What is ADA Compliance?
By Moss · 12 min read · March 2026
The Americans with Disabilities Act (ADA) is a civil rights law enacted in 1990 that prohibits discrimination against individuals with disabilities. While originally focused on physical spaces, the ADA has been increasingly applied to digital environments -- websites, mobile applications, and electronic documents.
Who Does the ADA Apply To?
The ADA is organized into five titles, but two are most relevant to digital accessibility:
Title II covers state and local government entities. Every government website, portal, and digital service must be accessible. In 2024, the Department of Justice published a final rule explicitly requiring WCAG 2.1 Level AA conformance for state and local government web content and mobile apps.
Title III covers private businesses that operate "places of public accommodation." Courts have increasingly interpreted this to include websites and mobile apps, especially those connected to physical locations. While there is no single federal regulation specifying a technical standard for Title III, WCAG 2.1 AA is the widely accepted benchmark.
Organizations That Must Comply
- Federal agencies (covered under Section 508)
- State and local governments (ADA Title II)
- Private businesses open to the public (ADA Title III)
- Organizations receiving federal funding
- Educational institutions
- Healthcare providers
What Does "ADA Compliant" Mean for Digital Content?
ADA compliance for digital content generally means your website, app, or document conforms to the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. This standard is organized around four principles, known as POUR:
Perceivable
Content must be presentable in ways users can perceive. This includes:
- Alternative text for images
- Captions and transcripts for audio/video
- Content that can be presented in different ways without losing meaning
- Sufficient color contrast between text and background
Operable
Users must be able to navigate and interact with all functionality:
- All functionality available via keyboard
- Users have enough time to read and use content
- Content does not cause seizures or physical reactions
- Users can navigate, find content, and determine where they are
Understandable
Content and interface operation must be understandable:
- Text is readable and understandable
- Content appears and operates in predictable ways
- Users are helped to avoid and correct mistakes
Robust
Content must be robust enough to work with current and future technologies:
- Content is compatible with assistive technologies
- Proper use of semantic HTML and ARIA attributes
- Valid, well-structured markup
Common ADA Violations
Based on accessibility audits across thousands of websites, the most frequent violations include:
-
Missing alternative text -- Images without
altattributes leave screen reader users unable to understand visual content. -
Insufficient color contrast -- Text that doesn't meet the 4.5:1 contrast ratio (or 3:1 for large text) is difficult for users with low vision.
-
Missing form labels -- Form inputs without associated
<label>elements oraria-labelattributes are inaccessible to assistive technology users. -
Empty links and buttons -- Interactive elements without accessible text provide no context about their purpose.
-
Missing document language -- Pages without a
langattribute on the<html>element prevent screen readers from using the correct pronunciation. -
Inaccessible PDFs -- Untagged PDF documents cannot be read by assistive technologies.
The Legal Landscape
ADA digital accessibility lawsuits have increased dramatically. Here are the federal ADA Title III lawsuit numbers by year:
| Year | Lawsuits Filed | Change |
|---|---|---|
| 2021 | 11,452 | Peak year |
| 2022 | 8,694 | -24% |
| 2023 | 8,227 | -5% |
| 2024 | 8,800 | +7% |
| 2025 | 8,667 | -2% |
Even with a slight decline, 2025 lawsuit volume is still 3x higher than 2013 levels. The top states for filings are California (3,252), Florida (1,823), and New York (1,471).
Key legal developments:
-
DOJ Title II Rule (2024): The Department of Justice published a final rule requiring state and local government web content to conform to WCAG 2.1 AA. Compliance deadlines are phased: April 2026 for entities serving populations of 50,000 or more, and April 2027 for smaller entities.
-
DOJ Enforcement: The DOJ does not require a specific complaint before investigating. Pattern and practice matters -- systemic issues are high priority. Third-party content you host is your responsibility.
-
Title III Litigation: Federal courts have consistently ruled that websites of businesses open to the public must be accessible under Title III. Notable cases include Robles v. Domino's Pizza (2019), where the Ninth Circuit ruled that the ADA applies to websites and mobile apps.
-
State Laws: Several states have enacted their own digital accessibility requirements, including California, New York, and Illinois.
Getting Started with Compliance
Immediate Actions
- Audit your current state: Use automated tools to identify obvious issues, then conduct manual testing with assistive technologies.
- Install accessibility checkers: Enable built-in accessibility checkers in Office applications and browser extensions for web content.
- Train staff who create documents: Content creators are the front line of accessibility.
- Create accessible templates: Start every new document from an accessible template.
- Establish review before publishing: No content goes live without an accessibility check.
For Each Document or Page
- Run the built-in accessibility checker
- Verify heading structure is logical
- Check all images have alt text
- Test that link text makes sense out of context
- Verify table headers are defined
- Check color contrast ratios
- Test with a screen reader when possible
Organizational
- Assign an accessibility coordinator -- Someone must own this
- Document your accessibility policy -- Put it in writing
- Create a remediation process for existing content
- Publish an accessibility statement on your website
- Provide a method for users to report issues -- and respond to them
Related Laws: Quick Reference
| Law | Scope | Standard |
|---|---|---|
| Section 508 | Federal agencies and ICT | WCAG 2.0 AA |
| Section 255 | Telecommunications equipment | Accessibility standards |
| ADA Title II | State/local government | WCAG 2.1 AA (by 2026/2027) |
| ADA Title III | Private businesses/public accommodation | WCAG 2.1 AA (de facto) |
| 21st Century IDEA | Executive agency websites | Modern, accessible design |
The bottom line: WCAG 2.1 Level AA is the standard. Use built-in accessibility checkers. Train your people. Prioritize HTML over PDFs when possible. Document your efforts -- good faith remediation matters in enforcement.
Next Steps
Ready to dive deeper? Continue with these courses:
- WCAG 2.1 AA Explained -- A practical breakdown of each success criterion
- ADA Title II Deadlines -- Key compliance dates for government entities
- Making PDFs Accessible -- How to create and remediate accessible documents