ADA Website Compliance: What the Law Requires in 2026

Updated October 21, 2026

Short answer: The ADA covers websites of businesses open to the public (Title III) and of state and local governments (Title II), but only governments have a technical rule: WCAG 2.1 Level AA, with compliance dates moved in April 2026 to April 26, 2027 (population 50,000 or more) and April 26, 2028 (smaller entities and special districts). Federal agencies follow Section 508, which uses WCAG 2.0 AA. For businesses, WCAG 2.1 or 2.2 AA is the usual target.

The Americans with Disabilities Act (ADA) applies to websites, but for most businesses it doesn't name a technical standard. The Department of Justice (DOJ) says businesses open to the public and state and local governments must make their web content accessible, and points to WCAG as helpful guidance. Only state and local governments have a binding web rule: WCAG 2.1 Level AA, now due on April 26, 2027 for entities serving 50,000 people or more and April 26, 2028 for smaller ones and special districts. For a business site, WCAG 2.1 or 2.2 AA is the practical target.

This is not legal advice. ADA obligations depend on your organization and on court decisions that differ by region. Talk to a lawyer about your specific situation.

Does the ADA apply to websites?

The ADA was passed in 1990, before the web, so the statute never mentions websites. The DOJ has taken the position since 1996 that it applies to web content anyway. Two parts matter:

Title II covers state and local governments: cities, counties, public schools and universities, courts, transit agencies.
Title III covers businesses open to the public ("public accommodations"): retail stores, banks, hotels, restaurants, doctors' offices, theaters and many more.

In its March 2022 guidance, the DOJ says businesses and governments "have flexibility in how they comply" but must still make what they offer online accessible. It names common barriers: poor color contrast, information shown by color alone, missing alt text, videos without captions, forms without labels, and pages that can't be used without a mouse. It lists WCAG and the Section 508 Standards as existing technical standards that help.

Title III and the courts

Because there is no Title III web regulation, the details come from lawsuits and settlements. Most cases are brought by individuals, and most settle with an agreement to fix the site, usually against WCAG 2.1 AA, plus legal fees. Federal courts have not agreed on everything: in particular, circuits differ on whether a business that exists only online, with no physical location, counts as a public accommodation. State laws can add to the federal rules; California's Unruh Act and New York's laws are often cited in website cases.

The number of cases is large. Seyfarth Shaw, a law firm that tracks ADA Title III filings, counted 3,117 website accessibility lawsuits in federal court in 2025, up 27% from 2,452 in 2024, about 36% of all ADA Title III suits filed in federal court that year. Those numbers don't include suits filed in state courts or demand letters that never reached court.

The Title II rule for state and local governments

On April 24, 2024, the DOJ published a final rule that, for the first time, set a technical standard under the ADA: web content and mobile apps that state and local governments provide or make available, directly or through contractors, must meet WCAG 2.1 Level AA. There are limited exceptions, such as archived content kept only for reference and not changed since, older documents, and some third-party content.

On April 20, 2026, the DOJ published an interim final rule that moved the deadlines by one year. The WCAG 2.1 AA requirement itself didn't change:

Who	Original date	Current date
Public entities with a total population of 50,000 or more	April 24, 2026	April 26, 2027
Public entities under 50,000, and special district governments	April 26, 2027	April 26, 2028

The DOJ took comments on the extension until June 22, 2026 and said it may review the rule further, so watch ADA.gov for changes. If you build sites for a city, school district or public university, these dates apply to your client's site and to any app they offer.

Does the ADA cover mobile sites and apps?

Yes. Nothing in the ADA or the DOJ guidance treats the mobile version of a site differently from the desktop one, and the Title II rule names mobile apps explicitly alongside web content. In practice, many complaints describe problems that are worst on phones: buttons too small to hit, text that can't be enlarged because zoom is disabled, menus that a screen reader can't open, and checkout forms whose fields have no labels. If your site is responsive, test it at phone width with VoiceOver and TalkBack, not only on a desktop with a mouse. If you have a native app as well, it needs the same attention: the Title II rule applies WCAG 2.1 AA to government apps too.

Section 508 for federal agencies

Federal agencies follow a different law: Section 508 of the Rehabilitation Act. The Revised 508 Standards (updated by the U.S. Access Board in 2017 and in force since January 2018) incorporate WCAG 2.0 Level A and AA and apply them to web pages and electronic documents. Contractors who sell software or build websites for federal agencies usually have to show conformance, often with an Accessibility Conformance Report (a VPAT).

Which WCAG version should a business aim for?

WCAG 2.1 AA is the level named in the Title II rule and in most settlements. WCAG 2.2, the current W3C version, keeps all of it (except the obsolete 4.1.1 Parsing) and adds criteria that matter on phones, such as 2.5.8 Target Size (Minimum) and 3.3.8 Accessible Authentication. Building to WCAG 2.2 AA meets 2.1 AA too, and it is also where the European standard is heading; see the European Accessibility Act guide if you sell in the EU.

Be wary of overlay widgets that promise instant compliance with one line of script. They don't change the underlying HTML that screen readers and keyboards rely on, and websites that use them still get sued.

A practical ADA checklist

Most of your visitors use phones, so check the mobile version first. Our WCAG 2.2 mobile checklist covers each criterion in detail; these are the problems DOJ guidance and lawsuits mention most:

Contrast — 4.5:1 for body text, 3:1 for large text. See fixing low-contrast text.
Alt text on every informative image; empty alt="" on decorative ones.
Form labels and error messages in text, not only color.
Keyboard and screen reader access to menus, dialogs, carousels and checkout.
Captions on videos.
Tap targets at least 24 × 24 CSS px. See tap target sizes.
Zoom and large text work: no user-scalable=no, nothing clipped at larger text sizes. See zoom disabled and large text.
An accessibility page with a contact for reporting barriers, and a record of what you have tested and fixed.

<label for="email">Email</label>
<input id="email" type="email" autocomplete="email">

<button type="button" aria-label="Open menu">
  <svg aria-hidden="true" …></svg>
</button>

How do I check my site?

Run the free mobile-friendly test first: it checks text size, contrast, tap targets, sideways scrolling, disabled zoom and 150% text on iPhone and Android screens, plus markup problems such as missing alt text, form labels and button names. Automated tools find a useful share of problems, but they can't decide whether alt text makes sense or whether a checkout works with VoiceOver. Test your most important tasks by hand with a keyboard and a screen reader, fix what you find, and repeat after each redesign.

Frequently asked questions

Is WCAG legally required under the ADA?

For state and local governments, yes: the 2024 Title II rule requires WCAG 2.1 Level AA, with compliance dates of April 26, 2027 or April 26, 2028. For private businesses no regulation names WCAG, but the DOJ points to it and courts and settlements usually use WCAG 2.1 AA.

When must state and local governments comply with the ADA web rule?

After the April 20, 2026 interim final rule, public entities with a population of 50,000 or more must comply by April 26, 2027, and smaller entities and special district governments by April 26, 2028.

Does the ADA apply to online-only businesses?

Federal courts disagree on whether a business with no physical location is a place of public accommodation, so the answer can depend on where you are sued. Many online-only businesses follow WCAG anyway to reduce risk.

Will an accessibility overlay make my site ADA compliant?

No widget can fix inaccessible HTML on its own. Missing labels, poor structure and keyboard traps have to be fixed in the site's code, and sites with overlays are still sued.