Government Website Accessibility: Title II Compliance Checklist

On April 24, 2024, the Department of Justice finalized new regulations requiring state and local government websites to meet WCAG 2.1 Level AA standards. With compliance deadlines approaching—April 24, 2026 for jurisdictions serving 50,000+ residents, and April 26, 2027 for smaller jurisdictions—government web teams need a clear action plan.

The challenge is significant. Research shows government websites average 307 accessibility violations per page, with common issues including keyboard navigation failures (51% of pages), missing alt text (28% of images), and color contrast problems (averaging 75.4 violations per page).

This checklist provides a practical, phase-by-phase approach to achieving Title II compliance.

Understanding WCAG 2.1 Level AA Requirements

Before diving into the checklist, it's essential to understand what compliance means. WCAG 2.1 Level AA conformance requires meeting all Level A criteria (foundational accessibility) plus additional Level AA criteria across four core principles:

Perceivable: Information must be presented in ways all users can perceive

• Alternative text for images and non-text content
• Captions and transcripts for audio/video
• Color contrast ratios of at least 4.5:1 for normal text, 3:1 for large text
• Content that adapts to different screen sizes and zoom levels

Operable: All functionality must be accessible via keyboard

• Complete keyboard navigation without mouse dependency
• Sufficient time to read and interact with content
• Content that doesn't cause seizures (no flashing more than 3 times per second)
• Clear navigation mechanisms and skip links

Understandable: Content and interfaces must be comprehensible

• Readable text with identified language
• Predictable navigation and functionality
• Input assistance and error identification for forms
• Clear labels and instructions

Robust: Content must work with current and future assistive technologies

• Valid, properly structured HTML
• Name, role, and value for all UI components
• Status messages that assistive technologies can announce

Phase 1: Assessment & Audit (Months 1-2)

1.1 Inventory Your Digital Properties

Action Items:

• Create a comprehensive list of all public-facing websites and web applications
• Document third-party applications and vendor-provided tools
• Identify mobile applications covered by the rule
• Catalog existing PDFs, Word documents, and other digital documents
• Note which properties are most critical for public services

Why This Matters: Title II covers all digital content, whether managed in-house or through vendors. Many government agencies have dozens of separate applications that must all comply.

1.2 Conduct Automated Accessibility Scans

Action Items:

• Run automated accessibility testing tools on all properties
• Use multiple tools for comprehensive coverage (axe-core, WAVE, Lighthouse)
• Document violation counts and types for each property
• Prioritize issues by severity and frequency
• Identify patterns across multiple sites (recurring problems)

Recommended Tools:

• Beacon: Automated scanning with Axe-core and Playwright for comprehensive site coverage
• WAVE: Browser extension for quick page-by-page checks
• axe DevTools: Developer-focused browser extension
• Lighthouse: Built into Chrome DevTools for quick audits

Reality Check: Automated tools catch approximately 30-40% of accessibility issues. They're excellent for identifying common violations like missing alt text, color contrast problems, and structural issues, but manual testing is essential.

1.3 Perform Manual Testing

Action Items:

• Test keyboard navigation on critical user paths
• Verify form functionality with assistive technology
• Check logical reading order and heading structure
• Test with screen readers (NVDA, JAWS, VoiceOver)
• Validate focus indicators are visible and logical
• Review all interactive elements for accessibility

Critical Areas for Manual Testing:

• Form submission and error handling
• Multi-page processes (applications, payments)
• Dynamic content and single-page applications
• Custom interactive widgets
• Video players and media controls

1.4 Conduct User Testing

Action Items:

• Recruit users with disabilities for testing sessions
• Test critical services with real assistive technology users
• Document usability issues beyond technical compliance
• Gather feedback on navigation and comprehension
• Identify real-world barriers automated tools miss

Budget Consideration: User testing is invaluable. Organizations can partner with local disability advocacy groups or hire accessibility consultants who work with people with disabilities.

Phase 2: Planning & Budgeting (Months 2-3)

2.1 Analyze Findings and Prioritize

Action Items:

• Categorize violations by WCAG criterion
• Identify quick wins (high-impact, low-effort fixes)
• Prioritize based on service criticality and violation severity
• Estimate remediation effort for each property
• Create a timeline working backward from your deadline

Prioritization Framework:

1. Critical Services First: Online payments, permit applications, emergency services
2. High-Traffic Pages: Homepages, service directories, contact pages
3. Severe Violations: Issues preventing basic access (keyboard traps, missing form labels)
4. Volume Fixes: Recurring issues that can be templated (consistent heading structures)

2.2 Develop Budget Requirements

Action Items:

• Calculate staff time for remediation (internal resources)
• Budget for accessibility testing tools and subscriptions
• Plan for vendor contracts (if outsourcing remediation)
• Include training costs for web team and content creators
• Budget for ongoing monitoring and maintenance
• Allocate funds for assistive technology and testing equipment

Budget Categories:

Tools & Technology ($2,000 - $10,000/year)

• Automated scanning tools (Beacon, Siteimprove, etc.)
• Screen readers and assistive technology for testing
• Browser testing subscriptions

Professional Services ($15,000 - $100,000+)

• Accessibility consultants for audits
• Remediation contractors for large backlogs
• User testing facilitation

Training ($5,000 - $20,000)

• WCAG certification courses for web team
• Content creator training
• Procurement officer education on accessibility requirements

Ongoing Maintenance ($10,000 - $50,000/year)

• Regular monitoring and scanning
• Quarterly compliance checks
• New content review processes

2.3 Build Your Accessibility Team

Action Items:

• Designate an accessibility coordinator or champion
• Identify stakeholders across departments (IT, Communications, Legal)
• Assign remediation responsibilities by property or department
• Establish governance structure for accessibility decisions
• Create escalation paths for complex issues

2.4 Integrate Accessibility into Procurement

Action Items:

• Update procurement policies to require WCAG 2.1 Level AA conformance
• Require Voluntary Product Accessibility Templates (VPATs) from vendors
• Include accessibility requirements in RFPs and contracts
• Establish vendor accountability for maintaining compliance
• Train procurement staff on accessibility evaluation

Section 508 Guidance: Federal agencies have developed extensive procurement resources at Section508.gov that state and local governments can adapt.

Phase 3: Remediation (Months 3-18)

3.1 Address Global Issues First

Action Items:

• Fix site-wide templates and shared components
• Implement consistent heading hierarchies
• Add skip navigation links to all pages
• Ensure keyboard focus indicators are visible site-wide
• Update color schemes to meet contrast requirements
• Fix navigation menus for keyboard and screen reader access

Why Start Here: Fixing templates and shared components provides the biggest ROI—one fix can improve hundreds or thousands of pages.

3.2 Remediate High-Priority Content

Action Items:

• Add alternative text to all images
• Provide captions for video content
• Create transcripts for audio content
• Fix form labels, instructions, and error messages
• Ensure all interactive elements are keyboard accessible
• Remove content that relies solely on color to convey information

Form Accessibility Checklist:

• All form fields have programmatically associated labels
• Required fields are clearly indicated
• Error messages are specific and helpful
• Errors are associated with relevant fields using aria-describedby
• Form submission feedback is provided to screen readers
• Multi-step forms indicate progress and allow return to previous steps

3.3 Fix Document Accessibility

Action Items:

• Audit all PDFs, Word documents, and spreadsheets
• Make new documents accessible from creation
• Remediate high-priority existing documents
• Create HTML alternatives for complex PDFs
• Train staff on creating accessible documents
• Establish document accessibility standards

Document Remediation Priority:

• Essential forms and applications (highest priority)
• Frequently accessed public documents
• Legal notices and official communications
• Historical documents (lower priority, consider HTML alternatives)

3.4 Address Complex Interactive Content

Action Items:

• Audit custom widgets (date pickers, accordions, tabs)
• Implement proper ARIA labels and roles
• Test and fix focus management in dynamic content
• Ensure live regions announce updates appropriately
• Fix modal dialogs for keyboard trapping and focus management
• Test single-page application routes with screen readers

Third-Party Applications:

• Work with vendors to obtain compliance timelines
• Request VPATs showing current conformance
• Establish service level agreements for accessibility
• Consider alternative vendors if current ones can't comply
• Document vendor responsibilities in contracts

Phase 4: Testing & Verification (Months 18-22)

4.1 Conduct Comprehensive Re-Testing

Action Items:

• Re-run automated scans on all remediated properties
• Perform manual testing on critical user journeys
• Test with multiple screen readers and assistive technologies
• Verify keyboard navigation throughout entire sites
• Check color contrast with updated designs
• Test responsive behavior at different zoom levels and viewport sizes

4.2 User Acceptance Testing

Action Items:

• Recruit diverse users with disabilities for final testing
• Test complete user journeys (not just individual pages)
• Gather qualitative feedback on usability
• Identify remaining barriers to access
• Document any outstanding issues and mitigation plans

4.3 Document Conformance

Action Items:

• Create accessibility conformance reports for each property
• Document known issues and planned remediation timelines
• Prepare accessibility statements for public websites
• Maintain testing records and evidence of compliance efforts
• Document third-party vendor conformance status

Accessibility Statement Elements:

• Commitment to accessibility
• Conformance status (full, partial, or non-conformant)
• Known limitations and alternative access methods
• Contact information for accessibility feedback
• Date of statement and review schedule

Phase 5: Ongoing Maintenance (Post-Compliance)

5.1 Implement Continuous Monitoring

Action Items:

• Schedule regular automated scans (weekly or monthly)
• Set up alerts for new violations
• Monitor newly published content for compliance
• Track accessibility metrics over time
• Conduct quarterly manual testing of critical paths

Recommended Monitoring Strategy:

• Automated Scans: Weekly scans with Beacon or similar tools
• Manual Testing: Quarterly reviews of key user journeys
• User Testing: Annual testing with people with disabilities
• Vendor Reviews: Annual VPAT updates from all third-party providers

5.2 Establish Content Governance

Action Items:

• Create accessibility guidelines for content creators
• Implement review processes before content publication
• Provide accessible templates and components
• Train all content contributors on accessibility basics
• Establish accountability for maintaining compliance

Content Creator Training Topics:

• Writing meaningful alternative text
• Using proper heading structures
• Creating accessible tables
• Writing clear link text (avoid "click here")
• Ensuring sufficient color contrast
• Creating accessible documents

5.3 Stay Current with Standards

Action Items:

• Monitor WCAG updates and new success criteria
• Review DOJ guidance and enforcement actions
• Participate in accessibility communities and forums
• Update internal standards as technology evolves
• Plan for WCAG 2.2 adoption (when required)

5.4 Build Accessibility into Development Processes

Action Items:

• Include accessibility in design reviews
• Implement automated accessibility testing in CI/CD pipelines
• Require accessibility checks before site launches
• Use accessible component libraries and design systems
• Train developers on ARIA and semantic HTML

Common Pitfalls to Avoid

Relying Only on Automated Tools: Automation catches only 30-40% of issues. Combine with manual and user testing.

Treating Compliance as One-Time Project: Accessibility requires ongoing commitment. New content must be accessible from creation.

Ignoring Third-Party Applications: You're responsible for vendor-provided tools. Build accessibility requirements into procurement.

Overlooking Document Accessibility: PDFs and documents are explicitly covered by Title II. They need remediation too.

Skipping User Testing: Real users with disabilities will find issues automated tools miss. Their feedback is invaluable.

Underestimating Timeline: With thousands of pages, remediation takes time. Start now to avoid deadline stress.

Resources for Government Agencies

Official Guidance:

• ADA.gov Title II Guidance
• Section508.gov (Federal standard, but excellent resource)
• DOJ Final Rule Fact Sheet

Training:

• W3C Digital Accessibility Foundations (Free)
• Section508.gov Training Resources
• Deque University

Testing Tools:

• Beacon - Automated scanning with depth control for comprehensive coverage
• WAVE Browser Extension - Free browser-based testing
• axe DevTools - Developer-focused testing
• Accessibility Insights - Microsoft's free testing suite

Procurement:

• Section508.gov Procurement Resources
• IT Accessibility Laws and Policies

How Beacon Helps Government Agencies

Beacon is specifically designed to address the scale challenges government agencies face:

Comprehensive Site Coverage: Unlike manual testing that checks individual pages, Beacon can scan entire websites at multiple depth levels, discovering violations across hundreds or thousands of pages automatically.

Axe-core Powered: Built on the industry-standard Axe-core accessibility engine, Beacon provides reliable WCAG 2.1 Level AA conformance checking trusted by major organizations.

Actionable Reporting: Violations are categorized by WCAG criterion, severity, and page location, making it easy to prioritize remediation efforts and track progress over time.

Continuous Monitoring: Schedule regular scans to catch new issues before they become compliance problems. Essential for maintaining compliance after initial remediation.

Multi-Project Support: Manage all your sites, departments, and third-party applications in one platform, perfect for government agencies with numerous digital properties.

Government agencies can start with a free account to scan critical pages, then upgrade to Professional or Enterprise tiers for comprehensive multi-page scanning as deadlines approach.

Timeline Recommendation

For jurisdictions with April 24, 2026 deadline (50,000+ population):

• Months 1-2 (Now - January 2026): Complete assessment and audits
• Months 2-3 (January - February 2026): Planning, budgeting, procurement
• Months 3-18 (February 2026 - June 2027): Remediation and implementation
• Months 18-22 (June - October 2027): Testing and verification
• Months 22+ (October 2027+): Ongoing maintenance and monitoring

For jurisdictions with April 26, 2027 deadline (under 50,000 population):

You have an extra year, but don't delay. The same scope of work exists, and starting early reduces stress and allows for thorough testing.

Conclusion

Title II compliance is achievable with proper planning, adequate resources, and a systematic approach. While the statistics on government website accessibility are sobering—307 violations per page on average—they represent an opportunity to improve access to critical public services for millions of people with disabilities.

The key is to start now, prioritize systematically, and build accessibility into your ongoing processes rather than treating it as a one-time project. With the right tools, training, and commitment, your agency can meet the deadline and provide truly accessible digital services.

Remember: accessibility isn't just about compliance. It's about ensuring all residents can access the government services they need, participate in civic life, and exercise their rights as citizens. That mission is worth the investment.

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Ready to start your compliance journey? Try Beacon free to scan your first government website and identify your accessibility baseline. Our automated scanning helps you understand the scope of work ahead and track progress toward compliance.