In March 2025, the U.S. Department of Justice (DOJ) withdrew 11 guidance documents related to the Americans with Disabilities Act (ADA). While the decision has drawn understandable concern within the accessibility community, it’s important to separate perception from reality: the legal responsibilities surrounding website and mobile accessibility have not changed.

If you manage digital platforms or advise organizations on compliance, here’s what you need to know — and why a strong focus on accessibility remains essential.

What Happened

On March 19, 2025, the Department of Justice (DOJ) under the Trump administration formally withdrew 11 technical assistance documents related to the Americans with Disabilities Act (ADA). These documents had historically provided businesses, public entities, and individuals with clarifications on how to meet various ADA requirements. Although they were never legally binding regulations, they were influential resources for understanding how the DOJ interpreted and enforced the ADA.

The rescinded documents addressed several aspects of physical accessibility, including:

• Accessible Parking Requirements: Clarifications around the minimum number, size, and placement of accessible parking spaces for businesses open to the public.
  
  
• Hotel Room Accessibility: Guidance on how many hotel rooms must be accessible and the features those rooms should include to accommodate guests with disabilities.
  
  
• Maintenance of Accessible Features: Expectations for maintaining accessible entrances, restrooms, and pathways to ensure access remains available over time, not just during construction or renovation.
  
  
• Hospital Visitation Policies During COVID-19: Temporary guidance that required hospitals to permit visitation by support persons for patients with disabilities during pandemic-related lockdowns.
  
  

The DOJ justified the withdrawal as part of a broader initiative to reduce what it termed “unnecessary regulatory burdens” on businesses, emphasizing the encouragement of economic growth. Officials indicated that removing these documents was intended to streamline guidance and prevent confusion over non-binding interpretations of ADA requirements.

Importantly, none of the documents specifically addressed the accessibility of websites, mobile applications, or other digital services. However, their withdrawal has created some unease across industries, as it signals a potential reduction in federal emphasis on detailed ADA compliance support, at least in the short term.

Without these technical assistance documents, businesses lose a layer of practical, DOJ-endorsed clarification that many relied on when interpreting their responsibilities. While the underlying law (the ADA) and its enforcement mechanisms remain unchanged, organizations now must navigate compliance more independently, relying on case law, industry best practices, and standards like the Web Content Accessibility Guidelines (WCAG) for guidance.

In short, the withdrawal removes explanatory resources, not the ADA itself. The legal requirements for accessibility, including digital accessibility, still apply and remain fully enforceable under federal law.

Digital Accessibility Requirements Are Unchanged

The ADA’s fundamental protections remain fully in effect and apply to digital environments. Despite withdrawing these documents, the DOJ has not provided guidance suggesting that digital spaces are exempt from accessibility obligations.

Over the past several years, courts across the United States have repeatedly found that websites and mobile applications fall within the ADA’s scope, particularly under Title III, which prohibits discrimination in places of public accommodation. Some courts require a direct connection between the digital service and a physical location. In contrast, others have taken a broader view, finding that purely online businesses can also fall under the ADA.

Regardless of slight variations in legal interpretation, a few points are clear:

• Failure to make a website or mobile app accessible can still expose a company to litigation.
  
  
• The DOJ maintains its position that businesses must offer equal access online.
  
  
• Settlements and enforcement actions typically reference WCAG 2.1 Level AA as the standard that businesses should meet.
  
  

Moreover, the DOJ had previously proposed formal rules for website accessibility for state and local governments and indicated an intent to extend similar rules to public accommodations. These efforts demonstrate that, far from backing away from digital accessibility, the federal government continues to recognize it as a critical civil rights issue.

In short, organizations cannot afford to assume that a shift in administrative tone changes their legal responsibilities. Accessibility is firmly embedded in modern ADA compliance.

Why Accessibility Remains a Business Imperative

Businesses might view regulatory rollbacks as an opportunity to slow-walk compliance initiatives, but doing so would be shortsighted. Digital accessibility is not just a regulatory expectation but an operational, reputational, and strategic priority.

1. Litigation Risks Remain High

The wave of lawsuits targeting inaccessible digital content shows no sign of slowing. Over the past five years, ADA digital accessibility lawsuits have increased by double digits annually. Plaintiffs’ attorneys are well-versed in targeting industries with heavy online engagement, e-commerce, hospitality, financial services, healthcare, and education.

Settlements can range from tens to hundreds of thousands of dollars, often excluding remediation costs and legal fees. Some businesses also face consent decrees requiring ongoing compliance monitoring and reporting to federal authorities.

If your digital properties are inaccessible, you are exposed.

2. Consumer Expectations Are Clear

Accessibility is no longer a niche concern. Modern consumers — including individuals with disabilities and their allies — expect brands to prioritize inclusivity across every touchpoint.

An accessible digital experience, like mobile responsiveness or data security, has become a baseline expectation. Companies that ignore this risk are losing customers, facing backlash on social media, and damaging their reputations with consumers who care about corporate responsibility.

3. Commitment to Inclusive Access

Digital accessibility plays a critical role in building organizations that are truly inclusive and welcoming to all. Companies that invest in accessibility demonstrate their commitment to ensuring equal access to information, services, and opportunities for every user, regardless of ability.

Embedding accessibility into digital strategies is not just about compliance; it reflects an organization’s broader values around fairness, innovation, and community engagement. In today’s environment, consumers, employees, and partners increasingly expect brands to prioritize inclusive access as a core part of their identity.

By making accessibility a standard practice, companies strengthen trust, expand their reach, and create a better experience for everyone.

What Companies Should Do Next

In an environment where regulatory guidance may fluctuate, smart organizations stay anchored to best practices rather than the political winds of the moment.

Anchor to Recognized Standards

The Web Content Accessibility Guidelines (WCAG) remain the most widely accepted technical standard for digital accessibility worldwide.
At a minimum, businesses should work toward meeting WCAG 2.1 Level AA standards, adopting WCAG 2.2, and preparing for WCAG 3.0 shortly. Compliance with WCAG helps mitigate litigation risk and ensures a broad, inclusive digital experience.

Conduct Regular Accessibility Audits

Accessibility is not a one-and-done exercise. Websites, apps, and other digital platforms evolve constantly, and ongoing changes can inadvertently introduce new barriers.

Companies should conduct automated testing and manual audits using assistive technologies like screen readers, voice navigation, and alternative input devices. By auditing regularly, they can maintain accessibility as content, features, and codebases change.

Integrate Accessibility Into Design and Development

Teams must treat accessibility as a core part of digital design and development workflows. Adding accessibility checkpoints to project management systems, reviewing designs for inclusivity, and following accessible coding standards all help build accessibility into the process from the start, rather than adding it later.

Invest in Team Training

Accessibility is a team sport. Developers, designers, marketers, product managers, and customer support teams all have roles to play in delivering accessible digital experiences.

Ongoing education — including live training sessions, self-paced e-learning modules, and expert workshops — ensures accessibility knowledge is current, practical, and actionable.

Navigating an Evolving Regulatory Landscape

The withdrawal of the ADA guidance documents underscores a broader point: the regulatory environment around accessibility can and does shift depending on political leadership.

However, organizations that base their compliance strategies solely on the current administration’s policies are taking a short-sighted approach. Regulatory trends may change, but consumer expectations, civil rights obligations, and market pressures endure.

Moreover, despite the DOJ’s current moves, the push toward formalizing digital accessibility requirements continues at the state and federal levels. States like California, New York, and others have shown interest in enhancing digital accessibility laws at the local level. Private lawsuits and advocacy group actions remain powerful, irrespective of federal agency action.

Accessibility is increasingly recognized globally as a civil right, and businesses that lead in this space will be more resilient, inclusive, and better prepared for future regulatory developments.

The Bottom Line

The DOJ’s withdrawal of 11 ADA guidance documents doesn’t eliminate the responsibility to make websites, mobile apps, and other digital services accessible to people with disabilities. Accessibility still plays a key role in legal compliance, customer experience, and corporate social responsibility. Organizations that recognize this and take action protect themselves from legal risk, expand their market reach, and show leadership in a digital-first world. Prioritizing accessibility isn’t just about meeting legal standards; it’s an investment in a more inclusive future.