Getting Started
If your organization is covered by the ADA's Title II web rule — or you're a private business aiming for digital accessibility — the question isn't whether to act, but where to start. This guide gives you a practical roadmap.
You don't need to fix everything overnight. The key is to start now, document your progress, and build accessibility into your workflow going forward.
Step 1: Conduct an Accessibility Audit
An accessibility audit tells you where you stand today. It should combine two approaches:
- Automated scanning: Tools like axe (by Deque), WAVE (by WebAIM), or Google Lighthouse can quickly scan pages and flag common issues like missing alt text, low contrast, and missing form labels. These tools catch roughly 30–40% of issues.
- Manual testing: A person tests the site using a keyboard only (no mouse), a screen reader (like NVDA, JAWS, or VoiceOver), and checks for logical reading order, clear navigation, and understandable content. This catches the other 60–70% of issues.
Example: An automated scan may flag that an image has no alt text. But only manual testing reveals that a dropdown menu can't be opened with a keyboard, or that a screen reader reads a table in the wrong order.
Official Standard
ADA.gov — Web Rule First Steps
The DOJ recommends that entities "audit the accessibility of existing web content and mobile apps" as a first step toward compliance. This includes both automated scanning and manual testing.
28 CFR §35.200 requires conformance with WCAG 2.1 Level AA. An audit evaluates your current content against these specific success criteria to identify gaps.
Step 2: Prioritize Issues by Severity
Once you know the issues, prioritize them. Not all accessibility problems are equally serious. Focus first on:
Also prioritize your highest-traffic pages and essential services first — the homepage, online forms, payment portals, and public meeting pages affect the most people.
Step 3: Create a Remediation Plan
With priorities set, create a written remediation plan with specific timelines:
- List every issue found in the audit, grouped by priority
- Assign owners — who is responsible for fixing each category of issue (web team, content team, vendor)
- Set deadlines — critical issues should be addressed first, ideally within weeks, not months
- Track progress — use a spreadsheet, project management tool, or accessibility-specific dashboard
- Re-test — verify that fixes actually resolve the issues and don't create new ones
Tip: A written plan with dates also demonstrates good faith effort, which can matter in enforcement contexts.
Step 4: Build Accessibility Into Vendor Contracts
If you use third-party vendors for your website, CMS, forms, payment systems, or apps — you're still responsible for their accessibility. Include these in vendor contracts:
- WCAG 2.1 Level AA conformance as a requirement, not a goal
- Vendor must provide a VPAT / Accessibility Conformance Report (ACR) based on testing, not self-declaration
- Remediation timelines for any issues discovered after deployment
- Accessibility testing as part of acceptance criteria before launch
Example: A city uses a vendor for its online permitting system. If the vendor's platform has inaccessible forms, the city — not the vendor — is responsible under the ADA. The contract should ensure the vendor delivers an accessible product.
Official Standard
DOJ Guidance on Third-Party Content
While the web rule excepts third-party content not under the entity's control, content posted by or for the entity — including content managed through vendor platforms — remains the entity's responsibility.
"A public entity may not… use contractual, licensing, or other arrangements as a subterfuge to evade its obligations." — 28 CFR §35.130(b)(3)
Step 5: Train Content Creators
Most accessibility issues are introduced when content is created — not during initial development. Everyone who adds or updates content needs basic training:
- Write meaningful alt text for every image
- Use proper heading structure (H1, H2, H3 in order — don't skip levels)
- Write descriptive link text ("View the meeting agenda" not "Click here")
- Create accessible documents — tagged PDFs with reading order, not just scanned images
- Add captions to all videos before posting
- Use sufficient color contrast when choosing colors for graphics or presentations
Step 6: Establish Ongoing Testing
Accessibility isn't a one-time fix. New content is added constantly, and each update can introduce new issues. Build testing into your regular workflow:
- Automated scans on a regular schedule (weekly or monthly) to catch regressions
- Manual review of new pages and features before they go live
- User testing with people who use assistive technology — this is the gold standard
- Feedback mechanism — a way for visitors to report accessibility issues they encounter
Step 7: Document Everything
Keep records of your accessibility work. This matters for two reasons:
- Good faith: If a complaint is filed, documented efforts show you're taking accessibility seriously and working toward compliance — not ignoring the issue.
- Institutional knowledge: Staff turnover is inevitable. Written plans, policies, and procedures ensure accessibility work continues.
Document your audit results, remediation plan, training records, vendor accessibility requirements, and testing schedule.
Useful Testing Tools
Important Note
This guide provides general information about approaching web accessibility compliance. Every organization's situation is different, and the technical and legal requirements can be complex. For legal advice about your obligations or your rights, connect with an experienced ADA attorney.
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