Updating to Meet ADA Title II Digital Accessibility Requirements: What Government Agencies Need to Know
For a long time, digital accessibility sat in an uncomfortable middle ground for many public agencies. It was recognized as important, but often treated as something to address later, after more immediate priorities were handled.
That “later” is arriving.
A recent update to ADA Title II makes web and mobile accessibility a clear, enforceable requirement for state and local governments, with specific technical standards and compliance deadlines starting in 2026. For agencies that publish information online, especially budget books, Annual Comprehensive Financial Reviews (ACFRs), and other financial reports, this represents a meaningful shift in expectations.
Here’s what’s changing, why it matters, and what government teams should be thinking about now.
What Is ADA Title II and What Changed?
The Americans with Disabilities Act (ADA) prohibits discrimination against people with disabilities. ADA Title II applies specifically to state and local governments, requiring that public services, programs, and activities be accessible to everyone, including individuals with disabilities.
Digital accessibility has technically fallen under this umbrella for years. But in practice, guidance was often fragmented, open to interpretation, and enforced primarily through complaints or legal action after the fact.
The ADA Title II Web and Mobile Accessibility Rule changes that dynamic. It clearly defines what accessibility means for digital content and makes those expectations enforceable.
Under the rule, public-facing websites, portals, and mobile applications operated by state and local governments must meet WCAG 2.1 Level AA standards.
Put simply: accessibility is no longer implied or assumed. It’s defined.
Who Is Impacted by ADA Title II Digital Accessibility Requirements?
The rule applies broadly across the public sector, including:
- State and local governments
- Counties, cities, and towns
- Special districts and authorities
- Public schools, colleges, and universities
- Transit agencies and public utilities
Compliance timelines are based on population size:
- Agencies serving 50,000 or more residents: April 24, 2026
- Agencies serving fewer than 50,000 residents and special districts: April 26, 2027
Those dates may feel distant, but accessibility remediation, especially when it involves years of accumulated content, takes longer than many teams expect.
What Does WCAG 2.1 Level AA Actually Mean?
WCAG, or the Web Content Accessibility Guidelines, is an international standard published by the World Wide Web Consortium (W3C). The ADA rule adopts WCAG 2.1 Level AA as the benchmark for digital accessibility compliance.
At a high level, WCAG is built around four core principles. Digital content must be:
- Perceivable
- Operable
- Understandable
- Robust
In practice, that translates to things like:
- Text alternatives for images, charts, and graphics
- Readable font sizes and sufficient color contrast
- Full keyboard navigation for users who can’t use a mouse
- Clear headings, tables, and page structure
- Compatibility with screen readers and other assistive technologies
It’s also worth noting that accessibility isn’t only about visual impairment. These standards support users with mobility limitations, hearing loss, cognitive disabilities, and even temporary impairments.
Why PDFs Are Becoming a Problem for Digital Accessibility
One of the most significant implications of the ADA Title II update is how it affects financial transparency content.
Many agencies still rely heavily on static PDFs to publish budget books, ACFRs, and reports. Unfortunately, PDFs are often:
- Scanned or image-based
- Poorly tagged—or not tagged at all
- Difficult to navigate with assistive technology
- Inaccessible to keyboard-only users
Even a well-designed PDF does not automatically meet accessibility standards simply because it’s posted online.
Under the new rule, agencies need to ensure that the information itself is accessible, not just technically available. That’s driving a growing shift toward web-native, structured digital publishing instead of document uploads.
Accessibility Is a Shared Responsibility Across Teams
Another change agencies are grappling with is organizational, not technical.
ADA Title II compliance isn’t owned by a single team. It spans:
- Finance, which owns the content
- Communications, which shapes how it’s presented
- IT, which manages platforms and infrastructure
- Legal and accessibility teams, which assess risk and compliance
That shared responsibility can be challenging, particularly when accessibility standards are detailed and constantly evolving. In many cases, the biggest risk is a lack of clarity about where responsibility begins and ends.
What About VPATs and Accessibility Documentation?
As agencies evaluate platforms and vendors, accessibility documentation is playing a larger role.
A VPAT (Voluntary Product Accessibility Template) is a standardized format vendors use to document how their products support accessibility standards. When completed, it’s called an Accessibility Conformance Report (ACR).
VPATs aren’t certifications, and they don’t guarantee compliance. What they do provide is transparency, including clear documentation that accessibility has been evaluated thoughtfully and systematically.
Because of that, requesting VPATs during procurement is becoming standard practice, especially for public-facing digital tools.
Why ADA Title II Digital Accessibility Requirements Matter Beyond Compliance
While the ADA Title II update introduces legal deadlines, the broader issue is access.
Budgets, financial reports, and transparency portals are essential public resources. When residents can’t access them because of visual, mobility, or cognitive barriers, trust suffers.
Accessible digital content:
- Expands participation
- Strengthens transparency
- Reduces legal and reputational risk
- Often improves usability for everyone
In many cases, accessibility improvements make information clearer and easier to navigate for all users, not just those with disabilities.
What Agencies Should Do Now to Meet ADA Title II Digital Accessibility Requirements
No agency needs to have everything figured out today. But having a plan matters.
Practical first steps include:
- Auditing public-facing websites and financial content
- Identifying high-risk areas, such as PDF-heavy pages or legacy portals
- Aligning internal teams around shared ownership
- Asking vendors for accessibility documentation
- Exploring web-based alternatives to static publishing
Agencies that start early tend to have more flexibility and less pressure as deadlines approach.
Reducing the Heavy Lift of Digital Accessibility
Preparing for ADA Title II doesn’t mean every agency needs to become an expert in WCAG standards or track every technical update as guidance evolves. This is where modern budgeting and transparency tools can help.
Euna Budget, part of the Euna Solutions® financial suite, offers public-facing transparency solution, OpenBook, designed to take on much of the technical complexity of digital accessibility. That allows government teams to focus on what matters most: sharing clear, accurate financial information with the public.
Rather than relying on static documents or continuously interpreting accessibility requirements internally, agencies can use tools built with accessibility best practices in mind. By staying aligned with evolving standards like WCAG 2.1 and ADA Title II guidance, and by providing accessibility documentation such as Accessibility Conformance Reports (ACRs) in the VPAT® format, Euna helps agencies deliver public financial reporting through tools designed to align with ADA Title II and WCAG accessibility standards, reducing compliance risk while expanding access for all stakeholders.
Accessibility will always remain a shared responsibility. But with the right tools in place, it doesn’t have to be a heavy lift.
Key Takeaways
Clear Standards: ADA Title II digital accessibility requirements now define enforceable standards for web and mobile content.
Broad Applicability: The rule impacts all state and local government entities, including special districts and education agencies.
PDF Limitations: Static PDFs often fail to meet accessibility benchmarks, driving a shift toward web-native publishing.
Shared Responsibility: Compliance requires collaboration across finance, IT, communications, and legal teams.
Documentation Matters: VPATs and Accessibility Conformance Reports (ACRs) are essential in vendor selection and procurement.
Conclusion
To meet ADA Title II digital accessibility requirements, government agencies should proactively audit content, align teams, and leverage accessible technology solutions to ensure public information is usable for everyone.
Frequently Asked Questions?
What are ADA Title II digital accessibility requirements and why are they important?
Euna’s Financial Suite is a purpose-built, cloud-based set of solutions designed exclusively for the public sector. It helps public organizations plan strategically, secure funding, manage spending, streamline procurement, collect revenue, and deliver results transparently – making the most of every public dollar.
Where can I find resources or tools to help with ADA Title II digital accessibility requirements?
Euna is built for public sector organizations of all sizes, including cities, counties, states, school districts, and publicly funded healthcare organizations. Our solutions are designed around real public finance workflows to support finance, budgeting, procurement, grants, and payments teams without adding complexity.
How can agencies begin implementing ADA Title II digital accessibility requirements?
Agencies can start by auditing their websites and digital content, identifying high-risk areas, and requesting VPATs or ACRs from vendors to verify accessibility compliance.
How do ADA Title II digital accessibility requirements compare to other accessibility standards?
ADA Title II digital accessibility requirements specifically reference WCAG 2.1 Level AA as the compliance standard, aligning with international best practices and providing a clear benchmark for public sector organizations.
Want to learn how OpenBook supports ADA Title II accessibility?
Contact Euna to see how our transparency solution helps agencies deliver accessible financial information now and as requirements continue to evolve.