ADA Title II and your website: what schools and governments need to know

Title II of the Americans with Disabilities Act prohibits state and local governments from discriminating against people with disabilities in their programs, services and activities. Courts and the DOJ have treated websites as part of those services for over a decade. What changed in April 2024 is that the DOJ made the requirement explicit and measurable: WCAG 2.1 Level AA, with hard dates (now April 26, 2027 for entities of 50,000+ and April 26, 2028 for smaller entities and special districts).

Who is covered

• Public K-12 school districts
• Cities, towns and villages
• Counties
• Public libraries and library districts
• Special districts (water, transit, fire, parks, hospital districts)
• State agencies, public universities and community colleges

Coverage includes your primary website, subdomains, web applications such as bill pay and enrollment portals, mobile apps, and third-party content that is integral to your services.

What enforcement looks like

OCR complaints. Between 2016 and 2018 a single advocate filed roughly 2,400 complaints against K-12 systems with inaccessible websites; over 1,000 districts signed resolution agreements requiring audits, remediation, policies and years of monitoring.

DOJ settlements. Recent agreements with counties over inaccessible election websites required independent audits, ADA coordinators and staff training.

Private lawsuits. Web accessibility suits exceeded 5,000 federal filings in 2025. The Title II rule gives plaintiffs a defined standard that is easy to prove with automated tools.

What it costs

Resolution	Typical cost
Demand letter settlement	$5,000–$25,000
Out-of-court settlement	$25,000–$100,000+
Court judgment	$75,000+ average
Class action	$1M–$6M+

None of these include remediation, your attorney fees, or the staff time a two-to-three-year monitoring agreement consumes.

Eight steps

1. Run a baseline scan of the full site.
2. Designate an ADA coordinator for digital content.
3. Fix critical issues first: missing alt text on essential images, unlabeled forms, keyboard traps, missing page language.
4. Address color contrast and navigation.
5. Publish an accessibility statement with a way to report barriers.
6. Train content creators.
7. Fix or replace inaccessible PDFs; prefer HTML.
8. Monitor continuously and keep the records.