On January 8, 2025, the Department of Justice (DOJ) released “first steps" guidance to help public entities comply with the new Title II web accessibility rules. Those rules are firmly aligned with the Web Content Accessibility Guidelines (WCAG) 2.1, which are widely considered to be the international standards for digital accessibility.
In fact, the DOJ’s Title II rules specifically require conformance with WCAG Level AA. For state and local governments, that’s great news: Prior to 2024, the ADA had no specific technical requirements for web access, and WCAG provides clear, testable criteria.
However, the DOJ’s new guidance for Title II isn’t just for public institutions. By laying out the first steps for digital accessibility initiatives, the DOJ has provided all organizations — including private businesses — with a comprehensive roadmap for compliance.
The DOJ outlines 11 “action steps" for building an ADA compliance strategy
While several of the steps are specific to government entities, they’re generally good advice for adopting an accessible mindset. Here’s a brief overview:
- Learn about the new rule’s requirements. For web content, those requirements are essentially just WCAG 2.1 Level AA, though public entities have other obligations unrelated to digital accessibility.
- Figure out when you need to fully comply with the rule. The DOJ’s rule has different deadlines for organizations of various sizes; the first deadline is for state or local governments with a population of 50,000 or more, and takes effect on April 24, 2026.
- Figure out who within your state or local government will have a role in complying with the rule. Identifying key stakeholders and assigning clear responsibilities can help to keep the initiative on track.
- Train your staff. Everyone has a role to play — not just web developers — so training is crucial. Learn how digital accessibility training can help businesses and government agencies.
- Identify what web content and mobile apps your public entity has. All online content must be accessible, including apps, videos, and downloadable documents (such as PDFs).
- Refresh your understanding of the rule’s exceptions. There aren’t many exceptions for compliance, but they’re practically important; learn about potential ADA exceptions from this AudioEye post.
- Determine which of your web content and mobile apps need to comply with WCAG 2.1 under the rule.
- Determine what accessibility fixes are needed. The DOJ recommends using resources from the World Wide Web Consortium (W3C), which publishes WCAG. The W3C recommends a combination of manual and automated audits; learn about the differences between manual and automated accessibility testing.
- Prioritize which content to fix first. Few organizations have the resources to fix everything at once, so the best practice is to target issues that are likely to have a severe impact on real-life users.
- Identify any relevant contracts with vendors and figure out if they can produce accessible content for you, or if you need to make any changes.
- Create policies. Strong accessibility policies provide for sustainable, long-term compliance. Without regular reviews and upkeep, new accessibility issues are inevitable.
Once again, some of the DOJ’s guidance is specific to government agencies. But if you’re looking for a basic introduction to web accessibility, most of the document is applicable — and if you’re trying to build the case for accessibility to other stakeholders in your organization, the DOJ guidance can help to remove some of the uncertainty around Title III compliance.
Related: What Do the Justice Department's New ADA Standards Mean for Private Businesses?
Get help for compliance with the ADA’s Title II or Title III web accessibility requirements
A knowledgeable accessibility partner can help you train staff, develop policies, test content, and perform remediations. At AudioEye and the Bureau of Internet Accessibility, we combine powerful automation with guidance from human experts, including people with disabilities who regularly use screen readers and other assistive technologies (AT).
We believe that our approach provides the best path to compliance with a focus on self-sustainable results. To learn more, send us a message or get started with a free website accessibility scan from AudioEye.