What You Need to Know
Digital accessibility has been a legal requirement for public entities for decades. What changed in 2024 is that there's now a specific technical standard you'll be measured against, a hard deadline, and real enforcement behind it.
This post walks through what the federal requirement means, which of your digital properties it covers, and how to start.
What Changed and Why It Matters
Digital accessibility has technically been required under Title II of the Americans with Disabilities Act (ADA) since 1990. For decades, however, there was no defined technical standard, which led to inconsistent implementation and uneven enforcement.
That changed in April 2024, when the U.S. Department of Justice finalized a rule establishing a clear benchmark: WCAG 2.1 Level AA. WCAG (Web Content Accessibility Guidelines) is the globally recognized technical standard for making digital content usable by people with disabilities. Level AA is the middle conformance tier and is widely considered the appropriate standard for public-facing services.
The deadlines breakdown as follows:
• April 24, 2026 – Public entities (other than special districts) serving populations of 50,000 or more
• April 26, 2027 – Smaller entities and special districts (including JPAs, housing authorities, fire districts, and similar organizations)
The scope is broader than many agencies expect. Any digital channel residents use to access government services is in scope: websites, mobile apps, online forms, PDFs, payment portals, permit systems, emergency alerts, court filings, and vendor-provided platforms. If a resident must use it to interact with your agency, it must be accessible.
For California public entities, federal law is only part of the framework. In addition to Title II, many entities are independently subject to Section 504 of the Rehabilitation Act if they receive federal financial assistance. Section 504 - part of federal disability civil rights legislation enacted decades ago, has long prohibited disability discrimination in federally funded programs and activities.
At the state level, California Government Code § 11135 imposes similar nondiscrimination obligations on entities receiving state funding, while § 7405 establishes accessibility requirements for state agency electronic and information technology. These long-standing statutes operate alongside the ADA and may create overlapping compliance exposure depending on an entity’s funding structure and type.
California’s Unruh Civil Rights Act also prohibits disability discrimination and provides a private right of action with statutory damages of at least $4,000 per occurrence, plus potential attorney’s fees. Applicability to public agencies depends on the nature of the activity and how the statute is interpreted in a given context. Unlike the ADA Title II rule, Unruh is typically enforced through civil litigation rather than a standalone regulatory compliance program.
California state agencies face additional certification requirements under AB 434, and the state’s litigation environment has historically produced a higher volume of accessibility claims than many other jurisdictions. Agencies should consult legal counsel to understand how these overlapping requirements apply to their specific structure, funding profile, and services. The practical stakes are real. When digital services are not accessible, residents cannot renew licenses online. Emergency communications fail to reach people with disabilities during critical incidents. Outdated PDFs block access to public records and meeting agendas. Accessible design addresses these gaps and improves usability for everyone — including residents on mobile devices, seniors with changing vision, and people completing forms under stress.
What WCAG 2.1 AA Requires
You don’t need to become a WCAG expert, but a working understanding helps you have better conversations with your IT team and vendors. The standard is built on four principles: perceivable, operable, understandable, and robust.
Perceivable means people can access the content regardless of how they consume it. Images need text descriptions for screen readers. Videos need captions. Color can’t be the only way to convey information.
Operable means everything works with a keyboard, not just a mouse. No flashing content that could trigger seizures. Clear navigation, page titles, and enough time to read and complete forms.
Understandable means text is readable, forms have clear labels and error messages, and pages behave predictably.
Robust means your content works with assistive technology and follows web standards so screen readers can interpret it.
Many of the most common failures are fixable without a major project: missing image descriptions, low color contrast, form fields without labels, and broken heading structure. A baseline audit will quickly surface these.
Where to Start in the Next 30–60 Days
Agencies consistently underestimate the amount of work that comes after the audit.
Large, complex sites can take months or more to remediate, and many issues require manual code-level fixes rather than simple content edits. Post-audit work commonly stalls when there's no dedicated roadmap, no assigned owner, and no budget lined up. Build your plan with that reality in mind.
Inventory your digital footprint
Start by listing every public-facing digital property: your main website, department microsites, third-party platforms (permitting systems, payment processors, event registration tools), mobile apps, and online PDFs. Most agencies discover they have more digital surface area than they realized.
Identify your highest-risk services
Not everything carries the same risk. Focus first on services tied to public safety, legal rights, payments, and health. What gets the most resident traffic? What would cause the most harm if someone with a disability couldn’t access it? Start there.
Assign ownership
Accessibility requires coordination across IT, communications, procurement, legal, and program teams. Someone needs to own it with actual decision authority and accountability.
Get baseline data
Run a free automated scan on your main website and top services to understand your starting point. Automated tools help you quickly find some issues, but they cannot check everything required for accessibility. You’ll eventually need manual review and testing as well. However, a scan is the fastest way to identify obvious problems and build a case for resources.
Start here:
UsableNet AQA - Free accessibility scan
Review your vendor contracts
Under the rule, public entities remain responsible for the accessibility of vendor platforms used to deliver services. Check your contracts: do they require WCAG 2.1 AA conformance? Can the vendor provide documentation? If not, you’ll need to renegotiate or plan for remediation.
Accessibility is easier to manage when it is part of procurement, not a retrofit after purchase. For any platform used to deliver public services (payments, permitting, forms, alerts, scheduling, learning platforms), include accessibility requirements in RFPs and renewals, not just in implementation plans.
A practical starting point is to ask vendors for an Accessibility Conformance Report (ACR) using the VPAT format, and to confirm which standard it covers. VPAT/ACR documentation is widely used in public-sector technology procurement to describe how a product supports accessibility standards.
Define how accessibility issues will be addressed, including remediation timelines and documentation expectations. The DOJ rule applies when a public entity provides or makes available web content or mobile apps, including when there is an “arrangement” with a third party to provide the app or service. In other words, vendor platforms used to deliver public programs still need to meet the standard.
Start these conversations now.
The PDF Problem
PDFs are where a lot of agencies feel the most overwhelmed. You may have hundreds or thousands of documents online, and not all require immediate attention.
The rule focuses on current documents used for service delivery - things a resident needs to access a program, apply for a permit, or complete a required process. Certain archived content and older materials that are not actively used for current service delivery may qualify for limited exceptions under the rule.
Your immediate focus should be on forms residents must complete, current meeting agendas, public safety information, and legal notices. For frequently updated documents, consider moving them to accessible web pages instead of PDFs - they’re often easier to maintain and more accessible by default.
And stop creating new inaccessible PDFs. Train staff to build accessible documents from the start using built-in tools in Microsoft Word or Adobe Acrobat.
If You’re Working With a Limited Budget
Smaller cities, counties, and special districts face the same requirements with fewer resources. The key is being strategic rather than trying to boil the ocean.
Start with your top 10–20 pages: your homepage, contact information, bill payment, meeting agendas, forms, and emergency information. This is where most residents interact with your agency, and getting these pages accessible creates real, immediate impact while you work through the rest.
Resources are available. The W3C Web Accessibility Initiative (w3.org/WAI) offers free tutorials and guidance. Section508.gov has resources applicable beyond federal agencies.
PRISM members can also leverage our risk management services and peer network. Neighboring jurisdictions often face the same challenges, and sharing assessment or training costs is worth exploring through your regional connections.
Signal Good Faith Now
One of the most important things you can do before your compliance deadline costs almost nothing: publish an accessibility statement on your website. Include your commitment to accessibility, the standard you’re working toward, how residents can report issues or request accommodation, and a contact for accessibility concerns.
This can matter legally. An accessibility statement helps demonstrate good faith effort. By letting residents report issues, you create a feedback loop that surfaces problems you might not find through scanning alone. Residents who rely on assistive technology will tell you what’s broken if you let them.
April 2026 is Almost Here
The April 2026 deadline is real, and the work takes longer than it looks. Agencies that are in good shape by then won’t be the ones that panicked in March - they’ll be the ones that started with a clear inventory, assigned ownership, prioritized by risk, and built a remediation plan tied to their budget cycles.
Digital accessibility is a core part of how government services work and an ongoing operational responsibility. New pages get published, vendors push updates, and staff turn over. Agencies that stay ahead of this build accessibility into their standard workflows: procurement checklists, content publishing guidelines, regular audits, and staff training. The goal isn’t just to meet the April 2026 deadline. It’s still to be in compliance in 2028.
If you have questions or want to talk about where your agency stands, reach out to UsableNet at usablenet.com or contact Nicole Montalvo, IT Manager (nmontalvo@prismrisk.gov) or John Russell (jrussell@prismrisk.gov) at PRISM.
PRISM has partnered with UsableNet for accessibility compliance of the PRISM website.