The DOJ has extended ADA Title II digital accessibility compliance deadlines by one year. This extension offers public entities and their compliance officers a chance to address conformance gaps that could have led to enforcement actions under the original timeline.
This checklist guides you on what to audit, fix, and document during this period. Each item includes the specific requirement, what completion looks like, and how to verify your work.
Checklist Overview
This checklist is for public entities subject to ADA Title II digital accessibility requirements. It assumes you have existing web properties (websites, mobile apps, electronic documents) and need to achieve WCAG 2.1 Level AA conformance before the extended deadline.
The checklist focuses exclusively on digital content and services delivered through web-based channels. It does not cover physical facility compliance or telecommunications relay services.
Prerequisites
Before starting, confirm:
- Authority to audit: You can run automated scans, manual tests, and assistive technology evaluations across all public-facing digital properties.
- Access to source code and CMS: Your team can modify HTML, CSS, JavaScript, and content management templates.
- Budget for remediation: Resources are allocated for developer time, third-party audits, or vendor support.
- Stakeholder buy-in: Department heads understand that accessibility fixes may require content rewrites, design changes, or feature deprecation.
If any prerequisite is missing, secure it first. Partial authority leads to partial conformance.
Compliance Checklist
1. Inventory All Digital Properties
List every website, web application, mobile app, PDF, and electronic form your entity publishes or maintains. Include third-party platforms where you post official content.
Completion looks like: A spreadsheet with columns for URL, content type, owner department, last update date, and estimated page/document count. You know exactly what needs testing.
2. Run Automated Accessibility Scans
Use an automated testing tool (axe DevTools, WAVE, Lighthouse) to scan representative pages from each property. Focus on home pages, top-level navigation, forms, and high-traffic content.
Requirement reference: WCAG 2.1 Level A and AA Success Criteria
Completion looks like: A report showing violation counts by Success Criterion, organized by property. You can prioritize fixes based on severity and frequency.
3. Test Forms with Keyboard and Screen Reader
Navigate every form using only the keyboard. Then test with a screen reader (NVDA on Windows, VoiceOver on macOS). Verify that labels are announced, error messages are programmatically associated with fields, and required fields are marked.
Requirement reference: WCAG 2.1 SC 1.3.1, SC 3.3.2, SC 4.1.3
Completion looks like: Every form field has a visible label and programmatic label. Error messages appear in the accessibility tree and are announced by assistive technology. You can complete and submit forms without touching a mouse.
4. Audit Color Contrast Ratios
Measure contrast between text and background colors using a contrast checker. Test normal text (4.5:1 minimum) and large text (3:1 minimum). Include button text, link text, and placeholder text.
Requirement reference: WCAG 2.1 SC 1.4.3
Completion looks like: A style guide showing compliant color pairings. No text fails contrast requirements. Designers reference the guide when creating new content.
5. Add Alternative Text to Images
Write descriptive alt text for informative images. Use alt="" for decorative images. For complex images, provide long descriptions via aria-describedby or adjacent text.
Requirement reference: WCAG 2.1 SC 1.1.1
Completion looks like: Every <img> tag has an alt attribute. Screen reader users receive equivalent information. Content editors have written guidelines for alt text creation.
6. Provide Captions and Transcripts for Video
Add closed captions to all video content. Provide transcripts that include spoken dialogue, sound effects, and speaker identification. For prerecorded video with important visual information, add audio description.
Requirement reference: WCAG 2.1 SC 1.2.2, SC 1.2.8
Completion looks like: Every video has a WebVTT caption file. Transcripts are posted on the same page as the video or linked from the Audio Description. Audio description tracks are available for content where visual information is not conveyed in dialogue.
7. Fix Heading Structure
Ensure pages use heading tags (<h1> through <h6>) in hierarchical order. Do not skip levels. Use only one <h1> per page. Headings should describe the content that follows.
Requirement reference: WCAG 2.1 SC 1.3.1, SC 2.4.6
Completion looks like: A screen reader user can navigate by headings and understand page structure. The heading outline makes logical sense when viewed in isolation.
8. Make PDFs Accessible or Replace Them
Tag existing PDFs with proper structure. If a PDF cannot be remediated, replace it with an accessible HTML page or Word document. Do not publish scanned images as PDFs.
Requirement reference: PDF/UA, WCAG 2.1 Level AA
Completion looks like: PDFs pass the Accessibility Checker in Adobe Acrobat. Reading order is logical. Forms have fillable fields with labels. Alternatively, you have eliminated PDFs in favor of web-based content.
9. Document Accessibility Conformance
Create an Accessibility Conformance Report using the Voluntary Product Accessibility Template (VPAT). Publish an accessibility statement on your website explaining conformance level, known issues, and contact information for accessibility complaints.
Completion looks like: A public-facing accessibility page with a link in the footer. The statement includes a conformance claim (WCAG 2.1 Level AA), date of last evaluation, and email address for reporting barriers.
10. Train Content Creators
Provide accessibility training to staff who publish web content, create documents, or post social media. Cover alt text, heading structure, link text, and color contrast.
Completion looks like: Every content creator has completed a training module. They can identify common accessibility errors and know where to find internal guidance. Training records are maintained for audit purposes.
Common Mistakes
Relying solely on automated testing: Automated tools catch 30-40% of WCAG violations. Supplement with manual keyboard testing and screen reader evaluation.
Treating accessibility as a one-time project: Conformance degrades over time as new content is added. You need ongoing monitoring and governance.
Ignoring third-party content: Embedded widgets, social media feeds, and vendor-provided tools are your responsibility under ADA Title II. If you publish it, you own its accessibility.
Publishing a VPAT without testing: A Voluntary Product Accessibility Template is a report of actual conformance, not a declaration of intent. Do not claim conformance you have not verified.
Next Steps
After completing this checklist, schedule quarterly conformance audits to maintain compliance. Assign accountability: designate a person or team responsible for monitoring new content, responding to complaints, and updating your accessibility statement.
The extension gives you time to build sustainable processes. Use it to shift from reactive fixes to proactive governance. When the extended deadline arrives, your conformance should be verifiable, documented, and maintained through routine oversight.
