In April 2024, the U.S. Department of Justice issued a landmark final rule updating digital accessibility requirements under Title II of the Americans with Disabilities Act (ADA). This rule mandates that all public-facing websites and digital content from state and local governments must comply with the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA—a sweeping change that effectively aligns ADA enforcement with Section 508 standards previously limited to federal agencies.
For local governments, this rule is a wake-up call—and an opportunity. With deadlines fast approaching (2026 for jurisdictions with 50,000+ people, and 2027 for smaller municipalities), agencies must act now to evaluate and upgrade their digital experiences.
In this article, we’ll break down what the DOJ rule says, what WCAG 2.1 AA actually requires, and what you can do today to start your compliance journey.
What Changed in 2024?
While the ADA has always required “effective communication” and equal access to government services, the rules around what that meant for websites and PDFs were vague—until now.
The 2024 DOJ final rule establishes, for the first time, that digital content must meet WCAG 2.1 Level AA. This standard applies to:
- Public websites
- Mobile applications
- Online forms and portals
- PDFs, reports, and public records
- Interactive tools like payment systems or GIS maps
Agencies serving over 50,000 people have until April 24, 2026 to comply. All others have until April 26, 2027.
What Is Section 508—and Why Does It Matter?
Section 508 is a federal law requiring all federal agencies to make their digital content accessible to people with disabilities. The standard is based on WCAG 2.1 AA and includes rules for both web pages and online documents (like PDFs and Word files). Many state and local agencies have already been modeling their efforts on Section 508 voluntarily—but now, under the DOJ rule, similar expectations are enforceable under the ADA.
What WCAG 2.1 AA Requires
To meet WCAG 2.1 AA, digital content must be:
- Perceivable – Text alternatives for non-text content, captions for videos, content that can be presented in different ways
- Operable – All functionality must be available from a keyboard, with proper timing and no seizures
- Understandable – Text must be readable, predictable, and have helpful input assistance
- Robust – Content must work with current and future assistive technologies
In practice, this means your website and documents need things like:
- Alt text for all meaningful images
- Keyboard navigability
- Logical heading structures
- Accessible form labels and error messaging
- High color contrast ratios
- Screen reader-compatible content
What Happens If You Don’t Comply?
The DOJ’s rule gives enforcement teeth to years of vague guidance. Here’s what noncompliance could lead to:
- DOJ investigations and civil enforcement
- Lawsuits from individuals or disability advocacy groups
- Loss of public trust
- Delayed or denied grant funding
In short: it’s not worth the risk.
How to Get Started Now
You don’t have to fix everything at once, but you do need a plan. Here’s a smart starting point:
1. Audit Your Website
Run automated scans with tools like:
- WAVE (WebAIM)
- AXE DevTools
- Siteimprove
Look for red flags:
- Missing alt text
- Keyboard traps
- Confusing navigation
- Poor color contrast
- Lack of headings
2. Check Your Documents
Download a few of your public PDFs and open them in Adobe Acrobat Pro:
- Open the Tags panel. If it’s empty, your document isn’t accessible.
- Check to make sure your tags are correct. Properly mark headers, lists, figures, etc.
- Run the built-in Accessibility Checker – but know this doesn’t tell the whole story!
- Try using the Read Aloud feature or a screen reader like NVDA.
Many government documents fail this test. If you see a wall of <P> tags or a single blob of text, it’s time to remediate.
3. Create an Accessibility Statement
Every public-facing site should have a page that:
- Declares commitment to accessibility
- States which standards the site meets (e.g., WCAG 2.1 AA)
- Lists contact information for reporting barriers
- Offers alternate formats upon request
This shows good faith—and may reduce your legal risk.
4. Prioritize Critical Content
You likely have hundreds of legacy documents. Start with the highest impact:
- Forms and applications
- Public notices
- Permits, tax documents, agendas, and meeting minutes
Not every old file must be remediated. The 2024 DOJ rule focuses on content that is currently necessary to access public services. This includes documents like applications, notices, and current policies, even if they were uploaded before the compliance deadline.
Archived files that are not updated, maintained, or required for service may be exempt—but must be clearly labeled. Agencies must still provide accessible versions on request.
Start by remediating documents that affect public access today, and develop a plan for handling historical files.
5. Get Expert Help
Compliance is complex. Trying to “DIY” your way through it can be frustrating and risky. Look for a qualified accessibility consultant who understands both WCAG and PDF/UA.
Why It’s Not Just About Risk
Yes, compliance matters—but so does service. Digital accessibility isn’t just about avoiding lawsuits. It’s about ensuring that all residents—especially seniors, veterans, and people with vision or mobility impairments—can access the services they rely on.
Accessible design makes your government more transparent, more inclusive, and more trusted.
Final Thoughts
The 2024 DOJ rule is a turning point for digital accessibility in local government. If you serve more than 50,000 people, the clock is already ticking. Even if your compliance date is 2027, starting now will save you time, money, and stress.
The good news? You don’t have to do it alone.
Ready to Get Compliant?
Let’s start with a quick audit of your website and documents. We’ll give you a clear picture of where you stand—and what’s next.
