Updated May 2026 · DOJ Title II in force

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Key Deadline
Apr 24

Title II rule takes effect for state and local government websites.

Coverage Across
  • WCAG 2.2
  • ADA
  • EAA
  • Section 508
  • ACA
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What is ADA compliance for websites?

The Americans with Disabilities Act of 1990 bans discrimination based on disability. For websites, that means your site has to be usable by people who navigate with screen readers, keyboards, voice control, magnification, and other assistive tools.

The law itself does not name a technical standard. So the courts settled on one. Since 2017, US federal courts have used the Web Content Accessibility Guidelines (WCAG)as the yardstick. WCAG 2.1 AA was the baseline through 2025. From April 2026, the Department of Justice's Title II rule formalizes WCAG 2.1 AA for state and local government websites, with most private sector cases now citing WCAG 2.2 AA.

Key Takeaway
The ADA doesn't spell out the technical bar. Courts have. WCAG 2.1 AA is the floor. WCAG 2.2 AA is what defensible compliance looks like in 2026.

Who has to comply

The short answer is almost everyone with a public-facing website.

The Department of Justice and federal courts have ruled that websites of “places of public accommodation” fall under ADA Title III. That covers retail, restaurants, healthcare, hospitality, finance, education, and most other commercial sectors. Title II covers state and local government websites and has a specific 2026 deadline.

  • Title I: employer websites used by employees or applicants
  • Title II: state and local government websites (April 2026 deadline for entities with 50,000+ residents)
  • Title III: private business websites tied to public accommodation

If your business has a physical storefront, sells to consumers online, or operates in healthcare, education, or finance, your website is in scope. Period.

ADA vs WCAG, in one minute

Two terms get conflated all the time. They're different.

ADA

A US civil rights law from 1990. Enforced by the DOJ and by private plaintiffs. Doesn't tell you how to comply.

WCAG 2.2

A technical standard from the W3C. Tells you exactly what to do. Used by courts as the yardstick for ADA cases.

WCAG is organized around four principles, often called POUR: Perceivable, Operable, Understandable, Robust. Each principle has testable success criteria graded as A, AA, or AAA. AA is the practical bar for ADA compliance.

What changed in 2026: the Title II rule

In April 2024, the DOJ published a final rule under Title II of the ADA. It explicitly requires state and local government websites and mobile apps to conform to WCAG 2.1 Level AA. The compliance dates fell in 2026.

Entity sizeCompliance deadline
Public entities serving 50,000 or more peopleApril 24, 2026
Public entities serving fewer than 50,000 people, and special district governmentsApril 26, 2027

While the rule itself only binds Title II entities, courts cite it as evidence of what reasonable compliance looks like. That raises the bar for private sector defendants too.

Penalties, lawsuits, and what they actually cost

Here's the part that gets boards moving.

Most ADA web cases never see a courtroom. They start with a demand letterfrom a plaintiff's firm, citing specific WCAG failures on your site. Settlement typically lands between $25,000 and $50,000 for a first letter, plus a binding remediation commitment.

Repeat letters cost more. Class actions cost a lot more.

The DOJ can also pursue civil penalties of up to $96,384 for a first violation and $192,768 for each subsequent one. Those numbers are indexed and rise each year.

And the volume keeps climbing. ADA web filings in US federal courts crossed 4,600 in 2025. The same plaintiff firms file hundreds of cases per year, often targeting any site with obvious automated-test failures.

The POUR checklist (skim version)

If you only have ten minutes, scan against the four POUR principles. The full 12-point checklist is right below.

Wondering where your site actually stands?

Drop in a URL. Zylyn scans against WCAG 2.2 in 90 seconds, with issues grouped by severity.

The 12-point POUR checklist

Three things to verify under each WCAG principle. Pass these and you're past the most common lawsuit triggers.

  • Perceivable

    • Alt text on every image
    • 4.5:1 color contrast on body text
    • Captions and transcripts on video
  • Operable

    • Full keyboard navigation, no traps
    • Visible focus states everywhere
    • Skip-to-content link in the header
  • Understandable

    • Form labels and helper text
    • Clear, specific error messages
    • Consistent navigation across pages
  • Robust

    • Valid, semantic HTML
    • ARIA used correctly, not as decoration
    • Tested with a real screen reader

Want the full 47-point checklist? A free PDF with every WCAG 2.2 AA criterion, plain-English explanations, and code-ready fixes.

Download free PDF

How Zylyn gets you compliant.

Three tools, one platform. Use the audit to find what's broken, the widget for instant user-facing relief, and the reports to track real progress in code.

  • Free WCAG Audit

    Scan any URL against WCAG 2.2 in 90 seconds. Issues are grouped by severity with code-ready fix suggestions and direct links to the relevant criterion.

    Start a free scan
  • Most Popular

    Accessibility Widget

    User-first controls for text size, contrast, motion, font, and cursor. One-line install. Gives real users immediate relief while you fix the underlying code.

    See the widget
  • Audit Reports

    Export findings to PDF or CSV. Schedule re-scans, track progress over time, and push remediation tasks into your existing workflow tools.

    See a sample

Real teams, real results.

Companies use Zylyn to cut manual testing time, ship accessibly, and stay ahead of demand letters.

“We've reduced manual accessibility testing time by over 70%. It flags issues in real-time and even suggests fixes. Our audit process is now faster and more reliable.”
Neha BhatSenior QA Engineer
4.8
G2 · Capterra
Case Study
How PDXSigning hit WCAG 2.2 AA in 14 days
Read story

Frequently asked questions

The questions that come up most often from teams getting started on ADA compliance.

US courts have consistently held that websites of places of public accommodation fall under ADA Title III. Title II covers state and local government websites and has a hard April 2026 deadline for WCAG 2.1 AA conformance. In practice, almost every public-facing US business website is in scope.

Settlements for a first ADA web demand letter average $25,000 to $50,000. Repeat or class-action cases can exceed $250,000. DOJ civil penalties can reach $96,384 for a first violation and $192,768 for each subsequent one.

ADA is a US civil rights law that applies to private and public accommodation. Section 508 applies only to US federal agencies and their contractors. The European Accessibility Act applies to private sector products and services sold in the EU after June 2025. The good news: all three lean on WCAG, so one compliance program covers most of them.

A widget alone is not enough. Genuine compliance comes from fixing the underlying code. The defensible posture in court is a widget plus a documented remediation plan, regular audits, and tracked progress. Zylyn combines all three.

At minimum, run a full audit quarterly and a scan on every major release. Accessibility regressions are common after redesigns or component library upgrades. Zylyn supports scheduled scans so issues get caught the day they ship.

WCAG 2.2 was published in October 2023 and adds nine new success criteria on top of 2.1. The focus is mobile interaction, users with cognitive disabilities, and people using authentication flows. 2.2 is backward-compatible, so meeting 2.2 AA also satisfies 2.1 AA.

Yes, if your business is a place of public accommodation under Title III, size doesn't get you off the hook. Plaintiff firms regularly target small business sites because they often have the most obvious accessibility failures. The good news is that running Zylyn's free audit and fixing the top issues handles most of the lawsuit risk.

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