A starting sequence · Based on DOJ's own guidance
11 First Steps Toward Title II Website Accessibility
Last updated June 11, 2026
The ADA Title II web rule gives every state and local government a deadline and a standard, WCAG 2.1 Level AA. What it does not give you is a to-do list. This page does. These 11 steps mirror the Department of Justice's own first-steps guidance, translated into the practical work each one actually involves.
Before You Start
You do not need to do all 11 steps this month, and you do not need to do them perfectly. You need to start, because several of these steps, especially the inventory and the vendor contracts, take far longer than people expect. Your deadline is April 26, 2027 if your entity serves a population of 50,000 or more, or April 26, 2028 if it is smaller or a special district. Confirm your deadline first, then work backward.
The 11 Steps
1.Learn the rule
Someone in your organization needs to actually understand what the rule requires, not just that it exists. Start with our plain-language overview of the web rule and our guide to WCAG 2.1 AA, then skim the regulation itself in Subpart H. An hour of reading now prevents months of confusion later.
2.Figure out your deadline
Your compliance date depends on your total population: April 26, 2027 for entities at 50,000 or more, April 26, 2028 for smaller entities and all special districts. Then build a working backward schedule. If fixes take a year and procurement takes six months, your real start date is sooner than the deadline suggests. Check your date here.
3.Identify staff roles
Decide who owns this. Typically that means a lead, often the ADA coordinator, plus the people who touch web content: communications staff, webmasters, clerks who post agendas, HR staff who post jobs, and the IT contact for each system. Compliance fails when everyone assumes it is someone else's job.
4.Train staff
Everyone who creates or posts content needs basic training: how to write alt text, how to use real headings, how to make an accessible PDF, how to caption a video. This is not developer training. It is an afternoon of practical skills for ordinary office software, repeated for new hires.
5.Inventory your web content and apps
List everything you provide or make available online: your main site, department microsites, payment portals, agenda and minutes systems, recreation registration, library systems, GIS maps, mobile apps, and major document collections. Include systems run by vendors on your behalf. Most entities are surprised by how long this list gets, which is exactly why it comes early.
6.Review the exceptions
The rule has five narrow exceptions, listed in section 35.201: archived content, certain preexisting documents, some third-party content, individualized password-protected documents, and preexisting social media posts. Walk your inventory against them honestly. They are narrower than they sound, and an exception stops applying the moment the content is used to access a current service.
7.Determine what must meet WCAG 2.1 AA
Whatever is left after the exceptions is your compliance scope. Mark each item in the inventory: must conform, excepted, or retire it. Retiring is underrated. An outdated page or a 2014 PDF nobody needs is faster to delete than to fix, and a smaller web presence is easier to keep accessible.
8.Identify what needs fixing
Now test against the standard. Run automated scans across your sites to catch common failures like missing alt text, low contrast, and unlabeled form fields, then have a person check key pages with a keyboard and a screen reader. The output is a findings list tied to your inventory: what fails, where, and how badly.
9.Prioritize the fixes
Fix the services people depend on first: payments, applications, emergency information, meeting agendas, enrollment. Use traffic data and complaint history to rank the rest. A prioritized, dated remediation plan also puts you in a far better position if a complaint arrives before you are finished.
10.Review vendor and procurement contracts
The rule covers content provided through contractors and vendors, so your payment portal and agenda system are your responsibility even though someone else built them. Ask every vendor for their WCAG 2.1 AA status in writing, add accessibility requirements to new contracts and renewals, and make conformance a scored criterion in RFPs. Contract cycles are slow. Start this one now.
11.Create ongoing policies
Compliance is not a one-time project, because your website changes every week. Write it down: an accessibility policy, a posting checklist for staff, scheduled scans, accessibility checks before anything new launches, and a public way for residents to report barriers. Our checklist page is a good skeleton for these routines.
Notice the pattern: the first seven steps are about understanding, and only the last four are about fixing. That order is deliberate. Entities that jump straight to remediation tend to fix low-value pages, miss vendor systems entirely, and run out of budget before the content that residents actually depend on gets touched. An honest inventory and a clear scope make every dollar after that count.
Common Questions
Do we have to follow these 11 steps in order?
No. They are a sensible sequence, not a legal requirement. Many entities run several steps in parallel, for example training staff while the content inventory is underway. What matters is starting early enough that fixes, contracts, and retesting all finish before your deadline.
How long does it take to reach WCAG 2.1 AA compliance?
It depends on the size of your web presence and how much of it lives with vendors. Small towns with one site and a handful of PDFs can often get there in months. Counties, school districts, and states with dozens of systems usually need a year or more, especially when vendor contracts have to be renegotiated.
We have almost no IT staff. Can we still do this?
Yes. Most of the early steps, like inventorying content, reviewing contracts, and setting policies, are administrative work, not technical work. For the technical pieces, lean on your website vendor, your state municipal league, regional councils of government, or an accessibility partner.
Does fixing our main website cover us?
Not by itself. The rule covers all web content and mobile apps you provide or make available, including payment portals, agenda systems, recreation registration, library catalogs, and content provided through vendors. That is why the inventory step matters so much.
What should we fix first?
Start with the services people depend on most: payments, applications, emergency information, meeting agendas, and enrollment. A barrier on a high-traffic service page does more harm than one on an old newsletter. A scan plus traffic data gives you a defensible priority list.
Need help prioritizing? Start with a scan.
Steps 8 and 9 are where most entities stall. A scan of your sites turns the guesswork into a ranked list of what to fix first, sized to your deadline.