Member Services

1. Legal and Regulatory Framework - What laws apply and what they require

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.