The DOJ Title II Rule: Web and Mobile Accessibility
In April 2024, the U.S. Department of Justice (DOJ) announced a final rule under Title II of the Americans with Disabilities Act (ADA). This rule sets clear, technical accessibility standards for state and local government entities, including school districts, public universities, municipal boards, and regional utilities.
Under the mandate, all public entities must ensure their websites and mobile applications conform to the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA standards.
Key Focus Areas for Compliance
Meeting WCAG 2.1 Level AA requirements involves addressing several core aspects of web development:
- Keyboard Compatibility: All interactive elements (menus, links, buttons, and forms) must be fully usable without a mouse, using standard keyboard keys. Focus indicators must be clearly visible.
- Text Contrast: Text must stand out clearly against its background, with a minimum contrast ratio of 4.5:1 for normal text and 3:1 for large text.
- Form Labels: Form inputs must have descriptive labels associated in the code, ensuring screen readers can announce what information is requested.
- Document Accessibility: All hosted files, including PDFs and documents, must be accessible and readable by assistive technologies.
Avoiding the Accessibility Overlay Trap
Many organizations try to meet these rules by using “accessibility overlays” (JavaScript widgets that let users change settings). However, these tools do not make a website compliant and can actually interfere with native screen reader software, increasing legal liability.
True accessibility must be built directly into the site’s code and design structure.