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Free resource — Government & Public Sector

The Government Website ADA Compliance Checklist: 47 Points Before the April 2027 DOJ Deadline

The DOJ's Title II final rule requires state and local government websites to meet WCAG 2.1 Level AA. Compliance deadlines were extended in April 2026: April 26, 2027 for entities with 50,000+ population; April 26, 2028 for smaller entities. This checklist covers every success criterion your IT team and ADA coordinator need to verify — organized by WCAG principle so you can work through it systematically.

DOJ Title II Compliance Deadlines (Updated — Interim Final Rule, April 2026)

April 26, 2027

Cities, counties & state agencies with population ≥50,000

April 26, 2028

Special districts, small cities & agencies with population <50,000

What the checklist covers

1. Perceivable — Text Alternatives & Media

01Every non-decorative image has a descriptive alt attribute that conveys the same information as the image1.1.1
02Decorative images use empty alt="" or role="presentation" so screen readers skip them1.1.1
03Pre-recorded audio has a text transcript available on the same page or linked immediately adjacent1.2.1
04Pre-recorded video has synchronized captions — auto-generated captions reviewed for accuracy1.2.2
05Pre-recorded video with meaningful visual content includes an audio description or text alternative1.2.3
06Live audio content has live captions (webinar, public meeting broadcast, press conference)1.2.4

2. Perceivable — Adaptable Presentation

07Page structure uses semantic HTML headings in correct hierarchy (one <h1>, logical <h2><h6> nesting)1.3.1
08Form inputs are programmatically associated with labels via <label for>, aria-labelledby, or aria-label1.3.1
09Tables use <th> with scope attributes; complex tables include headers associations1.3.1
10Reading order in the DOM matches the visual presentation order — content makes sense without CSS1.3.2
11Instructions do not rely solely on shape, color, position, or sound ("click the green button" fails)1.3.3
12Content reflows at 320px viewport width without horizontal scrolling (tested at 400% zoom in Chrome)1.3.4
13Input fields for personal data use appropriate autocomplete tokens (name, email, tel, address-line1, etc.)1.3.5

3. Perceivable — Distinguishable

14Color is not the only means of conveying information, indicating an action, or distinguishing a visual element1.4.1
15Audio that plays automatically for more than 3 seconds can be paused or stopped by the user1.4.2
16Normal text (under 18pt or 14pt bold) meets 4.5:1 contrast ratio against its background in all states1.4.3
17Large text (18pt+ or 14pt+ bold) meets 3:1 contrast ratio against its background1.4.3
18Text can be resized up to 200% without loss of content or functionality (not just browser zoom)1.4.4
19Images of text are avoided; where used, text alternatives convey identical information1.4.5
20No content requires scrolling in two dimensions (horizontal + vertical) unless essential to the content1.4.10
21Non-text UI components (buttons, inputs, focus rings, chart axes) meet 3:1 contrast against adjacent colors1.4.11
22Line height can be set to 1.5×, letter spacing to 0.12em, word spacing to 0.16em without loss of content1.4.12
23Hover and focus tooltips/popovers are dismissable (Escape), hoverable, and persistent until pointer moves away1.4.13

4. Operable — Keyboard Accessible

24All functionality is operable with a keyboard alone — no mouse required for any task2.1.1
25Keyboard focus is never trapped in a component unless the user can escape with a documented key (Escape, Tab)2.1.2
26Character key shortcuts (single-key like "S" for search) can be remapped or disabled2.1.4

5. Operable — Enough Time

27Session timeouts warn users at least 20 seconds in advance and allow extension without data loss2.2.1
28Moving, blinking, or auto-updating content can be paused, stopped, or hidden by the user2.2.2

6. Operable — Seizures & Physical Reactions

29No content flashes more than 3 times per second (animated GIFs, video, CSS animations all checked)2.3.1

7. Operable — Navigable

30A skip-navigation link appears as the first focusable element, linking to #main2.4.1
31Every page has a unique, descriptive <title> that identifies topic and site2.4.2
32Keyboard focus order is logical and predictable — tab through the full page without a mouse2.4.3
33Link text is descriptive on its own — no "click here", "read more", or "more" without context2.4.4
34Multiple navigation paths exist to reach each page: breadcrumb, site search, or site map2.4.5
35Headings and labels describe the topic or purpose of the content they introduce2.4.6
36Keyboard focus indicator is visible and meets the 3:1 contrast ratio against adjacent unfocused state2.4.7
37Focus indicator area is at least the perimeter of the unfocused component × 2px (WCAG 2.2 new)2.4.11
38Focus is not hidden by sticky headers, cookie banners, or fixed overlays when navigating by keyboard2.4.12

8. Operable — Input Modalities

39All pointer operations (drag, swipe) have a single-pointer alternative that does not require a path gesture2.5.1
40Click/tap actions fire on the up-event (mouseup/pointerup), not down-event, so users can abort2.5.2
41Voice control users can operate all inputs by visible label — icon-only buttons have accessible names matching their visual label2.5.3
42Device motion (shake, tilt) is not the sole means of triggering any function2.5.4

9. Understandable — Readable & Predictable

43<html lang="en"> (or correct language code) is set on every page; language changes in-page use lang attribute3.1.1
44Navigation, labels, and component behavior are consistent across pages — same component behaves the same way everywhere3.2.3–4
45Input errors identify the field in error and describe the problem in text — not just a red border3.3.1
46Required fields and expected formats are communicated before submission, not only after errors3.3.2

10. Robust — Compatible

47All interactive components have accessible names, roles, and states that assistive technology can parse — tested with NVDA+Chrome and VoiceOver+Safari4.1.2

The regulatory context

Why government websites face the steepest compliance risk

The rule

On April 24, 2024, the DOJ issued a final rule under Title II of the ADA requiring all state and local government websites to conform to WCAG 2.1 Level AA. This is a binding legal obligation, not a best-practice recommendation.

The exposure

Government agencies that miss their deadline face DOJ complaint investigations, consent decrees, and court-enforceable remediation timelines. Unlike private-sector ADA litigation, these are regulatory enforcement actions with public record.

The gap

WebAIM's 2026 scan of the top million websites found 95.9% had detectable WCAG failures. Government sites are not an exception. Automated scanners miss approximately 43% of real violations — the 47 points in this checklist address both.