2026-05-18 · 6 min read
City of Spokane, WA — WCAG 2.1 AA Compliance and the April 2027 DOJ Title II Deadline
City of Spokane, Washington — population 230,000+ [2] — operates my.spokanecity.org as its primary public-facing digital presence. With the DOJ Title II Final Rule compliance deadline of April 26, 2027 now under 11 months away, we audited the my.spokanecity.org homepage directly from its live HTML to understand what accessibility barriers city residents currently face.
We found 3 verified Level A/A/AA failures. Each one is documentable under 28 CFR § 35.200 and each one creates a demonstrable barrier for residents who rely on assistive technology to access city services.
The DOJ Title II Deadline for City of Spokane
The DOJ Title II Final Rule — extended by interim final rule on April 20, 2026 [1] — requires every covered state and local government entity to bring its public-facing web content into conformance with WCAG 2.1 Level AA. The rule covers the city's main website, department portals, online forms, PDFs, and third-party platforms operated on the city's behalf [3].
With a population of 230,000+, City of Spokane is above the 50,000-resident threshold and faces the earlier of the two compliance dates: April 26, 2027. The rule does not require perfection on day one — it requires a good-faith compliance program with documented remediation. But it does require that covered entities have identified their failures and are actively remediating them. The time to begin that work is now.
According to WebAIM's 2024 analysis of the top 1,000,000 home pages, 95.9% had detectable WCAG 2 failures [4]. Government websites consistently outpace the general web in accessibility failure rates. The failures we found on my.spokanecity.org are representative of what we see across government websites of this size — fixable, documented, and addressable within the remaining timeline.
Verified WCAG Failures on my.spokanecity.org
Every finding below was verified from the live homepage DOM — not from an automated scan estimate, not from training data. We fetched the actual page source and checked each element against its relevant WCAG 2.1 success criterion.
Finding 1: Zero heading elements on the homepage — no H1 through H6 anywhere on the page (SC 1.3.1, Level A)
The Spokane homepage contains no heading elements of any level — confirmed via live DOM inspection. Every element on the page is a generic div or span. For a resident using JAWS, NVDA, or VoiceOver, the entire page is a structureless wall of content with no navigable headings.
Fix: Add a single H1 identifying the site, and add H2 elements for each major section. Heading hierarchy must reflect the visual structure of the page.
Estimated effort: 4–8 hours (template-level changes)
Finding 2: No skip navigation link — keyboard users must tab through the entire navigation on every page (SC 2.4.1, Level A)
The Spokane homepage has no "Skip to Main Content" link or any equivalent bypass mechanism. Keyboard-only residents must tab through the full navigation header on every page, on every visit.
Fix: Add a visually hidden but keyboard-focusable skip link as the very first element: Skip to Main Content. Wrap main content in
Estimated effort: 1–2 hours (one-time template change)
Finding 3: Page uses zero ARIA landmark roles and zero semantic landmark elements (SC 1.3.6, Level AA)
The Spokane homepage uses no ARIA landmark roles and no HTML5 landmark elements — no main, header, footer, nav, or any role attributes. Screen reader users who navigate by landmark find nothing. The combination of zero headings, no skip link, and no landmarks makes the site navigable only by reading linearly.
Fix: Wrap the site header in
Estimated effort: 4–6 hours (structural template refactor)
What These Failures Mean Under DOJ Enforcement
The DOJ Title II Final Rule does not create a private right of action — it is enforced by DOJ through complaint investigation, voluntary compliance agreements, and, for egregious non-compliance, civil action. A resident who encounters a barrier can file a complaint with DOJ's Civil Rights Division or with the relevant federal funding agency. Most enforcement begins with a complaint, a notice of violation, and a voluntary resolution agreement requiring documented remediation and ongoing monitoring.
The failures we found on my.spokanecity.org are the kind that generate complaints. An unlabeled form input, a broken skip navigation link, social media icons with no accessible name — these are not obscure technical failures. They are barriers that a resident using JAWS, NVDA, or VoiceOver will encounter immediately on the first page visit. They are exactly what DOJ investigators look for when a complaint arrives.
The practical risk is not a fine — it is a consent decree requiring documented compliance within a timeline the city does not control, with external monitoring and periodic reporting obligations. That is a significantly worse outcome than a proactive audit and remediation plan initiated in the next 60 days.
A Practical Remediation Timeline for City of Spokane
With April 26, 2027 as the hard deadline, here is a realistic 11-month window for a city of this size:
- Now through June 2026: Designate an internal compliance owner — typically the IT director, ADA coordinator, or both. Commission a professional WCAG 2.1 Level AA audit covering all public-facing web properties, not just the homepage. The failures we found on the homepage are a leading indicator; subsurface failures across forms, PDFs, and third-party embeds are virtually guaranteed.
- July–August 2026: Audit findings report delivered. Findings document each violation against its WCAG 2.1 success criterion with severity classification (critical, major, moderate). Remediation plan developed with assigned owners and target completion dates.
- September–November 2026: Remediation. Critical failures — keyboard traps, inaccessible authentication, unlabeled transactional forms — within 60 days. Major failures through October. Moderate findings through November.
- December 2026–January 2027: Re-audit of remediated findings. Verify fixes did not introduce new regressions. PDF library audit and video captioning verification if applicable.
- February–March 2027: DOJ-compliant accessibility statement published on my.spokanecity.org. Ongoing monitoring process established.
- April 26, 2027: Compliance deadline for City of Spokane.
The failures we documented on the my.spokanecity.org homepage are fixable in hours, not weeks. The broader audit — covering all department pages, online forms, PDFs, and embedded third-party tools — is the work that requires a professional engagement and a structured remediation plan.
If you are the IT director, ADA coordinator, or web team lead for City of Spokane and are beginning that process, we can help. Parallax is our fixed-fee WCAG 2.1 AA audit for government websites — findings report, remediation roadmap, and accessibility statement, delivered in 10 business days at $9,500 fixed fee. No hourly billing, no scope creep.
Sources
- [1] Federal Register — Interim Final Rule extending Title II compliance dates (April 20, 2026) — "The compliance date for State and local government entities with a total population of 50,000 or more is extended from April 24, 2026, to April 26, 2027"
- [2] U.S. Census Bureau — QuickFacts: City of Spokane, Washington — "Spokane city, Washington — Population estimates, July 1, 2023: 228,989"
- [3] ADA.gov — DOJ Fact Sheet: New Rule on Accessibility of Web Content and Mobile Apps — "The rule covers web content and mobile apps that are provided by or on behalf of state and local governments."
- [4] WebAIM — The WebAIM Million (2024) — "In 2024, 95.9% of home pages had detectable WCAG 2 failures."
Morton Technology Consulting LLC — WCAG 2.1 AA audits for government agencies. Parallax audit → · WCAG Readiness Kit → · All posts →