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Preparing for the ADA Title II Compliance Deadline

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Digital Accessibility Essentials:

Hosted virtually by Travel Oregon

Facilitated by Jen Macias, Digital Accessibility Adviser, CPACC

Held on Tuesday, February 10th, 2026

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Accessibility Check

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Any digital materials I share in this presentation will include

Added alt text to images
Checked headlines, outline, and reading order of slide layouts
Checked color contrast
Brief visual descriptions will be provided of images

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Agenda for Today

Legal Landscape
Scope & Applicability
Understanding WCAG 2.1 vs 2.2 Standards
Assessment & Prioritization
Accessibility Statements
Action Planning & Next Steps
Resources & Ways to Stay Engaged
Q&A

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What to Expect

Unpacking of regulatory guidelines
Clarifying questions from you
Reflection questions from Jen
Defining how accessibility supports destination stewardship
Perspective videos
Sharing resources

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Hi, I’m Jen 👋🏽

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I am a…

Strategist, experience designer and accessibility specialist �
Cross-pollinator, moving ideas between disciplines to create more coherent, caring environments

I’m shaped by…

A childhood rooted in Arizona and navigating foster care by thirteen�
Moving through the world as a mixed-race person with a non-apparent disability�
Surviving state-sanctioned hostility —experiences that sharpened my sense of care/responsibility

My work has grown through…

Founding and running an independent, community-rooted design studio
Consulting for major enterprises, from Fortune 10 to Fortune 500, and public institutions
Leading and evolving the accessibility practice within a global consulting firm

Qualifications

10 + years
Certified Professional in Accessibility Core Competencies (CPACC)
DHS OAST: Section 508 Web Standards, Authoring Accessible Docs, Trusted Tester

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What is Digital Accessibility?

Digital accessibility is about ensuring everyone, regardless of ability, can use digital products with the same ease, dignity, and independence as anyone else.

Digital Accessibility Essentials

Preparing for the ADA Title II Compliance Deadline

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Web vs Digital Accessibility

Digital Accessibility Essentials

Preparing for the ADA Title II Compliance Deadline

Digital accessibility means designing and developing digital content, tools, and technologies so that people of all abilities can perceive, understand, navigate, and interact with them — equally and independently.

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What’s the difference between�Web and Digital Accessibility?

Web Accessibility:

Websites and web applications

Digital Accessibility:

Websites and web applications
Mobile apps (iOS, Android)
Software applications/programs
Digital documents (PDFs, Word docs, presentations)
Digital media (videos, audio, interactive content)
Electronic kiosks and digital displays, and more

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AT Example: Apple

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Biggest Questions & Concerns

We asked:

“What's your biggest question or concern about how the new ADA Title II rule will affect your work with government agencies?”

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45%

Want to understand compliance requirements

30%

Interested in implementation and how-to

10%

Learning more about resources and support

7.5%

Understand enforcement mechanisms and impact

7.5%

Not sure yet. “Don’t know what I don’t know”

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Legal Landscape

New ADA Title II requirements
Compliance deadlines
Why this matters: real consequences of non-compliance

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Legal Framework

Digital Accessibility — Legal Landscape

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Policy / Law	Description
Americans with Disabilities Act (ADA)	U.S. civil rights law (1990) prohibiting disability-based discrimination. Requires equal access to physical and digital spaces, including websites and online services.
Section 508�part of the Rehabilitation Act of 1973, amended in 1998	U.S. federal law requiring federal agencies to ensure all electronic and information technology (EIT)—websites, software, and digital documents—is accessible to people with disabilities.
—Title II	Applies to state and local governments. Mandates accessibility across all programs and services, including digital platforms and online services.
—Title III	Applies to private businesses and public accommodations. Requires equal access to goods and services, including accessible websites and digital content.

Adopts a rule which was proposed and open for comment in Oct 2023
Specifies tech requirements for web, mobile, and conventional electronic documents, with timelines for compliance
Applies to all Title II entities under the ADA
Outlines several exceptions

Americans with Disabilities Act (ADA)

A U.S. civil rights law passed in 1990 that protects people with disabilities from discrimination. The ADA requires equal access to services, programs, and spaces—including digital experiences like websites and apps—so people with disabilities can participate fully in public life.

Section 508

A U.S. federal accessibility law, originally part of the Rehabilitation Act of 1973 and strengthened in 1998. Section 508 requires federal agencies to ensure that all electronic and information technology (EIT)—such as websites, software, and digital documents—is accessible to employees and the public with disabilities.

ADA Title II

Applies to state and local government entities. Title II requires that all programs, services, and activities—whether in person or online—are accessible. This includes government websites, digital forms, online services, and other public-facing technology.

ADA Title III

Applies to private businesses and organizations open to the public, such as restaurants, retail stores, healthcare providers, gyms, schools, and entertainment venues. Title III requires equal access to goods and services, including accessible websites and digital content, so people with disabilities are not excluded.

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New ADA Title II Requirements

Digital Accessibility — Legal Landscape

In April of 2024, the Department of Justice (DOJ) updated its Title II regulations to “ensure that web content and mobile applications (apps) are accessible to people with disabilities.

The Americans with Disabilities Act (ADA) Title II now requires all state and local governments, along with their third-party contractors and software vendors, to comply with WCAG 2.1, Level AA standards.

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DOJ Title II Fact Sheet

Digital Accessibility — Legal Landscape

Applies to all Title II entities (not just state & local gov) — e.g., courts, schools, public transit, special districts
Covers websites, mobile apps, and electronic documents �(Word docs, PDFs, spreadsheets, etc.)
Requires conformance to WCAG 2.1, Level AA
Includes third-party platforms/services operated for covered entities

Resource: Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps…

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ADA Title II Compliance Deadlines

Digital Accessibility — Legal Landscape

Compliance deadlines for the new ADA Title II requirements are based on the population size of the area served by the government entity.*

Entities serving 50k or more people, compliance is required by April 24, 2026 �
For entities serving fewer than 50k people, compliance is required by April 26, 2027�
For special district governments, compliance is also required by April 26, 2027.�

“State” means each of the 50 US states
District of Columbia
Commonwealth of Puerto Rico
Guam
American Samoa
Virgin Islands
Trust Territory of the Pacific Islands
Commonwealth of the Northern Mariana Islands.

*Local government applies to county, city, town, and municipal governments.

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Timelines for conformance are based on the population size the Title II entity serves

50k or greater = 2 years after rule goes into effect
Less than 50K = 3 years after the rule goes into effect

The rule was entered into the Federal Register on April 24 and goes into effect 60 days afterward
Mark June 23, 2026/2027 on your calendar

The Department of Justice (DOJ) has established compliance deadlines for the new ADA Title II requirements based on the population size of the area served by the government entity.

By definition, “State” means each of the 50 US states, as well as the District of Columbia, the Commonwealth of Puerto Rico, Guam, American Samoa, the Virgin Islands, the Trust Territory of the Pacific Islands, and the Commonwealth of the Northern Mariana Islands. Local government applies to county, city, town, and municipal governments.

For entities serving 50,000 or more people, compliance is required by April 24, 2026 (two years after the rule’s publication).
For entities serving fewer than 50,000 people, compliance is required by April 26, 2027 (three years after the rule’s publication).
For special district governments, compliance is also required by April 26, 2027.

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Mechanisms of Enforcement

Digital Accessibility — Legal Landscape

How will ADA Title II regulations be enforced?

Government Enforcement → Department of Justice (DOJ)

DOJ can take direct action against non-compliant entities
Tools include federal lawsuits, administrative actions, and settlement agreements
Consequences result fines, legal fees, and mandatory remediation

Private Enforcement → Individuals & Advocacy Groups

Most ADA enforcement starts here—not with the government
Individuals or disability rights organizations file complaints or lawsuits when they encounter barriers
Cases often result in private settlements or escalate to DOJ involvement

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The new rule under Title II of the ADA does not propose any new enforcement mechanisms. Instead, the DOJ can take existing enforcement actions such as filing lawsuits in federal court, administrative actions, or entering into settlement agreements with state and local government entities.

Two Main Enforcement Paths:

The Government Route The Department of Justice (DOJ) has direct authority to enforce ADA Title II. They can file lawsuits in federal court, take administrative actions, and negotiate settlement agreements with state and local governments. When entities don't comply, they face fines, legal fees, and are required to fix the issues.

The Private Action Route Here's what's important to know: most ADA enforcement actually starts with individuals and advocacy groups. When someone encounters a barrier—whether it's a website, a building, or a service—they can file a complaint or pursue a private lawsuit. These cases often result in settlements, but they can also escalate to DOJ involvement.

The Bottom Line: Either path leads to significant legal costs and mandatory fixes. The key takeaway? It's far more cost-effective to build accessibility in from the start than to defend against enforcement actions later.

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Why this matters

Digital Accessibility — Legal Landscape

A turning point for digital equity and destination stewardship

The shift:

Accessible digital services extend stewardship beyond the physical destination
Exclusion online means exclusion from your destination's economy and community
Accessibility shifts from intent to obligation

What this means:

Clear compliance standard: WCAG 2.1 Level AA
Digital accessibility covers the full visitor journey—planning, booking, navigating
Public agencies are accountable for third-party vendors

Real impact:

Inaccessible services quietly turn away visitors and their spending power
Communities lose participation, connection, and trust
Organizations risk funding eligibility, accountability, and public credibility

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Scope & Applicability

Which organizations are covered by the ruling?
What digital properties must comply?
Are they any exceptions?

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Organizations Impacted by Ruling

Digital Accessibility — Scope of the new ADA Title II Ruling

Title II Entities:

State and local government departments and agencies (city councils, town halls, housing authorities)
Courts and legislative bodies
Law enforcement and public safety (police and fire departments)
Public education (public schools, school districts, public colleges, and universities)
Public transportation systems (city buses, regional transit authorities, Amtrak)

Public health and social services �(health departments, mental health agencies, public housing)
Libraries, museums, and recreational facilities
Voting locations and emergency management services
Special purpose districts �(water districts, utility districts)

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Public Entities Covered by ADA Title II include any State or local government, department, agency, special purpose district, or other instrumentality of a State or local government, as well as the National Railroad Passenger Corporation (Amtrak) and any commuter authority. This encompasses a wide range of government functions and services, such as:

State and local government departments and agencies (e.g., city councils, town halls, housing authorities)
Courts and legislative bodies
Law enforcement and public safety (e.g., police and fire departments)
Public education (e.g., public schools, school districts, public colleges, and universities)
Public transportation systems (e.g., city buses, regional transit authorities, Amtrak)
Public health and social services (e.g., health departments, mental health agencies, public housing)
Libraries, museums, and recreational facilities
Voting locations and emergency management services
Special purpose districts (e.g., water districts, utility districts)

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Third-Party Platforms, Services, & Vendors

Digital Accessibility — Scope of the new ADA Title II Ruling

Who is liable for compliance, the government entity or third-party contractor?

Primary liability of government entities

Under Title II, government entities are responsible for ensuring that all public-facing digital content, including content provided or managed by third parties, complies with accessibility standards such as WCAG 2.1 Level AA. This means the government entity cannot transfer its obligations under Title II to third-party contractors.

Role of third-party vendors

Third-party vendors are considered agents of the government entity. While third-party vendors play a critical role in creating or managing digital content, the government entity is responsible for ensuring that vendors adhere to accessibility requirements.

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Title II of the Americans with Disabilities Act (ADA) places the ultimate responsibility for compliance on the government entity, even when third-party vendors provide content or services. Here’s how this impacts third-party content and vendor relationships:

Primary liability of government entities�Under Title II, government entities are responsible for ensuring that all public-facing digital content, including content provided or managed by third parties, complies with accessibility standards such as WCAG 2.1 Level AA. This means the government entity cannot transfer its obligations under Title II to third-party contractors.

Role of third-party vendors�Third-party vendors are considered agents of the government entity. Therefore, while third-party vendors play a critical role in creating or managing digital content, the government entity is responsible for ensuring that vendors adhere to accessibility requirements.

Contractual obligations�Government entities should include explicit accessibility requirements in their contracts with vendors. These contracts should:

Require compliance with WCAG 2.1 Level AA or other applicable accessibility standards.
Include provisions for monitoring and verifying compliance.
Clearly define consequences for non-compliance, such as withholding payment or requiring remediation.

Shared responsibility for compliance:�If a vendor fails to meet accessibility standards, the government entity remains liable. However, the vendor may also face legal or financial repercussions depending on the terms of the contract.

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Third-Party Platforms, Services, & Vendors Cont.

Digital Accessibility — Scope of the new ADA Title II Ruling

A shared responsibility for compliance

Contractual obligations

Government entities should include explicit accessibility requirements in their contracts with vendors. These contracts should:

Require compliance with WCAG 2.1 Level AA or other applicable accessibility standards.
Include provisions for monitoring and verifying compliance.
Clearly define consequences for non-compliance, such as withholding payment or requiring remediation.�

→ Compliance Guide: Third-Party Exceptions

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Title II of the Americans with Disabilities Act (ADA) places the ultimate responsibility for compliance on the government entity, even when third-party vendors provide content or services. Here’s how this impacts third-party content and vendor relationships:

Primary liability of government entities�Under Title II, government entities are responsible for ensuring that all public-facing digital content, including content provided or managed by third parties, complies with accessibility standards such as WCAG 2.1 Level AA. This means the government entity cannot transfer its obligations under Title II to third-party contractors.

Role of third-party vendors�Third-party vendors are considered agents of the government entity. Therefore, while third-party vendors play a critical role in creating or managing digital content, the government entity is responsible for ensuring that vendors adhere to accessibility requirements.

Contractual obligations�Government entities should include explicit accessibility requirements in their contracts with vendors. These contracts should:

Require compliance with WCAG 2.1 Level AA or other applicable accessibility standards.
Include provisions for monitoring and verifying compliance.
Clearly define consequences for non-compliance, such as withholding payment or requiring remediation.

Shared responsibility for compliance:�If a vendor fails to meet accessibility standards, the government entity remains liable. However, the vendor may also face legal or financial repercussions depending on the terms of the contract.

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Public Education

Digital Accessibility — Scope of the new ADA Title II Ruling

Public schools, school districts, public colleges, and universities

The compliance deadline for public universities or school districts depends on the population of the area they serve, not the size of the student body.

For example, if a school district has 50,000 or more people, the deadline is sooner than for areas with fewer than 50,000 people.

Private universities and school districts are required by ADA Title III to make their digital offerings accessible to students, parents, and guardians.

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Tourism Campaigns & Social Media

Digital Accessibility — Scope of the new ADA Title II Ruling

How does this ruling impact tourism digital touchpoints?

Title II requires all visual and multimedia content on state and local government digital platforms to be accessible to individuals with disabilities.

This includes websites, tourism campaigns, and social media. Compliance with the regulation means meeting the WCAG 2.1, AA standards.

There are some exceptions for archived web content and preexisting social media posts. You can check out the five exceptions in detail within the DOJ’s compliance guidelines.

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Digital Properties

Digital Accessibility — Scope of the new ADA Title II Ruling

What digital properties must adopt this ruling?

Website and web applications
Digital documents
Mobile applications
Online forms and applications
Online learning and administration platforms
Digital kiosk and self-service terminals
Third-party content and vendor services
Social media and live content

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Under the new requirements, all websites and mobile apps that US state and local governments provide to their constituents and the general public must be accessible to people with disabilities.

One important distinction is that these rules also apply to any third-party vendors that governments use to provide these online services.

This includes any online services, information, or activities that the public can access such as

websites for public schools
libraries
voting information
health services
Public museums

Websites and Web Applications�All public-facing and internal websites, including main portals, departmental sites, microsites, and web apps used by state and local governments, must comply with WCAG 2.1 Level AA. This includes interactive tools, online forms, and content behind login systems.

Mobile Applications�Government-provided mobile apps—such as those for public transportation tracking, emergency alerts, or service portals—must be accessible and conform to WCAG 2.1 Level AA.

Digital Documents�PDFs, Word documents, PowerPoint presentations, and spreadsheets used to apply for, access, or participate in public services must be accessible. This includes syllabi, forms, reports, and financial documents.

Online Forms and Applications�All digital forms for services such as license applications, permit requests, tax payments, and student enrollment must be fully accessible, with proper labeling, error handling, and keyboard navigation.

Online Learning and Administrative Platforms�For public universities, this includes learning management systems (e.g., Canvas, Blackboard), course materials, digital textbooks, video lectures with captions, and student or employee portals.

Digital Kiosks and Self-Service Terminals�Publicly accessible kiosks, such as those in libraries, transportation hubs, or government offices, must provide accessible digital interfaces.

Third-Party Content and Vendor Services�Content or services provided through contracts or licensing agreements (e.g., SaaS platforms, cloud tools) must meet accessibility standards if they are used to deliver public services.

Social Media and Live Content�Publicly posted social media content, live streams, and prerecorded videos must include captions, transcripts, and audio descriptions.

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Digital Documents

Digital Accessibility — Scope of the new ADA Title II Ruling

What kinds of digital documents must adopt this ruling?

Any form of documentation used to apply for, access or participate in public services must be accessible.

Most commonly used formats:

PDFs
Word documents
Presentations files (ex: PowerPoint, Google Slides, Keynote)
Spreadsheet files

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Private Websites

Digital Accessibility — Scope of the new ADA Title II Ruling

Do these new requirements apply to private citizens with websites?

The new ADA Title II requirements do not apply to personal websites owned by private citizens, especially if no direct sales or public services are offered.

Title II of the ADA specifically applies to websites and mobile apps run by state and local governments. Personal websites, blogs, or hobby sites that don’t offer public services or sell products are not required to meet these new accessibility standards.

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Key Exceptions

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Exceptions

ADA Title II Ruling — Exceptions

Are there any exceptions to the new Title II regulations?

There are five specific exceptions to the Title II regulation, categorized as follows:

Archived web content
Pre existing conventional electronic documents
Content posted by a third party where the third party is not posting due to contractual, licensing, or other arrangements with a state or local government
Individualized documents that are password-protected
Preexisting social media posts

→ Compliance Guide: Summary of Exceptions

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Archived Web Content

ADA Title II Ruling — Exceptions

What are the guidelines on archived documents?

Your state or local government’s web content that meets all four of the following points would not need to meet WCAG 2.1, Level AA:

The content was created before the date your government must comply with this rule, or reproduces paper documents or the contents of other physical media that were created before your government must comply with this rule, AND
The content is kept only for reference, research, or recordkeeping, AND
The content is kept in a special area for archived content, AND
The content has not been changed since it was archived.�

→ Compliance Guide: Archived Web Content

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2. Pre Existing Conventional Electronic Documents

ADA Title II Ruling — Exceptions

What about older documents that aren’t technically archived?

State or local government’s documents that meet all three of the following points do not need to meet WCAG 2.1, Level AA

The documents are word processing, presentation, PDF, or spreadsheet files; AND
They were available on your state or local government’s website or mobile app before the date your state or local government must comply with this rule; AND
They are not currently being used to apply for, access, or participate in your state or local government’s services, programs, or activities.

→ Compliance Guide: Preexisting Conventional Electronic Documents

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Some state and local governments have a lot of old documents, like PDFs, on their website. It can sometimes be hard to make these documents meet WCAG 2.1, Level AA.

Your state or local government’s documents that meet all three of the following points do not need to meet WCAG 2.1, Level AA:

The documents are word processing, presentation, PDF, or spreadsheet files; AND
They were available on your state or local government’s website or mobile app before the date your state or local government must comply with this rule; AND
They are not currently being used to apply for, access, or participate in your state or local government’s services, programs, or activities.

Example: This exception would apply to a PDF flyer for a Thanksgiving Day parade posted on a town’s website in 2018, or a Microsoft Word version of a sample ballot for a school board election posted on a school district’s website in 2014.

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3. Third-Party Content (Non-contractual)

What about content posted that isn’t under contract, license, or other arrangements with state and local governments?

Third parties are members of the public or others who are not controlled by or acting for state or local governments. Your state or local government may not be able to change the content third parties post.

Example:�A message that a member of the public posts on a town’s online message board would fall under the exception.

Content that is posted by third parties on your state or local government’s website or mobile app would not need to meet WCAG 2.1, Level AA.�

→ Compliance Guide: Non-Contractual Third-Party

→ Compliance Guide:

ADA Title II Ruling — Exceptions

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4. Password-Protected Documents

ADA Title II Ruling — Exceptions

What about individualized documents that are password-protected?

Your state or local government’s documents that meet all three of the following points do not need to meet WCAG 2.1, Level AA:

The documents are word processing, presentation, PDF, or spreadsheet files, AND
The documents are about a specific person, property, or account, AND
The documents are password-protected or otherwise secured.

Example: A PDF version of a water bill for a person’s home that is available in that person’s secure account on a city’s website would fall under the exception. However, the exception does not apply to the city’s website itself.�

→ Compliance Guide: Individualized Documents that are Password-Protected

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State and local governments sometimes use password-protected websites to share documents that are for specific individuals, like a water or tax bill. It might be hard to make all of these documents accessible right away for everyone, and there might not be a person with a disability who needs access to these documents.

Your state or local government’s documents that meet all three of the following points do not need to meet WCAG 2.1, Level AA:

The documents are word processing, presentation, PDF, or spreadsheet files, AND

The documents are about a specific person, property, or account, AND

The documents are password-protected or otherwise secured.

Example: A PDF version of a water bill for a person’s home that is available in that person’s secure account on a city’s website would fall under the exception. However, the exception does not apply to the city’s website itself.

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5. Preexisting Social Media Posts

ADA Title II Ruling — Exceptions

What are the guidelines on historical content in the form of social media?

Preexisting social media posts are exempt from the new requirements. Any social media posts made before the ADA Title II compliance date for your state or local government entity do not need to be accessible or archived.

What the exception does not change:

It’s important to know that archived content that does not meet WCAG 2.1 Level AA must be made accessible if an individual with a disability requests access to the content.

→ Compliance Guide: Social Media Posts

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Understanding WCAG �2.1 and 2.2 Standards

What WCAG is and how it's structured (Levels A, AA, AAA)
Key differences between WCAG 2.1 and 2.2
The DOJ's Level AA requirement explained

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Understanding WCAG

Understanding WCAG 2.1 and 2.2 Standards

Web Content Accessibility Guidelines (WCAG) often pronounced as “wuh-cag.”

WCAG is the global standard in digital accessibility guidelines. It enables all organizations to measure the accessibility of content, sites, and apps against documented requirements for all people, including those with disabilities

World Wide Web Consortium (W3C)

WCAG are developed and maintained by the World Wide Web Consortium (W3C) and are widely accepted as the go-to standard for digital accessibility.

WCAG 2.0, 2.1, and 2.2

Successive versions of standards, each building on the previous one to address evolving technologies and user needs.

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Level A, AA, and AAA

Understanding WCAG 2.1 and 2.2 Standards

Levels A, AA, and AAA is how conformance is measured.

z

Level A is the most basic level of accessibility conformance.

Level AA is the second level of conformance. The ADA and Section 508 require both Level A and Level AA.

Level AAA is the third and most advanced level of conformance. It is not generally recommended as a requirement, because it is not possible to satisfy all criteria for some types of content.

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Level A

30 �success criteria

Level AA

20 �success criteria

Level AAA

31 �success criteria

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POUR Principles of Accessibility

P

O

U

R

Understanding WCAG 2.1 and 2.2 Standards

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Web Content Accessibility Guidelines (WCAG)

Perceivable

Information and the user interface must be presented to users in ways they can perceive.

Operable

User interface components and navigation must be operable.

Understandable

Information and operation of the user interface must be understandable.

Robust

Content must be robust enough that it can be interpreted reliably, including while using assistive technology.

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Support all the ways users interact with digital interfaces

Understanding WCAG 2.1 and 2.2 Standards

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Mouse

Pointing, clicking, mouse, or trackpad

Keyboard

Especially for navigation on all elements

Touch

Swiping, gestures, especially on mobile, but consider desktop touch screens too

Assistive Tech

Primarily screen readers, but also consider screen zoom, audio captions, SEO crawlers

Voice

“Hey Google, open the photos app. Select all the pictures of elephants. Send them to my friend.”

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Support all the ways people consume digital information

Understanding WCAG 2.1 and 2.2 Standards

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Visual

All images presented on screens, videos, text, websites, captions

Audio

Music, speech, notification chimes

Haptics

Physical reminders of notifications or interactions

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AT Example: Haptics

Understanding WCAG 2.1 and 2.2 Standards

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Key Differences - WCAG 2.1 vs 2.2

Understanding WCAG 2.1 and 2.2 Standards

WCAG 2.0, 2.1, and 2.2 are designed to be “backwards compatible”

which means content that conforms to 2.2—conforms to 2.1 and 2.0. All success criteria from 2.0 are included in 2.1, and all from 2.1 are in 2.2 (with one exception).

WCAG 2.1

The new TItle II ruling is requiring that WCAG 2,1, Level AA be met. This essentially operates as the “floor.” Organizations may choose to adopt more rigorous standard such as WCAG 2.2.

WCAG 2.2

Adds 9 new success criteria focused on mobile accessibility, low vision, and cognitive disabilities.

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WCAG 2.1, Level AA

Understanding WCAG 2.1 and 2.2 Standards

Ensures travelers can plan, access, and participate in your destination—regardless of how they access the web.

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Assessment & Prioritization

How to scope your accessibility work
Recommended evaluation tools
Prioritization frameworks for remediation

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How to scope your accessibility work

Building A Realistic Compliance Roadmap

Start with critical visitor journeys, not the entire site
Scope by impact, not page count
Include content and tools visitors rely on to plan and participate

Reflective Question for DMOs:

Which digital touchpoints most affect whether someone can confidently visit our destination?

Scope the work around where access enables/blocks participation in the destination.

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Evaluation Tools

Building A Realistic Compliance Roadmap

Tools help you see problems, but people experience them.

Automated checks → catch obvious issues early
Keyboard testing → reveals navigation barriers fast
Basic screen reader testing → surfaces usability gaps

Reflective Question for DMOs:

Are we evaluating access the way visitors actually encounter our content?

Automated Tools:

Keyboard Testing:

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Prioritization frameworks for remediation

Building A Realistic Compliance Roadmap

Prioritization is about removing the greatest barriers first.

Does this block someone from planning or booking?
Does it affect high-traffic or essential content?
Does it prevent independent use?

If “yes” to any → high priority

Reflective Question for DMOs:

Which barriers cause the most friction, or exclusion, right now?

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Prioritization Frameworks Example

Perceivable

1.3.1 Info and Relationships - Level A

1.3.1 Sensory Characteristics - Level A

1.4.3 Contrast - Level AA

1.1.1 Non-Text Content

1.4.1 Use of Color�

Operable

2.4.6 Headings and Labels - Level AA

2.4.1 Bypass Blocks - Level A

2.4.4 Link Purpose - Level A

2.4.2 Page Titled

2.4.7 Focus Visible

Understandable

3.3.2 Labels or Instructions - Level A

3.1.1 Language of Page - Level A

3.2.2 On Input - Level A

Robust

4.1.2 Name, Role, Value - Level A

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Low Effort

Low Impact

High Impact

High Effort

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Accessibility Statements:�Your Public Commitment

What an accessibility statement is and why it matters
How statements demonstrate good faith compliance efforts
Examples of effective statements

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What is an Accessibility Statement?

Action Planning & Next Steps

An accessibility statement is a public record of responsibility. It clarifies standards, sets expectations, acknowledges gaps, and invites dialogue—demonstrating that digital equity is an ongoing practice, not a promise made once.

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Accessibility Statement Importance

Action Planning & Next Steps

Why it matters

Makes accessibility visible, not implied
Builds trust by setting clear expectations for users
Extends digital equity beyond intent into accountable practice�

How it demonstrates good faith

Names the standards you follow (e.g., WCAG 2.1 AA)
Describes how accessibility is integrated into your digital work
Acknowledges known limitations and areas in progress
Invites feedback with clear contact information
Documents accessibility as an ongoing responsibility, not a checkbox

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Accessibility Statement Example #1

Action Planning & Next Steps

Inclusive language—clearly stating accessibility is about maintaining dignity and independence
Contact options
Actively invites feedback
Ongoing accessibility efforts
Inclusive design practices
Clear compliance level
Multi-year roadmap
Living practice, not a checklist

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Accessibility Statement Example #2

Action Planning & Next Steps

Inclusive language
Contact options
Actively invites feedback
Ongoing accessibility efforts
Inclusive design practices
Clear compliance level
Multi-year roadmap
Community resources

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Action Planning & Next Steps

Building a realistic compliance roadmap
Common pitfalls to avoid (overlay tools, automated-only testing)
Resources for ongoing compliance

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Building A Compliance Roadmap

Action Planning & Next Steps

Anchored to destination stewardship, trust, and care

A strong accessibility roadmap doesn’t promise perfection. It establishes standards, names responsibility, documents progress,

and treats access as part of caring for a destination and its people.

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Start with responsibility, not perfection

Building A Realistic Compliance Roadmap

Destination Stewardship Mindset:

We’re accountable for the whole visitor journey—even when systems are imperfect.

You don’t need a flawless website to begin
You do need clarity about what works, what doesn’t, and what’s in progress
Transparency builds trust faster than silence

Reflective Question for DMOs:

Where might our digital experiences be quietly preventing people from fully participating in our destination—and are we willing to name that publicly?

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Define your baseline

Building A Realistic Compliance Roadmap

Destination Stewardship Mindset:

We agree on the standard we’re working toward.

WCAG 2.1 Level AA as a shared reference point
Not as a ceiling, but as common ground
This creates alignment across marketing, IT, vendors, and leadership

Reflective Question for DMOs:

Have we clearly agreed on an accessibility standard that guides how we care for visitors across all digital touchpoints—not just our website?

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Map the real visitor journey

Building A Realistic Compliance Roadmap

Destination Stewardship Mindset:

Accessibility failures online become barriers at the destination.

Planning → booking → arrival → on-site → follow-up
Digital touchpoints shape who can participate in the local economy
If a visitor can’t plan, they often can’t come

Reflective Question for DMOs:

Can someone using assistive technology plan, book, and arrive at our destination with the same confidence as everyone else?

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Make progress visible

Building A Realistic Compliance Roadmap

Destination Stewardship Mindset:

Good faith is demonstrated through action and communication.

Publish an accessibility statement
Acknowledge known gaps
Share how issues are reported and addressed
Update as improvements are made

Reflective Question for DMOs:

If a visitor encounters a barrier, do we make it easy for them to tell us?

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Build for continuity, not one-time fixes

Building A Realistic Compliance Roadmap

Destination Stewardship Mindset:

Stewardship means maintaining access over time.

Accessibility survives staff turnover, redesigns, and new vendors
Policies, training, and procurement matter as much as audits
Small, repeatable practices outperform big one-off efforts

Reflective Question for DMOs:

If staff, vendors, or platforms change tomorrow, would our commitment to digital accessibility remain intact?

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Real accessibility is built into systems, not layered on top

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Top 3 “Quick Fixes” to Avoid

Action Planning & Next Steps

Anchored to destination stewardship, trust, and care

Real accessibility is built into systems, not layered on top.

Accessibility overlays and widgets
Automated-only testing
One-time audits

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Accessibility Overlays

Building A Realistic Compliance Roadmap

Accessibility should be part of the destination, �not a setting visitors have to manage.

The quick-fix → add a widget and call it accessible

Quick-fix accessibility overlays or widgets do not meet ADA Title II requirements. �In fact, accessibility overlays or widgets often introduce new barriers and have �been the subject of legal challenges.

A better alternative → fix core barriers in the experience itself

Address structure, contrast, labels, and keyboard access directly
Prioritize high-traffic pages and critical journeys (plan → book → visit)
Use accessibility statements to explain what’s working and what’s in progress

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Automated-Only Testing

Building A Realistic Compliance Roadmap

If visitors can’t complete their journey, compliance doesn’t matter.

The quick-fix → run a scan and move on

Automated tools catch only a fraction of real issues
Miss usability, context, and task completion failures
Don’t reflect lived experience

A better alternative → combine tools with human testing

Use automated tools to catch obvious issues early
Add keyboard testing and basic screen reader checks
Validate real tasks: finding events, booking lodging, getting directions

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One-Time Audits

Building A Realistic Compliance Roadmap

Caring for access is part of maintaining the destination.

The quick-fix → fix issues once and check the box

Sites change constantly
New content introduces new barriers
Compliance decays without ongoing care

A better alternative → build accessibility into ongoing maintenance

Re-test when content, vendors, or platforms change
Set simple internal checks for new pages and campaigns
Assign ownership—even if it’s a shared role

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Where to start

Action Planning & Next Steps

Accessibility is a journey, not a destination.

Don’t panic, but don’t wait. Getting started is the most important part
Determine your timeline for conformance–do you have until April 2026 or 2027?
Inventory assets across your digital environments–determine which can be archived and which must be remediated
Identify services which are operated or maintained by 3rd parties, and begin the conversation regarding their accessibility conformance
Arrange for an evaluation of your digital touchpoints
Post an accessibility statement to collect feedback and communicate progress

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