Short answer: State and local governments must meet WCAG 2.1 Level AA on their web content and mobile apps under the ADA Title II web rule. Governments serving 50,000 or more people have until April 26, 2027, and smaller ones and special district governments have until April 26, 2028.
Sources: ADA.gov fact sheet; Federal Register, 91 FR 20902.
WCAG 2.1 has dozens of success criteria. This guide picks 12 that web teams can check quickly and that catch many common failures. It is a starting point for a spot check, not a full audit.
What does WCAG 2.1 AA require?
WCAG defines 3 levels of conformance: A, AA and AAA. For Level AA, a page has to satisfy all the Level A and all the Level AA success criteria.
That means a checklist for AA must include Level A checks too. Several of the 12 items below are Level A for that reason.
The Justice Department named WCAG Version 2.1, Level AA as the standard for state and local government web content and mobile apps.
Sources: W3C, Web Content Accessibility Guidelines (WCAG) 2.1, section 5.2.1; ADA.gov fact sheet.
Which dates and exceptions apply?
The dates depend on population. A government serving 50,000 or more people must comply by April 26, 2027. A government serving fewer than 50,000 people, and every special district government, must comply by April 26, 2028.
The Justice Department published an Interim Final Rule on April 20, 2026 that set these dates. Not everything on a site has to be fixed. ADA.gov lists exceptions for:
- Archived web content that meets all 4 listed conditions
- Preexisting conventional electronic documents, such as PDF, word processing, presentation and spreadsheet files, posted before the compliance date
- Content posted by third parties that are not acting for the government
- Password-protected documents about a specific person, property or account that meet all 3 listed conditions
- Social media posts made before the compliance date
Content the government posts itself, including through its vendors or contractors, is not exempt. The exceptions also do not remove the duty to provide effective communication and equal access.
Source: ADA.gov fact sheet.
The 12-point WCAG 2.1 AA checklist
Run each check on your highest-traffic pages first: home page, search, payments, forms and service pages. Write down the page, the result and the owner of the fix.
| Check | WCAG criterion and level | How to test it |
|---|---|---|
| 1. Images have text alternatives | 1.1.1 Non-text Content, A | Turn images off or use a screen reader. Each meaningful image needs a useful description. Decorative images need an empty alt. |
| 2. Videos have captions | 1.2.2 Captions (Prerecorded), A | Play each recorded video with sound off. Spoken words and key sounds must appear as captions. |
| 3. Structure is real markup | 1.3.1 Info and Relationships, A | Check that headings, lists and table headers use real HTML, not bold text or spacing. |
| 4. Text has enough contrast | 1.4.3 Contrast (Minimum), AA | Test text against its background with a contrast tool. Normal text needs at least 4.5:1. Large text needs at least 3:1. |
| 5. Pages reflow on small screens | 1.4.10 Reflow, AA | Set the window to 320 CSS pixels wide. Vertical scrolling content should not need side scrolling. |
| 6. Buttons and fields are visible | 1.4.11 Non-text Contrast, AA | Check borders, icons and focus rings against nearby colors. They need at least 3:1. |
| 7. Everything works by keyboard | 2.1.1 Keyboard, A | Put the mouse aside. Use Tab, Shift+Tab, Enter and Space to reach and use every menu, form and dialog. |
| 8. There is a skip link | 2.4.1 Bypass Blocks, A | Press Tab once on a page. A "skip to main content" link should appear and work. |
| 9. Keyboard focus is visible | 2.4.7 Focus Visible, AA | Tab through the page. You should always see where focus is. |
| 10. Page language is set | 3.1.1 Language of Page, A | Inspect the html element. It needs a correct lang value, such as en. |
| 11. Forms have labels and clear errors | 3.3.1 Error Identification, A; 3.3.2 Labels or Instructions, A | Each field needs a visible label. Submit a form with mistakes. The error must be described in text. |
| 12. Custom controls have a name, role and value | 4.1.2 Name, Role, Value, A | Test custom widgets, such as tabs and date pickers, with a screen reader. Each must announce what it is and its state. |
Sources: W3C, WCAG 2.1; W3C, How to Meet WCAG (Quick Reference).
How do you run the checklist in an afternoon?
Pick 5 pages. A home page, a search results page, a form, a PDF landing page and a payment or permit page cover most patterns.
- Run an automated scan first. Tools find missing alt text, low contrast and missing labels fast, but they cannot judge whether alt text is useful.
- Do checks 5, 7, 8 and 9 by hand. They take minutes and need no tools.
- Test one form end to end with a keyboard and a screen reader. Forms are where residents lose the most time.
- Log each failure with the page, the criterion number, a screenshot and a severity.
- Fix templates before pages. One fix in a header or form component clears hundreds of pages.
- Retest after each fix and keep the log. It shows progress to leadership and to a prime or agency client.
Treat a pass on these 12 as a good sign, not proof of conformance. A full audit reviews every applicable criterion on a representative sample of pages.
What this means for subcontractors
Primes often hold the contract and need a team that can test and remediate to WCAG 2.1 AA. A written 12-point log gives the agency a clear view of what was tested and what is fixed.
See how we work with primes on accessibility and software projects and how to subcontract with Konnex. For dates, read ADA Title II web rule deadlines. For documents, see how to remediate PDFs.
Quick answers
Does WCAG 2.1 AA apply to PDFs on a government site?
Yes, with limits. Preexisting documents posted before the compliance date are generally exempt, but documents posted after it are not.
Is Level A enough for the ADA web rule?
No. The rule requires WCAG 2.1 Level AA, and Level AA includes every Level A criterion plus the Level AA ones.
Does a vendor-hosted payment page count?
Yes. Content the government posts through its vendors or contractors is not exempt as third-party content.
Sources: ADA.gov fact sheet; W3C, WCAG 2.1.
Sources
- Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments, ADA.gov
- Extension of Compliance Dates for Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities, Federal Register, April 20, 2026
- Web Content Accessibility Guidelines (WCAG) 2.1, W3C Recommendation
- How to Meet WCAG (Quick Reference), W3C Web Accessibility Initiative
This is general information, not legal advice.
Planning an accessibility spot check for an agency client? Contact Konnex to talk through scope.