ADA Compliance for City and County Websites (Title II)

Who Title II covers

Title II of the ADA applies to state and local government entities regardless of size or whether they receive federal funding. In practice that includes:

• Cities, towns, villages and counties
• Public school districts, community colleges and state universities
• Public libraries and library systems
• Transit authorities, water and sewer districts, and other special districts
• Courts, police and fire departments
• Public hospitals and health departments

It also reaches content a government entity posts through a third party. Putting the council agenda on a commercial hosting platform does not move the obligation onto the vendor.

The standard is specific

The requirement is WCAG 2.1 Level AA — a published, testable standard rather than a general duty to be reasonable. Compliance dates were tiered by population, with larger entities required to comply first and smaller ones given an additional year. Both tiers are now in force.

The practical consequence is that "we are working on it" is a weaker position than it was. A complainant does not have to argue that your site is unusable in the abstract; they can point at a named success criterion and a page that fails it.

What trips up municipal sites

Government sites tend to fail in a distinctive pattern, and it is rarely the homepage:

• Scanned PDFs. Meeting minutes, budgets and permit forms uploaded as images of paper. To a screen reader these are blank pages. This is the single most common Title II problem.
• Third-party embeds. Payment portals, permit systems, GIS maps and agenda-management tools bought from vendors, each an accessibility surface you did not build and often cannot fix.
• Public-notice tables. Layout tables and merged cells that make tabular data unnavigable.
• Video without captions. Recorded council and board meetings posted with auto-captions that were never reviewed.
• Legacy pages. Twenty years of content behind a modern homepage redesign.

A realistic plan for a small municipality

1. Inventory what people actually use. Pull your analytics and list the twenty most-visited pages. Add every page in a payment, permit or application path, whether it is popular or not.
2. Scan those templates, not your whole archive. Most municipal sites run on a handful of templates. Fixing the template fixes hundreds of pages.
3. Deal with PDFs by triage. You will not remediate twenty years of documents. Prioritise anything still legally operative — current forms, current fee schedules, current notices — and provide an accessible HTML alternative for those.
4. Put accessibility in your vendor contracts. Ask for a current VPAT or ACR before renewing anything. Your obligation does not transfer, so your leverage has to be contractual.
5. Publish an accessibility statement with a contact route. Include a named way to report a barrier and a commitment to respond. Many complaints begin because there was nowhere to complain.
6. Monitor continuously and keep the records. A dated history showing you test regularly and fix what you find is the most useful thing you can hold.

Budget reality

Small entities frequently assume this means a five-figure audit. It usually does not. Automated scanning across your real templates will surface the mechanical failures — contrast, labels, alt text, heading structure — which is the bulk of what gets cited. Reserve paid human review for the transactional paths and the documents that carry legal weight.

What is not optional is doing it repeatedly. A single remediation project decays the moment the next department posts a new PDF.

Related reading

• ADA Title II compliance deadline
• Section 508 compliance
• Your scan found 0 issues — that isn't compliance