The Ultimate Guide to Web Accessibility, Part 1: Understanding Accessibility and Compliance

A resident tries to renew a business license online and gives up because the form doesn’t work with their screen reader. Someone tries to find the agenda for tonight’s city council meeting and can’t because it’s a scanned PDF with no readable text. Digital accessibility barriers like these can prevent residents from independently accessing government information and services.

Under Title II of the Americans with Disabilities Act (ADA), the Department of Justice (DOJ) requires state and local governments to make their web content and mobile applications (apps) conform to WCAG 2.1 Level AA. Yet knowing this rule applies is different from understanding what it requires and how it fits into the broader web accessibility landscape.

This two-part guide provides that foundation. Part 1 covers the accessibility requirements local governments need to understand, how WCAG fits into them, and the common barriers that can prevent residents from accessing digital information and services. Part 2, coming later in 2026, gets into the how: implementing, testing, and maintaining accessibility across websites and digital content.

What Is Web Accessibility?

Web accessibility means designing and developing websites, tools, technologies, and other digital assets so people with disabilities can use them. People should be able to perceive, understand, navigate, interact with, and contribute to the web. For local governments, that applies across the digital experience residents use to access information and services, including websites, documents, and apps.

Making those experiences accessible requires accounting for the different ways people interact with digital content. Some people use assistive technologies. For instance, a person who is blind or has low vision may use a screen reader or screen magnifier. And someone who can’t use a mouse may navigate a website using a keyboard or voice recognition software. A digital asset built without these tools in mind creates barriers for residents and can prevent them from completing a task or getting the info they need.

And because local governments continually publish and update digital content, accessibility requires ongoing attention. Every new page, document, or application can introduce accessibility barriers.

Who Must Comply and When?

With compliance deadlines in 2027 and 2028, organizations have time to prepare, but they should start well before their deadline because the work can be extensive. Evaluating websites, remediating existing content, updating publishing processes, and training staff often require significant time and cross-department collaboration.

ADA Title II Deadlines

The DOJ extended the deadline, giving entities an additional year to comply. State and local governments must meet Level AA requirements on or before these dates:

Keep in mind that web accessibility requirements don’t start or stop after the deadlines. Title II of the ADA is the law of the land today: It already requires state and local governments to give residents equal access to programs and services, whether delivered in person or online.

What had been missing until recently was a clear technical definition of what “accessible” means in a digital context. The DOJ’s 2024 Title II Final Rule changed that. It named WCAG 2.1 Level AA as the specific standard that satisfies the ADA’s accessibility requirement for web content and mobile apps.

Right now, before your compliance deadline arrives, your organization is already expected to provide equal digital access under the ADA’s general standard. After the deadline, “accessible” means meeting that same WCAG 2.1 Level AA standard.

Who Has to Comply

All U.S. state and local governments, including special districts, school districts, and public universities (regardless of population size), must meet Title II of the ADA. This includes:

• State and local government offices that provide benefits and/or social services, like food assistance, health insurance, or employment services
• Public schools, including K-12, community colleges, and public universities
• State and local police departments
• State and local courts
• State and local election offices
• Public hospitals and public healthcare clinics
• Public parks and recreation programs
• Public libraries
• Amtrak and public transit agencies/commuter authorities

How Do Public Entities Comply?

While the full rules provide more detail, compliance boils down to aligning digital content to Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, including content provided through contractual, licensing, or other arrangements. That “digital content” refers to web content and mobile apps that entities provide or make available. This includes:

• Websites (including text, images, and audio)
• Mobile apps
• Online forms
• PDFs and other digital documents
• Public meeting materials
• Digital services and transactions
• Videos and multimedia
• Online payment systems

There are some exceptions, but these exceptions are narrow and shouldn’t be viewed as exemptions from broader accessibility responsibilities. To be considered exempt, web content and mobile apps must meet specific definitions and criteria.

Why Web Accessibility Matters for Local Governments

Web accessibility is a civil rights matter for local governments. Under the ADA, residents have a right to equal access to government information and services, whether they visit an office in person or use a website. And with more than one in four U.S. adults living with some type of disability, that access affects a substantial share of every community.

Accessible digital services let residents with disabilities handle everyday interactions with local government independently, whether they’re finding information, requesting a service, paying a bill, or weighing in on a public decision. When a digital barrier gets in the way, that same resident may have to call for assistance, make a trip to an office, or abandon the task altogether.

But digital accessibility can also make online content easier to use for people without disabilities. Someone watching a video with captions on when they can’t turn on the sound, a resident with a temporary injury, or a household on a slow internet connection all run into the same kinds of barriers that formal accessibility standards are designed to remove.

There’s a business case, too. When residents can find, understand, and use information independently, they have less reason to call or visit an office for help completing routine tasks. Accessible information also supports transparency, since more residents can find and use public information without assistance.

What’s WCAG and Why Does It Matter for Local Governments?

If your local government team publishes web content, WCAG already applies to your work. The Web Content Accessibility Guidelines (WCAG) are a set of internationally recognized standards for making digital content accessible to people with disabilities.

WCAG is developed and maintained by the World Wide Web Consortium (W3C) through its Web Accessibility Initiative. The W3C publishes the official WCAG documentation and supporting guidance. The WCAG 2 Overview and related documents are available through the W3C Web Accessibility Initiative.

While laws such as the ADA require state and local governments to provide equal access to services, whether in physical spaces or online, WCAG explains how to meet that obligation in the digital environment.

In other words:

• The ADA establishes the civil rights requirement
• The DOJ’s Final Rule specifies how to meet it in a digital context
• WCAG provides the roadmap for getting there

Understanding the Four WCAG Principles (POUR)

WCAG is organized around four core principles. Together, they define what accessible digital content must achieve. Content must be perceivable, operable, understandable, and robust.

These principles, often simply referred to as POUR, directly impact the PDFs, forms, meeting materials, and webpages that communications teams publish every day.

Related: Web Accessibility Checklist for Local Governments

Perceivable

Perceivable means information must be perceptible to people using only one of their senses, so they can understand all related content.

This goes beyond simply making content visible. For someone using a screen reader, images require alternative text. Headings must be structured correctly so the page can be navigated logically. Text needs sufficient color contrast to remain readable for residents with low vision.

When these elements are missing, the barrier is immediate. A budget chart uploaded as an image without a description may look complete to one resident and blank to another. Headings styled visually but not properly tagged may appear organized, yet screen reader users can’t move through the document efficiently.

If content can’t be perceived, access stops before it begins.

Operable

Operable means residents must be able to navigate and interact with content using different methods and tools.

Not every resident uses a mouse. Some rely entirely on a keyboard. Others use assistive technologies to navigate forms and interactive elements.

For instance, if an online permit form can’t be completed using keyboard navigation, the process effectively excludes certain residents. If focus indicators are missing, users may not know where they are on a page. If a session times out too quickly, a resident may lose progress before completing a submission.

In each case, the issue isn’t whether the information exists. It’s whether residents can successfully interact with it.

Understandable

Understandable means residents must be able to make sense of the content and know what to do next.

For communications teams, this often shows up in forms, applications, and service pages. Instructions need to be clear. Navigation labels need to match the content they lead to. Error messages must explain what went wrong and how to fix it.

For example, if a resident submits a permit application and receives an error message that simply says, “Invalid entry,” they’re not going to know exactly what went wrong and how to fix it. Without clear guidance, the resident may not be able to complete the process independently.

Robust

Robust means content must work reliably with assistive technologies, now and in the future. This is where formatting decisions matter. A document may look polished on screen but fail behind the scenes.

For example, uploading a scanned, image-only PDF of meeting minutes may appear compliant because it enables online access. However, if a screen reader can’t interpret the text, the content isn’t accessible in practice. If headings are not properly tagged, screen readers can’t convey the structure. If tables lack header associations, the data may be read in the wrong order. If a PDF is scanned as an image, the text may not be readable at all.

Robust content relies on proper structure, machine-readable text, and accessible documents. Without that foundation, even well-written content can’t be reliably accessed by residents who use assistive technology.

WCAG Levels Explained

WCAG includes three levels of conformance: A, AA, and AAA. The three levels are designed to progressively enhance accessibility for users with disabilities.

Level A

Level A is the foundational level of WCAG.

It addresses the most basic accessibility barriers that can prevent residents from accessing content at all. But on its own, it does not represent comprehensive accessibility for local government websites, nor does it meet the DOJ’s rule on web accessibility.

Level AA

Level AA builds on Level A and addresses barriers that commonly affect how residents experience and complete tasks online. WCAG 2.1 Level AA is widely recognized as the benchmark for local governments and special districts. The DOJ establishes WCAG 2.1 Level AA as the technical standard under Title II of the ADA. For more information, the ADA’s Fact Sheet outlines this requirement.

At this level, accessibility moves beyond removing obvious blockers. It focuses on usability and clarity. It includes requirements related to color contrast, form labels, error identification, and navigation structure.

In practice, Level AA determines whether a resident can complete a process, not just access it. For example, a form field without a programmatically associated label may appear clear visually but prove confusing when accessed by a screen reader.

Level AAA

Level AAA represents the highest level of conformance. It includes all Level A and AA requirements and aims to make content usable by the widest possible audience.

However, the W3C notes that it’s not always possible to meet all Level AAA success criteria for entire websites due to cost, complexity, and technical limitations. That’s why WCAG 2.1 Level AA remains the realistic and widely recognized benchmark for state and local governments.

Common Web Accessibility Barriers

Most of these barriers come from ordinary content, design, and development decisions, not specialized technical problems. WebAIM’s 2026 analysis of the top one million home pages found low-contrast text on 83.9% of pages and missing alt text on 16.2% of all images.

Some of the most common web accessibility barriers include:

• Images without alternative text: Alt text, or alternative text, serves as a written description for digital images. Screen readers can’t interpret an image on their own. Without alt text, a resident using one loses whatever information that image was meant to convey. So, it’s important to include descriptive (and not generic) alt text.
• Poor heading structure and page organization: Headings help organize content, providing structure and flow. Proper formatting improves readability and user experience. Assistive technologies rely on this structure to interpret the page correctly, and AI and search engines use it to understand the content. Use clear heading hierarchy (H1 for page title, H2 for main sections, H3 for subsections, and so on) to make online content easy to navigate.
• Inadequate color contrast: Text can be difficult to read when there isn’t enough contrast between the text and its background, particularly for people with low vision or color vision deficiencies. WCAG sets minimum contrast ratios of 4.5:1 for normal text and 3:1 for large text (18pt or 14pt bold). Use a color contrast checker to verify compliance and adjust colors as needed.
• Keyboard navigation issues: Government websites should be fully navigable without a mouse to support users who can’t use a mouse or navigate websites without one. If menus, links, buttons, forms, or other interactive elements can’t be reached and operated with a keyboard, parts of the website may be inaccessible.
• Non-descriptive link text: Link text like “click here” or “learn more” tells a screen reader user nothing about where a link goes. Descriptive link text provides that context.
• Inaccessible online forms: Missing labels, unclear instructions, inaccessible error messages, and other form issues can prevent residents from completing applications, registrations, payments, and other online transactions.
• Videos and multimedia without accessible alternatives: Missing captions, transcripts, or audio descriptions can prevent residents from accessing information presented through audio or video. Without captions, a resident who is deaf or hard of hearing, or anyone watching without sound, may miss information communicated through audio. Without audio descriptions or another alternative that conveys important visual information, someone who is blind or has low vision may miss information communicated visually.
• Inaccessible PDFs and other documents: Many agencies have a large library of portal document formats (PDFs) on their website. PDFs often contain essential public information (like forms, reports, and meeting agendas) that residents rely on. Unless they fall into one of the DOJ’s narrow exceptions, the PDFs will need to conform to WCAG 2.1 AA. If these documents aren’t accessible, screen reader users or those using other assistive technologies can’t read them, creating barriers to critical services and compliance risks for local governments.

DocAccess removes the manual work of making PDFs accessible, automatically converting all current and future PDFs into screen reader-friendly, WCAG 2.1 AA-aligned HTML transcripts.

Accessibility barriers affect residents differently depending on their disability, how they access digital content, and what they’re trying to accomplish. Because websites, documents, forms, and other content are created and maintained by people across many departments, these barriers often show up inconsistently across a single site rather than in one predictable place.

Building on Your Accessibility Foundation

Understanding web accessibility is the first step toward creating digital services that more residents can access and use. From here, the work shifts from recognizing barriers to removing them: designing and building accessible websites, creating accessible content, testing what you’ve built, and putting a governance structure in place so content and services remain accessible.

Part 2 of this guide, coming later in 2026, covers exactly that: implementing, testing, governing, and maintaining accessible digital services.

See Where Your Website Stands Today

An accessibility scan can provide an initial view of common barriers across a website and identify areas that may need further review. It’s a useful starting point for organizations preparing to meet their compliance deadline or determining where to focus accessibility work.

CivicPlus offers a free web accessibility scan to help local governments identify potential accessibility issues on their websites.

Get a Free Web Accessibility Scan

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