10 ADA Title II Website Compliance Mistakes Local Governments Make (and How to Avoid Them)

ADA Title II compliance deadlines are ahead — April 26, 2027, for large public entities and April 26, 2028, for smaller entities and special district governments. The Department of Justice extended both dates by one year in April 2026, but the underlying obligation has not changed.

Public entities must still make their websites, mobile apps, and other digital services accessible to people with disabilities under WCAG 2.1 Level AA. Title II at its core says public entities must already be accessible — the 2024 rule added a specific standard and timeline, and the extension moved the timeline, not the duty. For the legal perspective on what the extension changes (and doesn't), see Seyfarth Shaw's analysis of the DOJ Interim Final Rule.

Even with precise requirements, many public entities fall into the same traps, slowing progress or missing compliance altogether.

In this article, I'll outline 10 common ADA Title II website compliance mistakes, explain why they happen, and give you concrete steps to avoid them.

1. Waiting Too Long to Start ADA Title II Remediation

Large projects can take months, not weeks, once remediation starts, especially with legacy systems and third-party integrations.

Some agencies plan to "start next year." Even with the extension to April 2027, large entities now have roughly 12 months to complete an accessibility audit, fix barriers, test, and confirm compliance. Remediation alone can take 12–18 months when you're dealing with hundreds of pages, legacy CMS platforms, untagged PDFs, or multiple vendor-managed systems — which means the math doesn't work if you delay. 

How to avoid it:

1. Begin immediately with a WCAG 2.1 AA audit of your highest-traffic, highest-risk content.
2. Build a phased remediation roadmap, starting with critical services like tax payments, permits, or emergency alerts.
3. Secure budget and staffing now — demand for accessibility specialists tightened in 2025 and will tighten again as the 2027 deadline approaches. 

2. Relying on Widgets Instead of Full WCAG Conformance

Overlays and accessibility widgets are often marketed as "quick fixes." In reality, they're not enough for ADA Title II compliance. DOJ requires actual WCAG 2.1 AA conformance, which means fixing underlying code and content issues. Automated tools cannot catch or correct many core accessibility barriers.

How to avoid it:

1. Treat overlays as supplemental tools, not substitutes for remediation.
2. Pair automated checks with manual testing using assistive technology.
3. Confirm vendor-provided widgets meet WCAG criteria and don't interfere with screen readers or keyboard navigation.

For CIOs, Read: Achieving ADA Title II Compliance: A 10-Step Guide 

3. Treating the Accessibility Audit as the Finish Line

An audit is just the starting point. Without a clear post-audit roadmap, agencies stall for months and lose valuable time.

For some agencies, six months may pass between the audit and the first remediation task, leaving the site noncompliant and the deadline looming. The audit identifies the barriers; it doesn't fix them.

How to avoid it:

1. Schedule remediation work to start immediately after the audit is delivered.
2. Assign ownership for each fix to internal teams or vendors.
3. Require your vendor to provide a post-audit action plan with milestones and completion dates.

4. Overlooking Mobile Accessibility Requirements

ADA Title II covers mobile apps as well as websites. WCAG 2.1 adds mobile-specific criteria for touch targets, gestures, and device orientation. Ignoring mobile risks means missing compliance — especially since many residents access local government websites via smartphones.

How to avoid it:

1. Include mobile app audits alongside website testing.
2. Test on multiple devices and operating systems using real assistive technologies.
3. Ensure responsive design maintains accessibility across viewports.

Free Download:  ADA Title II Web and Mobile App Compliance

5. Ignoring Accessibility in Digital Documents

Digital documents like PDFs are covered if they're used to access public services or information. The DOJ rule allows limited exceptions (e.g., certain archived or third-party content), but most active forms and publications must be accessible.

How to avoid it:

1. Audit all downloadable documents, prioritizing forms, meeting agendas, and reports.
2. Train staff to create accessible PDFs or publish in HTML.
3. Replace legacy PDFs with accessible formats during remediation.

6. Not Holding Vendors Accountable for Accessibility

Agencies remain responsible even when a vendor builds or hosts the site. Without accessibility clauses in contracts, recurring issues will resurface.

Third-party vendors often manage public-facing tools — payment portals, mapping services, scheduling systems — that can create significant accessibility gaps. Vendors may meet WCAG standards at launch but fail to maintain them during updates.

How to avoid it:

1. Add WCAG 2.1 AA conformance clauses to all procurement contracts.
2. Require accessibility testing and documentation before accepting deliverables.
3. Include maintenance provisions to ensure ongoing compliance after launch.

7. Skipping Assistive Technology and Manual Accessibility Testing

Automated scans are not enough. Manual testing with real assistive technologies, screen readers, magnifiers, and voice control finds issues automation can't, like reading order problems or mislabeled form fields.

How to avoid it:

1. Include Assistive technology testing in every audit and re-audit.
2. Involve users with disabilities for authentic feedback.
3. Document all assistive technology test results to show due diligence. 

Read: ADA Title II Compliance: Frequently Asked Questions

8. Neglecting Continuous Accessibility Compliance Monitoring

You may achieve compliance at launch, but it can be lost within a year because new content or features may not have been tested for accessibility.

Compliance is not "set it and forget it." New content, CMS updates, or vendor changes can introduce fresh barriers within weeks.

How to avoid it:

1. Schedule quarterly manual reviews and monthly automated scans.
2. Set up a public feedback form on your accessibility statement.
3. Require vendors to run accessibility checks before pushing updates. 

9. Underestimating Accessibility Training for Staff

Without training, recurring "user input errors" like inaccessible PDFs or missing alt text can undo months of remediation.

Training content authors to create accessible PDFs, add alt text, and follow proper formatting prevents the same mistakes from being fixed repeatedly.

How to avoid it:

1. Provide annual accessibility training for all content editors, developers, and procurement officers.
2. Integrate accessibility requirements into onboarding materials.
3. Give staff access to checklists and quick-reference guides.

10. Not Publishing a Public Accessibility Statement

An accessibility statement is both a legal safeguard and a signal to residents that your agency values inclusion.

How to avoid it:

1. Publish a clear accessibility statement with WCAG standard references.
2. Include contact information for accessibility feedback.
3. Update the statement annually to reflect progress.

For insights on an accessibility policy versus a statement, read this blog Accessibility Policy: Why It Matters and What to Include

Embedding Accessibility in Government Website Operations

Sustainable accessibility requires embedding practices into everyday workflows, not just "fixing" a site once. For ADA Title II compliance, you must make accessibility a part of your culture. With roughly 12 months until the April 2027 deadline for large entities and 24 months until April 2028 for smaller ones, the work that matters most starts now. 

If you missed it, read Title II Compliance Timeline: Key Dates And Deadlines

By starting early, engaging vendors, training staff, and committing to ongoing monitoring, you can meet compliance deadlines, reduce legal risk, and ensure your services work for every resident.