Member Services

Accessibility

Digital accessibility ensures that websites, applications, documents, and online services are usable by individuals with disabilities. This includes people who rely on assistive technologies such as screen readers, voice navigation, or keyboard-only interaction.

For public entities in California, accessibility is not optional. It is a legal requirement under federal and state law, and it is increasingly being enforced in the context of digital services.

    Start Here: If You’re Starting from Scratch

    If your organization has not yet begun addressing digital accessibility, you are not alone. Many public entities are in the same position. The most important step is to begin with a structured approach and focus on high-impact actions first.

    Accessibility compliance is not achieved all at once. It is built through planning, assessment, remediation, and ongoing governance. The goal for the first 120 days is to establish control, understand your current state, and begin addressing the highest-risk areas.

    Most organizations will need a combination of internal training and external support to effectively assess and remediate accessibility issues.

    What to Focus on in the First 120 Days

    1. Establish Ownership and Direction

    • Designate an ADA Coordinator or internal accessibility lead
    • Adopt a basic compliance plan to define roles, responsibilities, and timelines
    • Align leadership on expectations and resource needs

    2. Identify and Inventory Your Digital Assets

    3. Conduct an Initial Accessibility Assessment

    • Run automated scans on your website and key applications (these tools identify issues but do not replace manual testing or expertise)
    • Identify obvious barriers such as missing alt text, poor color contrast, and inaccessible forms
    • Begin documenting issues in a centralized audit or remediation log

    4. Build Internal Capability or Secure Support

    • Recognize that most staff are not trained to identify or remediate accessibility issues
    • Provide foundational training for key roles such as IT, content creators, and procurement staff
    • Use available training resources to build baseline knowledge (see “Training” section)
    • Consider engaging a qualified vendor for audits, remediation, or advisory support if internal expertise is limited - members may consider use of any available subsidy funds to help cover costs.  

    5. Prioritize High-Impact Services

    • Focus first on services the public depends on, such as applications, payments, permits, and emergency information
    • Address issues that block access entirely or prevent task completion
    • Do not attempt to fix everything at once—prioritization is critical

    6. Begin Remediation and Documentation

    • Start fixing the most critical issues identified in your assessment
    • Track remediation progress and maintain records of actions taken
    • Maintain documentation to demonstrate good-faith compliance efforts

    7. Evaluate Vendors and Contracts

    • Identify systems provided by third-party vendors
    • Request VPATs or accessibility documentation
    • Begin incorporating accessibility requirements into new and renewing contracts

    Use Available Templates and Tools: This resource library includes a compliance plan, audit templates, and tracking tools to help you implement each of the steps above in a structured and defensible way.

    Key takeaway: You do not need to achieve full compliance in 120 days, but you do need a plan, documented progress, and a clear focus on high-impact services.

    Organizations that are further along in their accessibility journey but want to better understand their overall compliance posture - including audit coverage, documentation, and readiness to respond to inquiries - may benefit from a structured assessment resource. PRISM has developed a comprehensive ADA compliance packet to support this effort across both physical and digital accessibility. 

    Download the ADA Compliance Audit and Inventory Tool

    A. Federal Requirements

    Americans with Disabilities Act (ADA) – Title II

    Applies to state and local governments and requires equal access to programs, services, and activities, including those delivered digitally.

    Learn more about ADA Title II requirements

    U.S. Department of Justice (DOJ) Final Rule (2024) – Digital Accessibility

    The U.S. Department of Justice adopted WCAG 2.1 Level AA as the required technical standard for web content and mobile applications.

    • Applies to websites, web applications, mobile apps, social media, and more
    • Establishes compliance timelines based on entity size
      • April 24, 2026: Public entities serving 50,000 or more people
      • April 26, 2027: Public entities serving fewer than 50,000 and all special district entities

    Read the 2024 DOJ digital accessibility final rule

    Read the DOJ's Fact Sheet:  New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments

    Read the DOJ's Small Entity Compliance Guide

    Section 504 of the Rehabilitation Act

    Applies to entities receiving federal financial assistance and requires nondiscrimination on the basis of disability.

    Read Section 504 regulations

    Section 508 of the Rehabilitation Act

    Applies directly to federal agencies but is widely used as a benchmark and is referenced in California law for electronic and information technology.

    Learn more about Section 508 and information and communication technology accessibility standards

    B. California Requirements

    California Government Code section 11135

    Prohibits discrimination, including disability discrimination, in programs or activities that are conducted, operated, funded, or receive state financial assistance.

    Read CGC § 11135

    California Government Code section 7405

    Requires state entities to ensure that electronic and information technology is accessible and aligns with Section 508 standards. Importantly, it also requires certain contractual commitments addressing accessibility.

    Read CGC § 7405

    Taken together, § 11135 and § 7405 ensure that California public entities cannot fall back on gaps in federal coverage. Where federal funding may be limited, stated funding triggers § 11135. Where procurement and technology contracting are involved, § 7405 establishes an affirmative state-law basis for the same accessibility requirements already present under federal law.

    C. California Civil Rights Exposure

    Unruh Civil Rights Act (California Civil Code section 51)

    Provides an additional layer of liability in California by prohibiting disability discrimination and allowing private lawsuits.

    • Can be asserted alongside ADA claims
    • Provides for statutory damages in qualifying cases

    Read CIV § 51

    Key takeaway: Public entities in California operate within a layered legal framework. Even where one law may not apply directly, others may still create obligations or legal exposure.

    Rather than defining accessibility requirements independently, laws and regulations rely on established technical standards. The authoritative source for these standards is the W3C.

    Core Standard - Web Content Accessibility Guidelines (WCAG)

    WCAG defines how to make digital content more accessible to people with disabilities.

    Review the WCAG overview

    Read the WCAG 2.2 recommendation

    These guidelines are not static - they evolve over time to reflect changes in technology, user needs, and best practices. As a result, WCAG published in versions, with each new version building on the previous one by adding or refining success criteria. This means organizations should pay attention not just to "WCAG compliant", but to which version and level they are aligning with, as expectations continue to advance. 

    Important context:

    • The DOJ rule references WCAG 2.1 Level AA
    • W3C recommends using the most current version where feasible
    • WCAG is organized around four principles: Perceivable, Operable, Understandable, and Robust

    Supporting Guidance

    Review WCAG Fundamentals

    Learn how to evaluate web accessibility

    These resources are especially useful for developers, designers, content creators, and quality assurance or testing teams.

    Key takeaway: WCAG is the technical standard that organizations build and test against. Policies, audits, and remediation efforts all point back to it.

    These resources provide foundational knowledge and practical skills at no cost.

    W3C Digital Accessibility Foundations Course

    A strong general introduction for both technical and non-technical staff.

    Access the W3C Digital Accessibility Foundations Course

    Section508.gov Training

    Covers accessibility across roles including procurement, design, development, and content creation.

    Access Section508.gov accessibility training

    Department of Homeland Security (DHS) Section 508 Training Program

    Practical training for creating and testing accessible digital content.

    Access DHS Section 508 training

    Key takeaway: Start with broad awareness training across staff, then move into role-specific training for developers, content authors, procurement teams, and others with implementation responsibilities.

    This section provides templates and tools that can support implementation and ongoing program management.

    The ADA National Network has created an ADA Title II Action Guide for State and Local Governments, including, 7 Steps to Implement the ADA

    Access the Action Guide

    A. Public-Facing Resources

    W3C Accessibility Statement Generator

    Create a standardized accessibility statement for your organization.

    Use the W3C Accessibility Statement Generator

    B. Evaluation and Reporting

    W3C Accessibility Evaluation Report Template

    Provides a standard structure for documenting audit results.

    View the W3C accessibility evaluation report template

    WCAG-EM Report Tool

    Interactive tool for generating accessibility evaluation reports.

    Use the WCAG-EM report tool

    C. Procurement and Vendor Evaluation

    VPAT (Voluntary Product Accessibility Template)

    Industry-standard format for vendor accessibility conformance reporting.

    Access VPAT resources

    Download VPAT 2.5Rev WCAG (April 2025)

    Section508.gov – Buy Accessible ICT

    Guidance for incorporating accessibility into procurement processes.

    Access Section508.gov procurement guidance

    Access Accessibility Requirements Tool (ART) to assist with generating procurement requirements

    Develop a Procurement Plan

    Developing a procurement plan establishes a structured approach to acquisition across the full contract lifecycle - helping the entity define requirements, evaluate vendors, manage performance, and ensure a more efficient and successful procurement process from initial solicitation through ongoing contract management.

    Access additional guidance on procurement

    Members may benefit from maintaining internal templates and working documents such as:

    • Accessibility policy
    • Accessibility statement
    • Vendor accessibility questionnaire
    • VPAT or accessibility conformance report review checklist
    • Accessibility audit intake form
    • Remediation roadmap
    • Issue tracking log
    • Exception or risk acceptance documentation
    • Certification checklist, where applicable

    E. Tools

    A substantial body of guidance, tools, and training already exists - so when you identify gaps or opportunities to improve compliance, leverage established resources and frameworks rather than starting from scratch.

    • ADA National Network (800) 949-4232
    • Department of Justice’s ADA Information Line (800) 514-0301
    • View Colorado Governor's Office of IT - Digital Accessibility Law for Colorado State and Local Government
      • Colorado has taken a more prescriptive and proactive approach to digital accessibility than many states, establishing clear requirements and expectations for public entities. Even for organizations outside Colorado, their materials can serve as a useful benchmark and starting point for building or refining an accessibility program.

    While many vendors operate in this space, PRISM has direct experience working with the organizations below and can speak to their capabilities.

    UsableNet Resources

    PRISM has partnered with UsableNet for addressing website accessibility via their managed service offering (UsableNet Assistive) and is leverages their testing software - AQA.  In addition to these offerings, they can provide accessibility audits, manual expert testing, testing with assistive-technology users, training for design and development teams, and strategy and consulting. 

    Key characteristics:

    • Developer-led (not automation alone)

    • AI-assisted testing and prioritization

    • Ongoing maintenance and regression prevention

    • Minimal lift required from internal teams

    • Initial improvements typically delivered with ~60 days

    • Deployment does not require backend or server access

    • Includes legal support and indemnity protections

    WebAIM Resources

    WebAIM (Web Accessibility In Mind) has provided comprehensive web accessibility solutions since 1999. These years of experience have made WebAIM one of the leading providers of web accessibility expertise internationally. WebAIM is a non-profit service center at Utah State University.  Their services include training, evaluation, and technical assistance and consulting.  PRISM has engaged with WebAIM for both training and evaluation services.  Additionally, they've developed and support WAVE (Web Accessibility Evaluation Tool) which is a suite of evaluation tools that help web authors evaluate accessibility of their web content.