Reviewed September 30, 2026
ADA Title II and Title III
ADA compliance for websites
The Americans with Disabilities Act requires businesses open to the public, and state and local governments, to give people with disabilities equal access to their services. The Department of Justice treats websites and apps as part of that duty.
Who has to comply?
Title III covers private places of public accommodation: stores, hotels, restaurants, banks, healthcare, and other businesses that serve the public. Title II covers state and local government programs. Federal agency sites follow Section 508, which is a separate statute.
In April 2024 the DOJ issued a Title II rule that sets WCAG 2.1 Level AA as the technical standard for state and local government web content and mobile apps. On April 20, 2026 the DOJ extended the dates: governments with a population of 50,000 or more have until April 26, 2027, and smaller governments and special districts have until April 26, 2028. The dates and who they cover are on the Title II web rule page. The fact sheet is on ADA.gov.
What does “compliant” mean in practice?
WCAG is organized into four principles. A page passes when each applicable success criterion is met, not when a scanner score looks high. Automated tools catch only a fraction of failures. The rest show up in keyboard checks, screen reader checks, and review of forms, video, and documents.
- Perceivable: text alternatives, captions, contrast of at least 4.5:1 for normal text.
- Operable: every function available by keyboard, no keyboard trap, visible focus.
- Understandable: labels, instructions, and error messages that identify the field and how to fix it.
- Robust: name, role, and value exposed to assistive technology, including custom widgets.
What does a program that holds up include?
- Audit the templates people actually use: home, navigation, search, account, checkout, and PDFs.
- Fix failures in code and content. Do not rely on an overlay to rewrite the page after it loads.
- Retest with a keyboard and at least one screen reader, then publish the remaining issues.
- Train whoever publishes new pages, and recheck when the design system changes.
What should you ignore?
A badge that says “ADA compliant” is not a success criterion. A city-by-city landing page that repeats the same paragraph does not make a business local, and it does not fix a form. The work that changes access is on the templates: names, keyboard paths, contrast, errors, captions, and documents. The DOJ’s own explanation of how the ADA applies to the web is ADA.gov web guidance.
Questions and answers
Does the ADA apply to websites?
Yes. The U.S. Department of Justice says the ADA covers the websites and mobile apps of businesses open to the public and of state and local governments. Guidance: https://www.ada.gov/resources/web-guidance/
Which technical standard applies?
For state and local governments, the DOJ Title II web rule requires WCAG 2.1 Level AA. WCAG 2.2 is the current W3C Recommendation and is backward compatible with 2.1. Specification: https://www.w3.org/TR/WCAG22/
Is an overlay widget the same as compliance?
No. WCAG success criteria apply to the page itself: text alternatives, keyboard access, names and roles, contrast, and error identification. A widget does not replace fixing those failures in the site.
Who is covered by Title II versus Title III?
Title II covers state and local government programs, including public schools, courts, libraries, and special districts. Title III covers private places of public accommodation, such as stores, hotels, restaurants, banks, and healthcare providers that serve the public. Federal agency sites follow Section 508, which is a separate statute.
Related guides
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