The DOJ published an Interim Final Rule on April 20, 2026, extending ADA Title II web accessibility deadlines by one year. Public entities with populations of 50,000 or more now have until April 26, 2027, while smaller entities have until April 26, 2028.
If you're a compliance officer or accessibility program manager Assistive Technology a state or local government entity, you need a structured compliance plan that works regardless of your deadline. This template provides a framework to document your Title II conformance strategy, assign ownership, and track progress toward WCAG 2.1 Level AA conformance.
Purpose of the Template
This compliance plan template structures how your organization will meet ADA Title II web and mobile accessibility requirements. It's designed for:
- State and local government entities subject to Title II
- Public universities, courts, school districts, and special districts
- Compliance officers who need to document a defensible conformance strategy
- Program managers coordinating remediation across multiple departments
The template addresses WCAG 2.1 Level AA conformance requirements, establishes accountability for time-based media, and creates a governance structure that survives staff turnover and budget cycles.
Prerequisites
Before customizing this template, you'll need:
- Inventory of digital properties: List every public-facing website, mobile app, web application, video platform, document repository, and social media channel your entity operates or funds.
- Baseline conformance data: Results from automated scanning (axe DevTools, WAVE, Lighthouse) and manual testing against WCAG 2.1 Level AA.
- Media audit: Count of videos, podcasts, and audio content that require captions, transcripts, or audio description.
- Stakeholder map: Names and roles of department heads, web managers, content owners, procurement officers, and legal counsel who'll execute the plan.
- Budget authority: Confirmed funding source for remediation, testing, training, and ongoing conformance monitoring.
If you don't have baseline conformance data yet, your first action item is to commission an accessibility audit. You can't build a defensible plan without knowing what you're remediating.
The Template
PUBLIC ENTITY ADA TITLE II DIGITAL ACCESSIBILITY COMPLIANCE PLAN
[Entity Name]
Compliance Deadline: [April 26, 2027 or April 26, 2028]
Plan Owner: [Name, Title]
Last Updated: [Date]
---
1. SCOPE AND APPLICABILITY
This plan applies to all web content and mobile applications operated by or on behalf of [Entity Name] that provide services, programs, or activities to the public under ADA Title II.
Covered Digital Properties:
- [List each website, subdomain, web application, mobile app]
- [Include contractor-hosted platforms if they deliver public services]
Excluded Properties (with justification):
- [Archive sites with historical content predating compliance date]
- [Third-party platforms where entity is not the content owner]
---
2. CONFORMANCE STANDARD
All covered properties must conform to Web Content Accessibility Guidelines (WCAG) 2.1 Level AA.
This standard requires:
- Perceivable: Captions for video, transcripts for audio, text alternatives for images, sufficient color contrast (4.5:1 for normal text)
- [Operable](/glossary/operable): Full keyboard access, no keyboard traps, skip links, focus indicators
- [Understandable](/glossary/understandable): Clear labels, consistent navigation, [error identification](/glossary/error-identification) and correction
- [Robust](/glossary/robust): Valid HTML, proper ARIA usage, compatibility with assistive technology
---
3. ROLES AND RESPONSIBILITIES
Compliance Officer: [Name]
- Overall plan execution and reporting to executive leadership
- Budget management and vendor oversight
- Liaison to DOJ and legal counsel
Web Accessibility Coordinator: [Name]
- Day-to-day remediation coordination
- Developer training and support
- [Conformance testing](/glossary/conformance-testing) and documentation
Department Liaisons: [List by department]
- Content audits within their domain
- Remediation of owned content
- Ongoing conformance for new content
Procurement Officer: [Name]
- [Accessible procurement](/glossary/accessible-procurement) policy enforcement
- Vendor VPAT review and contract language
---
4. BASELINE ASSESSMENT
[Summarize current state. Example:]
- Automated scan (axe DevTools) identified 2,847 WCAG violations across 156 pages
- Manual testing found 23 critical keyboard access issues
- Video audit: 412 videos lack captions; 89 instructional videos require audio description
- PDFs: 1,203 documents not tagged for screen reader access
Priority 1 Issues (blocking access):
- [List specific barriers: missing captions, keyboard traps, unlabeled forms]
Priority 2 Issues (degraded experience):
- [List: contrast failures, missing alt text, inconsistent navigation]
---
5. REMEDIATION PLAN
Phase 1 (Months 1-3): Critical Barriers
- Caption all public-facing video content
- Fix keyboard access issues on transaction pages (payments, applications, registrations)
- Remediate top 50 high-traffic pages to full WCAG 2.1 Level AA
Phase 2 (Months 4-8): Comprehensive Remediation
- Audit and tag all public-facing PDFs
- Add audio description to instructional and emergency videos
- Remediate remaining web pages by traffic volume
- Deploy accessible content management system templates
Phase 3 (Months 9-12): Governance and Monitoring
- Implement automated conformance monitoring
- Train content authors and developers
- Establish quarterly accessibility review cycle
- Document exceptions and remediation timelines
---
6. TIME-BASED MEDIA REQUIREMENTS
All video and audio content must include:
- Captions: Synchronized, accurate, speaker-identified
- Transcripts: For audio-only content (podcasts, public meetings)
- Audio Description: For instructional, educational, and emergency video where visual information is essential to understanding
Vendor: [Name of captioning/audio description provider]
Turnaround: [Standard SLA]
Quality Standard: 99% accuracy for captions; audio description reviewed by subject matter expert
---
7. PROCUREMENT AND VENDOR MANAGEMENT
All new digital products, platforms, and services must include:
- [Accessibility Conformance Report](/glossary/accessibility-conformance-report) based on [Voluntary Product Accessibility Template](/glossary/voluntary-product-accessibility-template) (VPAT)
- Contractual requirement to maintain WCAG 2.1 Level AA conformance
- Remediation timeline for known non-conformance issues
Procurement Officer will reject any vendor proposal that does not include a current Accessibility Conformance Report.
---
8. TRAINING REQUIREMENTS
Required Training (Annual):
- Web developers: WCAG 2.1 Level AA technical requirements, ARIA usage, keyboard testing
- Content authors: Accessible document creation, alt text, caption ordering
- Procurement staff: VPAT review, accessible procurement policy
Recommended Certification:
- Accessibility Coordinator: [Web Accessibility Specialist](/glossary/web-accessibility-specialist) (Web Accessibility Specialist) or [Certified Professional in Accessibility Core Competencies](/glossary/certified-professional-in-accessibility-core-competencies) (CPACC)
---
9. ONGOING CONFORMANCE MONITORING
Automated Scanning:
- Tool: [axe Monitor, Siteimprove, or similar]
- Frequency: Weekly for high-traffic pages; monthly for full site
- Alerts: Email to Web Accessibility Coordinator for new critical issues
Manual Testing:
- Frequency: Quarterly for top 100 pages
- Method: [Screen reader testing](/glossary/screen-reader-testing) (NVDA, JAWS), keyboard-only navigation
- Documentation: Issues logged in [ticketing system]
User Feedback:
- Accessibility feedback form on every page
- Response SLA: 5 business days
- Tracking: All feedback logged and reviewed monthly
---
10. DOCUMENTATION AND REPORTING
Quarterly Report to Executive Leadership:
- Conformance status by property
- Remediation progress against timeline
- Budget utilization
- Outstanding issues and risks
Annual Public [Accessibility Statement](/glossary/accessibility-statement):
- Published on homepage
- Describes conformance status, known issues, and contact for accessibility concerns
- Updated within 30 days of any material change
---
11. EXCEPTION PROCESS
If full conformance is not achievable by the deadline for a specific property:
1. Document the [barrier](/glossary/barrier) and why remediation is infeasible
2. Describe alternative means of access provided
3. Establish remediation timeline
4. Obtain legal counsel review
5. Include in public accessibility statement
Exceptions require approval by [Compliance Officer and Legal Counsel].
---
12. BUDGET
Total Allocated: $[Amount]
- Remediation services: $[Amount]
- Captioning and audio description: $[Amount]
- Testing and monitoring tools: $[Amount]
- Training: $[Amount]
- Contingency (10%): $[Amount]
---
APPROVAL
[Signature, Executive Leadership]
[Date]
Customizing the Template
Section 1 (Scope): List every domain and subdomain your entity operates. Include contractor-hosted platforms if they deliver services on your behalf. If you're a public university, this includes your LMS, streaming platform, and department sites.
Section 4 (Baseline Assessment): Insert your actual audit results. If you don't have numbers yet, write "Baseline assessment in progress; results expected by [date]."
Section 5 (Remediation Plan): Adjust the timeline based on your compliance deadline. Larger entities (April 26, 2027 deadline) should compress Phases 1-2 into the first six months. Smaller entities have more runway but should still front-load critical barriers.
Section 6 (Time-Based Media): If your entity produces significant video content, this section is your highest-risk area. Specify your captioning vendor, turnaround time, and quality standard. If you're using automated captions, note that they don't meet WCAG conformance without human review.
Section 9 (Monitoring): Choose one automated scanning tool and commit to a frequency. Weekly scans for high-traffic pages catch regressions before they accumulate. Monthly full-site scans keep your documentation current.
Section 11 (Exception Process): Use this sparingly. Exceptions are defensible only when you've documented why conformance is technically or financially infeasible and what alternative access you're providing. Legal counsel should review every exception before you publish it.
Validation Steps
Once you've customized the template:
Cross-check against the 2024 Title II rule: Confirm your plan addresses web content, mobile applications, and time-based media. Verify you're using WCAG 2.1 Level AA as the standard.
Verify budget alignment: Confirm your allocated budget covers the scope in Section 5. If it doesn't, either reduce scope or document the funding gap and escalate.
Test stakeholder buy-in: Circulate the draft to department liaisons and procurement. If they push back on timelines or responsibilities, resolve it now, not six months into execution.
Legal review: Your compliance officer and legal counsel should approve the final plan before you publish it. This document may be discoverable in future litigation.
Publish the plan: Post a summary version (Sections 1, 2, 10, and 12) as part of your public accessibility statement. Transparency reduces legal risk and builds trust with the disability community.
The extended deadline gives you time to build this plan correctly. It doesn't give you permission to delay starting. If your entity hasn't begun remediation, this template is your first deliverable.
