ADA Web Accessibility
Compliance
Everything water districts, landscaping companies, and public entities need to know — who must comply, what the spec requires, when the deadlines hit, and what happens if you don't.
Section 01
Who
Section 02
What
The Standard: WCAG 2.2 Level AA — Four Principles (POUR)
WCAG 2.2 Level AA — Section by Section
55 success criteria across 13 guidelines, plus Section 5 conformance requirements. WCAG 2.2 (Oct 2023) adds 6 new A/AA criteria and retires 4.1.1 Parsing. Each section below is collapsed — expand to see criteria, common failures, and live examples.
Principle 1: Perceivable
Information must be presentable in ways users can perceive — 20 criteria
1.1Text Alternatives
Provide text alternatives for any non-text content so it can be changed into other forms people need.
All images, icons, SVGs, and non-text elements need text alternatives.
Common failures:
- Images missing
altattributes entirely - Decorative images not marked with
alt="" - Icon buttons (hamburger, close, search) with no accessible name
<img src="drip-emitter.jpg"><img src="drip-emitter.jpg"
alt="A drip emitter watering
a rose bush">Screen reader announces:
"drip-emitter.jpg, image"
Screen reader announces:
"A drip emitter watering a rose bush, image"
1.2Time-based Media
Provide alternatives for time-based media — captions, transcripts, and audio descriptions.
Common failures:
- Videos with no captions or auto-generated captions never reviewed
- Live-streamed board meetings with no real-time captioning
- Podcast episodes with no transcript
1.3Adaptable
Create content that can be presented in different ways without losing information or structure.
Common failures:
- Styled divs used instead of proper heading tags
- Form inputs without associated label elements
- Required fields indicated only by color with no programmatic indication
1.4Distinguishable
Make it easier for users to see and hear content — contrast, resize, spacing, and visual presentation.
Common failures:
- Light gray text on white backgrounds — the single most common WCAG failure
- Fixed-height containers that clip text at 200% zoom
- Form input borders that blend into the background
<p style="color: #a8c8e8;
background: #ffffff;">
Light blue on white (2.1:1)
</p><p style="color: #2d5f8a;
background: #ffffff;">
Dark blue on white (6.8:1)
</p>Light blue on white (2.1:1)
Contrast ratio: 2.1:1 — FAIL
Dark blue on white (6.8:1)
Contrast ratio: 6.8:1 — PASS
Principle 2: Operable
UI components and navigation must be operable by all users — 20 criteria
2.1Keyboard Accessible
Make all functionality available from a keyboard — no mouse required.
Common failures:
- Custom dropdowns, sliders, and carousels that only respond to mouse clicks
- Modal dialogs that trap focus without cycling back to the beginning
- onClick handlers on divs without keyboard event handlers or tabindex
2.2Enough Time
2.3Seizures & Physical Reactions
No content flashes more than 3 times per second.
2.4Navigable
Help users navigate, find content, and determine where they are.
Common failures:
- No "skip to main content" link
- CSS
outline: noneapplied globally with no replacement focus style - Links that say only "Click here" or "Read more" with no context
<a href="/tips">Click here</a><a href="/tips">View water
conservation tips</a>For water conservation tips, Click here.
Link list shows: "Click here" — meaningless without surrounding text
View water conservation tips
Link list shows: "View water conservation tips" — self-describing
2.5Input Modalities
Support various input methods beyond keyboard — touch, pointer, voice, motion.
Principle 3: Understandable
Information and UI operation must be understandable — 13 criteria
3.1Readable
3.2Predictable
Pages appear and operate in predictable ways — consistent navigation and identification.
3.3Input Assistance
Help users avoid and correct mistakes — labels, error messages, and confirmation steps.
Common failures:
- Form fields with only placeholder text and no visible label
- Validation errors shown only by turning the field border red
- Login forms that block password managers or prevent pasting
<input type="email"
placeholder="Email"><label for="email">Email</label>
<input type="email" id="email"
placeholder="you@example.com">No programmatic label — screen reader says "edit text, blank"
Screen reader says "Email, edit text"
Principle 4: Robust
Content must work reliably with assistive technologies — 2 criteria
4.1Compatible
Maximize compatibility with current and future user agents, including assistive technologies.
4.1.1 Parsing — retired in WCAG 2.2. Originally required well-formed markup, but modern browsers and assistive technologies handle parsing errors gracefully. This criterion is always met in current HTML.
Common failures:
- Custom components (tabs, accordions, modals) built with divs and no ARIA roles
- Toggle buttons missing
aria-pressedstate - Toast notifications that appear without
role="status"
Section 5: Conformance
Rules that define what it means to "conform" to WCAG — 5 requirements
5.2Conformance Requirements
These are not testable success criteria — they define the rules for claiming conformance. Failing any one means the page does not conform.
Key implications:
- No partial credit — one failure on a page means the page does not conform
- Process-wide — a conforming homepage means nothing if the bill-pay flow is broken
- Third-party content — embedded widgets, iframes, and ads count unless you claim partial conformance under 5.4
- Non-interference — a broken overlay or auto-playing video can invalidate an otherwise conforming page
5.3–5.5Claims & Partial Conformance
Practical notes:
- Conformance claims are optional — courts care about actual accessibility, not self-declarations
- The third-party exception is narrow — if you chose to embed it, you're responsible for vetting it
- Publishing an accessibility statement (even without a formal claim) is a strong good-faith signal
Section 03
When
| Entity | Deadline |
|---|---|
| Large state/local govt (50K+ pop) | April 24, 2026 |
| Small state/local govt (under 50K) | April 26, 2027 |
| Special districts (water, sewer, etc.) — any size | April 26, 2027 |
| Private businesses (Title III) | No deadline — lawsuits are happening now |
Section 04
Where
Section 05
Why
First violation penalty (Title II)
Up to $230,464 for subsequent violations. California Unruh: $4,000 per violation per visit.
The Carrot
- • 26% of U.S. adults (44.1M people) have some form of disability
- • Accessible sites get better SEO — proper headings, alt text, semantic HTML
- • Curb-cut effect — captions in noisy rooms, high contrast in sunlight, keyboard nav for power users
Overlay Tools
accessiBe, UserWay, AudioEye — these are a liability, not a solution.
FTC fine against accessiBe (Jan 2025) for deceptive claims that its AI product could make websites ADA compliant
companies using overlays were sued in 2024 — that's 25% of all ADA web lawsuits
- 600+ accessibility professionals signed an open letter opposing overlays
- National Federation of the Blind formally opposes all overlays
- Overlays cosmetically patch surface issues while leaving structural violations untouched
- Some overlays break assistive technology that was previously working
- Courts have consistently rejected "we installed an overlay" as a defense
“If a vendor pitches you an overlay as an ADA solution, run.”
Section 07
Tools
No single tool catches everything. Layer automated + AI + manual testing.
WAVE
Browser Extension
Color-coded overlays showing errors, alerts, and features directly on the page. Data stays in browser.
Section 08
Scoring
How Courts Evaluate Compliance
| Factor | Weight |
|---|---|
| Number and severity of violations | High |
| Whether core services are blocked | Very high |
| Documented accessibility program | Significant mitigator |
| Remediation timeline and progress | Significant mitigator |
| Responsiveness to complaints | Matters |
| Pattern vs. isolated violations | Matters |
Good Faith — Not a Defense, But It Shapes Outcomes
The DOJ has explicitly said good faith will not excuse noncompliance. However, entities with documented programs get case dismissals, reduced settlements, and shorter timelines. Think of it like OSHA — a safety program doesn't prevent a violation, but it determines whether you get a warning or a six-figure fine.
- 1Adopt a formal accessibility policy
- 2Conduct regular audits (at least annually)
- 3Create a remediation plan with deadlines
- 4Train staff who create web content
- 5Publish an accessibility statement
- 6Respond promptly to accommodation requests
- 7Budget for accessibility as recurring line item
- 8Document everything
See it in action
We built a fake water district website with 13 intentional WCAG violations. Try finding and fixing them with a live code editor.
SimplyScapes Labs · AWE Education & Outreach · March 17, 2026