web Consortium (W3C), this framework sets forth specific requirements that govern accessibility concerns for content on websites and apps. This includes options for navigation and user interface that make it easier for those with disabilities to access online tools, services and information. Specific requirements under WCAG 2.1 Level AA include:
- Providing captions for live audio content
- Ensuring a minimum contrast ratio for text and background
- Offering multiple methods of navigating to a site’s pages
- Incorporating error prevention strategies for legal, financial and data input
Does the updated requirement apply to my government entity?
All state and local entities must comply with WCAG 2.1 Level AA, with most required to comply as of April 24, 2026. That deadline applies to any government body with a population of 50,000 or more. Smaller populations and special districts must comply with the new standard by April 26, 2027.
What exactly does WCAG 2.1 Level AA cover?
One of the most important things to understand about WCAG 2.1 Level AA is its massive scope. The requirements it sets forth cover every kind of digital touchpoint, such as public websites, mobile apps and even third-party portals for paying taxes or utility bills online. It includes often-overlooked areas like an organization’s document library, with all the PDFs, Word documents and spreadsheets that are still active and available for public use.
Due to the law’s wide-ranging impacts, it’s essential to conduct a thorough assessment of affected areas and adopt an organized approach to ensuring compliance across the full range of services, programs and content your governmental entity offers.
Who can help me comply with the new standard?
Any knowledgeable technology advisor can help you understand WCAG 2.1 Level AA. However, as a government entity, it’s important to select an advisor who understands not just the standard but how it applies to your unique situation.
Look for a trusted service provider that works with many government clients and brings a thorough understanding of the specific budget and staffing hurdles your organization faces.
How can I tell if my organization is compliant?
Besides internal assessments, it’s imperative to seek objective analysis of potential pitfalls and unrecognized areas that require modifications to comply with WCAG 2.1 Level AA. For example, our team can run a full audit to identify exactly where a website or app fails to meet one or more of the 50 different success criteria required under the law. Following the audit, we provide a prioritized roadmap that shows you which high-risk issues to focus on before the April compliance deadline.
What should I do now?
Bridging the gap between your current controls and the new IT accessibility requirements can be challenging with severe consequences for noncompliance. But it’s not just about avoiding lawsuits; compliance is about making sure every citizen can access essential services online.
Adapting to WCAG 2.1 Level AA must be a high priority for state and local governments of all sizes. Reach out to Mauldin & Jenkins’ experienced advisors for a readiness assessment today; we’ll help you make the most of the time that’s left so you can face the compliance deadline with confidence.
