City websites serve as the front door to local government services. Residents rely on them to pay utility bills, register for programs, submit permits, and stay informed about community news. When these websites are not accessible, a significant portion of the population can be excluded from essential public services. Approximately 28% of U.S. residents have a disability, according to CDC data, meaning that inaccessible websites can prevent millions of people from engaging with their local government online. Performing a thorough ADA compliance audit on your city website is the first step toward ensuring equal access for everyone.
Recent regulatory changes have made this work even more urgent. In April 2024, the Department of Justice published a final rule under Title II of the ADA that clarifies web and mobile app accessibility obligations for state and local governments. This rule requires compliance with WCAG 2.2 Level AA success criteria. With compliance deadlines now set for April 26, 2027 for jurisdictions with 50,000 or more residents, and April 26, 2028 for smaller jurisdictions and special district governments, city staff need to start auditing their websites now to meet those timelines.
Understanding the Legal Requirements
Title II of the ADA prohibits discrimination by state and local governments in all services, programs, and activities, including those offered on the web. This means that any city website that provides access to government services, information, or transactions must be accessible to people with disabilities. The Department of Justice extended the rule’s compliance dates by one year as of April 2026, giving cities a bit more time, but the requirement remains in place.
For city websites, the technical standard is WCAG 2.2 Level AA. WCAG conformance levels are structured as Level A (minimum), Level AA (mid-range, and the required level for state and local governments under the 2024 rule), and Level AAA (highest, but not always achievable for all content types). Focusing on meeting Level AA success criteria will satisfy the DOJ rule.
Common Accessibility Barriers on City Websites
Before diving into an audit, it helps to know what to look for. According to official guidance from ADA.gov, common website accessibility barriers include poor color contrast, using color alone to convey information, lack of alt text on images, no captions on videos, inaccessible online forms, and mouse-only navigation. City websites often have multiple pages with images that lack meaningful descriptions, making them invisible to screen reader users.
These barriers affect real people every day. A resident with low vision may not be able to read a form field label if the contrast is too low. A person who relies on keyboard navigation may get stuck trying to fill out a permit application if the form requires a mouse click. By identifying these barriers during an audit, your city can prioritize fixes that have the biggest impact.
Steps to Audit Your Compliance
Step 1: Audit All Images for Alternative Text
Images are one of the most common problem areas on city websites. Staff photos, event promotions, maps, and informational graphics often lack alt text or have poor descriptions. To fix image accessibility, you need to audit all images on your site. For each informative image, add descriptive alt text that conveys the purpose or content of the image. For decorative images that add no meaning, mark them with an empty alt attribute (alt=””) so that screen readers ignore them.
This step requires a manual review. Automated tools can flag images without alt text, but they cannot determine whether the description is accurate or useful. Your city website team should go through every page and image, especially on high-traffic pages like the homepage, service directories, and news sections.
Step 2: Check Color Contrast and Use of Color
WCAG 2.2 Level AA requires a contrast ratio of at least 4.5:1 for normal text and 3:1 for large text. City websites often use color schemes that match city branding but fail contrast checks. Use a color contrast analyzer to test pairs of foreground and background colors. Also, ensure that information is not conveyed by color alone. For example, a link that is only blue and underlined works, but a chart that uses red and green to distinguish categories without labels or patterns will be inaccessible to people with color blindness.
Review any place where color is used to indicate status, such as “approved” in green and “denied” in red. Add text labels or icons so the information is clear to everyone.
Step 3: Ensure Full Keyboard Navigation
Many residents cannot use a mouse and rely solely on a keyboard to navigate websites. Your city website must be fully operable using only the Tab, Enter, Escape, and arrow keys. During the audit, test all interactive elements: navigation menus, dropdowns, forms, modals, and accordions. Check that the focus order makes sense and that a visible focus indicator (such as a highlight or outline) shows which element is currently selected.
Pay special attention to dropdown menus and pop-up modals, which are common trouble spots. If a user cannot open or close a modal without a mouse, that is a failure of keyboard accessibility.
Step 4: Review Online Forms and Document Accessibility
Forms are central to city websites for permits, service requests, payments, and event registration. Inaccessible forms can stop a user from completing a transaction. Ensure every form field has an associated label that is programmatically linked (using the label element or aria-label). Error messages must be clear and specific, and the form should not rely on timing or auto-submit actions that a user cannot control.
Documents posted on your website, such as PDFs of city council agendas or budgets, also need to be accessible. If you cannot make a legacy PDF accessible, consider providing an alternative HTML page with the same information. For new documents, follow accessibility standards from the start.
Step 5: Caption Videos and Provide Transcripts
Video content on city websites, such as council meetings, public service announcements, and tourism promotions, must have captions for users who are deaf or hard of hearing. Synchronized captions are required for all pre-recorded video under WCAG 2.2 AA. Additionally, provide a text transcript or summary for audio-only content like podcasts or recorded phone messages.
For live streams, consider real-time captioning. While the 2024 rule applies to content that the city provides, planning ahead for live captioning helps maintain compliance.
Step 6: Use a Combination of Automated and Manual Testing
No single tool can catch every accessibility issue. Automated checkers can identify problems like missing alt text, low contrast, and duplicate IDs quickly, but they miss contextual issues such as whether alt text is meaningful or whether a form label is correctly associated. Manual testing by a human with knowledge of WCAG is essential.
During a manual audit, test with a screen reader (such as NVDA or VoiceOver), navigate using only the keyboard, and check with magnification software. Also consider testing with users who have disabilities. Their feedback will reveal real-world barriers that automated checks may overlook.
Compliance Deadlines to Keep in Mind
The Department of Justice rule sets clear compliance dates for Title II entities. Jurisdictions with 50,000 or more residents must comply by April 26, 2027. Jurisdictions with fewer than 50,000 residents and special district governments must comply by April 26, 2028. These dates were extended by one year from the original timeline, but the work of auditing and remediating your city website should begin as soon as possible.
Because the rule requires meeting WCAG 2.2 Level AA, your audit should be updated to the latest version of the guidelines. Older audits that checked against WCAG 2.0 or 2.1 may not account for new success criteria in 2.2.
Building a Sustainable Compliance Process
An ADA compliance audit is not a one-time project. As your city website grows and changes, new content and features can introduce barriers. Establish a routine of regular audits, train content authors on writing accessible content, and integrate accessibility checks into your publishing workflow. When you add a new page, upload an image, or post a video, ensure it meets WCAG standards before it goes live.
Document your audit findings and create a remediation plan. Prioritize fixes that affect the most critical user paths, such as paying a bill or applying for a permit. Track your progress and keep records of your efforts. Maintaining good documentation can demonstrate good-faith compliance if questions arise later.
Frequently Asked Questions
- What is the deadline for my city to comply with the new ADA rule?
If your city has a population of 50,000 or more residents, the compliance date is April 26, 2027. For cities with fewer than 50,000 residents and for special district governments, the compliance date is April 26, 2028. The Department of Justice extended these dates by one year in April 2026. - Does the ADA rule apply to all content on my city website?
Title II of the ADA applies to all services, programs, and activities that a state or local government offers through its website. This includes informational pages, online forms, documents, videos, and any interactive features. The 2024 rule requires conformance with WCAG 2.2 Level AA for all public-facing web content. - Can I use an automated checker alone to ensure compliance?
Automated accessibility checkers are helpful for identifying technical issues like missing alt text or low contrast, but they cannot catch every problem. Manual testing with screen readers and keyboard navigation is necessary to evaluate context and user experience. A complete audit uses both automated tools and human review. - What are the most common accessibility problems on city websites?
Common barriers include poor color contrast, using color alone to convey information, images without alt text, videos without captions, inaccessible forms, and navigation that requires a mouse. City staff should specifically check images such as staff photos, event promotions, and maps for missing alt text. - How often should I perform an ADA compliance audit?
Because websites change frequently, you should conduct audits at least annually and whenever significant content or design updates occur. Establishing a continuous monitoring process with regular checks on new pages, images, videos, and documents will help you maintain compliance over time.
Learn more about ADA compliance deadlines and requirements to ensure your website and city are prepared for the upcoming deadlines.