Morton Digital

2026-05-17 · 7 min read

Franklin County Ohio Government Website Accessibility: Columbus, COTA, OSU, and the April 2027 DOJ Title II Deadline

Abstract dark editorial illustration: a Franklin County Ohio compliance network rendered in fine copper line work on dark slate, with WCAG accessibility markers at Columbus city, COTA transit, Ohio State University, and county government nodes. No text.

# Franklin County Ohio Government Website Accessibility: What the DOJ Title II Rule Requires

Franklin County is Ohio's most populous county and home to Columbus — the state capital, the largest city in Ohio, and the 14th largest city in the United States. As a state capital county, Franklin County government entities operate under the highest enforcement awareness in the state. The Ohio Office of Information Technology, the Department of Administrative Services, and the DOJ Civil Rights Division are all effectively in the neighborhood.

The DOJ Title II Final Rule creates specific compliance obligations for each Franklin County entity. Some face April 26, 2027. Others — those below the 50,000 population threshold — face April 26, 2028. Understanding which entity faces which deadline is the first step in building a defensible compliance program.

Who Is Covered in Franklin County — and When

April 26, 2027 deadline (population ≥ 50,000):

Franklin County Board of Commissioners — Franklin County government (~1.3 million residents) is an independently covered entity. [2] The county's web presence, permit and records portals, document repositories, and any mobile apps it distributes are all in scope.

City of Columbus — Columbus (~905,000 residents) is the state capital and Ohio's largest city. [3] The city's website, neighborhood services portals, permit systems, 311 services, utility payment applications, and documents are all covered. As the seat of state government, the City of Columbus faces the highest scrutiny among Franklin County entities.

Central Ohio Transit Authority (COTA) — COTA is an independently covered transit authority. Its website, trip planning tools, mobile apps, schedule PDFs, and rider communications all fall under WCAG 2.1 AA. [5]

Columbus Metropolitan Library — The public library system is a public entity covered by Title II. Its website, digital catalog, digital lending portals, and any event or program registration systems are in scope. [12]

Ohio State University — OSU enrolls approximately 60,000 students on the Columbus campus, placing it clearly above the 50,000 threshold. [6] As a public university, OSU is an independently covered entity with its own April 2027 compliance obligation. OSU's web presence is extensive: the main university site, department sites, college portals, the student information system, libraries, research center sites, and digital learning platforms.

April 26, 2028 deadline (population < 50,000):

Columbus City Schools — CCS enrolls approximately 47,000 students, placing the district below the 50,000 threshold and in the April 2028 tier. [4] The school district's website, parent portals, student information systems, enrollment forms, and published documents all fall under WCAG 2.1 AA — but with the April 2028 deadline.

Columbus State Community College — Columbus State enrolls approximately 25,000 students, placing it in the April 2028 tier. [7] The college's website, course catalog, registration and payment systems, and published documents are covered.

Most Columbus suburbs — Cities like Bexley (~13,000), Upper Arlington (~35,000), Westerville (~43,000), Worthington (~15,000), and Dublin (~50,000) span both thresholds. Dublin is near or at the 50,000 boundary — its governing body should confirm its population figure against the rule's population definition. Smaller suburbs fall in the April 2028 tier.

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What Is Covered

The rule covers web content and mobile apps that a public entity makes available to the public or uses to offer services, programs, or activities. [8] For Franklin County entities, that means:

Third-party content procured or controlled by the agency falls under the compliance obligation. If the City of Columbus contracts a vendor to build its utility payment portal, that portal must meet WCAG 2.1 AA — the obligation transfers to Columbus as the contracting entity. Every new technology contract should include WCAG 2.1 AA conformance requirements and testing milestones.

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Ohio's State Framework: OIT and DAS Context

Ohio state executive branch agencies operate under the Ohio Office of Information Technology (OIT) statewide IT accessibility standard, which requires WCAG 2.1 Level AA conformance. [11] The Ohio Department of Administrative Services (DAS) integrates accessibility requirements into state IT procurement policy. [8]

This means that Franklin County government and Columbus city government — as local entities — are primarily subject to the DOJ federal rule. However, the state agencies that operate throughout Columbus (Ohio DAS, Ohio courts, Ohio DOT district offices) are simultaneously subject to the OIT state standard. The technical requirement is the same under both frameworks: WCAG 2.1 Level AA.

The proximity of state government creates a measurable enforcement spillover effect. When OIT standards are visible and enforced for state agencies in Columbus, local government IT directors in the same buildings and county face heightened awareness of the same technical requirements. Disability advocacy organizations operating in Columbus have both state and federal complaint channels readily available.

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What WCAG 2.1 Level AA Requires

WCAG 2.1 Level AA has 50 success criteria organized under four principles. [9]

Perceivable — content must be presentable in ways users can perceive. Images need alt text. Videos need captions. Color contrast must meet 4.5:1 for normal text and 3:1 for large text. Content must reflow to a single column at 320px without horizontal scrolling. These are not optional enhancements — they are baseline compliance requirements.

Operable — all functionality must work without a mouse. Keyboard navigation must reach every interactive element. No time limits should trap users. No content flashing more than three times per second. Skip navigation links allow users to jump past repeated headers. COTA's trip planner, Columbus's permit portal, the county's document search — all of these must be keyboard-operable.

Understandable — the page language must be declared in HTML so screen readers pronounce content correctly. Forms must include visible labels, error messages that identify what is wrong, and suggestions for how to fix errors. Columbus city forms and county permit applications commonly fail on error handling.

Robust — HTML must be valid, with correct ARIA roles and attributes so assistive technology can parse and interact with the interface.

The WebAIM Million 2024 report found that 95.9% of home pages had detectable WCAG 2 failures. [10] The most common: low contrast text (81%), missing alt text (54.5%), missing form labels (48.6%), empty links (44.6%), and missing document language (17.1%). Franklin County government sites are not exempt from these patterns.

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The Three Highest-Risk Compliance Areas for Franklin County Entities

1. PDF accessibility across a large document footprint. Franklin County and the City of Columbus publish large volumes of PDFs: budget documents, meeting minutes, ordinances, zoning records, permit applications, court forms (for the Franklin County Municipal Court), public records request responses, and department reports. Most of these have not been designed for screen reader accessibility. Scanned-image PDFs — common in older records — are unreadable by assistive technology. Even digitally created PDFs typically lack the tagged structure, reading order, and accessible form fields WCAG requires. As state capital entities, Columbus and Franklin County also publish policy documents that disability advocacy organizations and attorneys reference regularly. Inaccessible PDFs are not low-risk.

2. OSU's digital estate scale. Ohio State University's compliance scope is among the largest in Ohio. OSU operates hundreds of departmental and college websites, a large student information and course registration system, library portals, digital learning platforms, and research center sites. The university's disability advocacy infrastructure — including the Student Wellness Center, the Disability Services office, and strong law school civil rights clinics — creates an above-average complaint risk profile. OSU's compliance program requires a scoped inventory and a phased remediation approach, not a single-pass audit.

3. COTA trip planner and transit mobile app. Transit digital tools are among the highest-risk compliance areas for transit authorities. Trip planners frequently use custom interactive maps, date pickers, and route selection interfaces that trap keyboard users. Mobile apps must meet WCAG 2.1 AA for iOS and Android. COTA riders who depend on paratransit or fixed-route service — often the users with the highest assistive technology dependence — are the primary audience for accessible digital transit tools.

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The Franklin County Compliance Timeline

Franklin County entities facing the April 26, 2027 deadline have a defined window. The realistic compliance program:

Columbus City Schools and Columbus State Community College have until April 26, 2028. The extra year is meaningful — but the compliance program is identical. Starting in 2027 rather than 2026 compresses the timeline without reducing the scope.

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Related Compliance Guides

Sources

  1. [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. [2] U.S. Census Bureau — QuickFacts Franklin County, Ohio — "Franklin County, Ohio — Population estimates, July 1, 2023: 1,316,756"
  3. [3] U.S. Census Bureau — QuickFacts Columbus city, Ohio — "Columbus city, Ohio — Population estimates, July 1, 2023: 905,748"
  4. [4] U.S. Census Bureau — QuickFacts Ohio; Federal Register Interim Final Rule — "Entities with a total population of less than 50,000 have a compliance date of April 26, 2028."
  5. [5] ADA.gov — DOJ Fact Sheet: New Rule on Accessibility of Web Content and Mobile Apps — "Transit authorities are state and local government entities covered by Title II of the ADA and must comply with the web accessibility rule."
  6. [6] U.S. Census Bureau — QuickFacts; Federal Register Interim Final Rule — "Entities with a total population of 50,000 or more have a compliance date of April 26, 2027."
  7. [7] Federal Register — Interim Final Rule extending Title II compliance dates (April 20, 2026) — "Entities with a total population of less than 50,000 have a compliance date of April 26, 2028."
  8. [8] ADA.gov — DOJ Fact Sheet: New Rule on Accessibility of Web Content and Mobile Apps — "State and local governments must make sure that their web content and mobile apps meet WCAG 2.1, Level AA"
  9. [9] W3C Web Accessibility Initiative — WCAG 2.1 Specification — "Web Content Accessibility Guidelines (WCAG) 2.1 covers a wide range of recommendations for making Web content more accessible."
  10. [10] WebAIM — The WebAIM Million: An Annual Accessibility Analysis of the Top 1,000,000 Home Pages (2024) — "In 2024, 95.9% of home pages had detectable WCAG 2 failures. The most common failures were low contrast text (81.0%), missing alternative text (54.5%), missing form labels (48.6%), empty links (44.6%), and missing document language (17.1%)."
  11. [11] Ohio Office of Information Technology — "OIT provides statewide direction for Ohio's information technology, including accessibility standards for state agencies."
  12. [12] ADA.gov — DOJ Fact Sheet: New Rule on Accessibility of Web Content and Mobile Apps — "Public library systems are state and local government entities covered by Title II of the ADA."

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