What are the ADA requirements for websites?

There is no single statute that lists ADA website requirements. Instead, courts and the DOJ apply WCAG 2.1 Level AA as the operative technical standard. WCAG 2.1 AA contains 50 success criteria — 30 at Level A and 20 at Level AA — organized under four principles: Perceivable, Operable, Understandable, and Robust (POUR). For ADA Title II (state and local government), the DOJ's 2024 rule codifies WCAG 2.1 AA as the required standard.

Is WCAG 2.1 AA legally required?

For state and local government websites under ADA Title II, yes — the DOJ's 2024 rule (89 Fed. Reg. 31320, with compliance dates extended one year by the April 2026 IFR at 91 Fed. Reg. 20902) requires WCAG 2.1 Level AA. For private businesses under Title III, there is no formal regulatory technical standard, but federal courts consistently apply WCAG 2.1 AA as the de facto benchmark. Section 508 still references WCAG 2.0 AA.

How many WCAG criteria are in Level AA?

WCAG 2.1 contains 78 success criteria total: 30 at Level A, 20 at Level AA, and 28 at Level AAA. To claim Level AA conformance you must meet the 50 criteria at Level A and Level AA. WCAG 2.2 (October 2023) adds 9 more criteria — 6 at Level A, 2 at Level AA, and 1 at Level AAA.

Which industries are most often sued for website ADA violations?

In 2025 EcomBack data: e-commerce/retail (~69%), food & beverage (~21%), entertainment (~2.5%), travel & hospitality (~1.8%), and banking/finance (~1.5%). E-commerce dominates because plaintiff firms can easily find barriers in checkout flows, product pages, and search.

What are the most common accessibility failures?

Per the WebAIM Million 2026 report, six failure types account for 96% of detected errors — for the seventh consecutive year. In order: low contrast text (83.9% of home pages), missing alternative text (53.1%), missing form input labels (51%), empty links (46.3%), empty buttons (30.6%), and missing document language (13.5%).

ADA Website Requirements

ADA website requirements are the technical accessibility criteria a website must meet to satisfy the Americans with Disabilities Act. Courts and the U.S. Department of Justice apply WCAG 2.1 Level AA— 50 success criteria across four principles (Perceivable, Operable, Understandable, Robust) — as the operative standard, codified for state and local government websites under the DOJ's 2024 Title II rule.

Who has to meet these requirements?

Private businessesthat are “places of public accommodation” under ADA Title III — most B2C websites. Courts apply WCAG 2.1 AA; Robles v. Domino's Pizza (9th Cir. 2019) is the controlling precedent in the 9th Circuit and persuasive elsewhere.
State and local government entities under ADA Title II. Deadlines extended to April 26, 2027 (50,000+ population) and April 26, 2028 (smaller entities and special districts) by the April 2026 DOJ Interim Final Rule (91 Fed. Reg. 20902).
Federal agencies + contractors + funding recipients under Section 508 of the Rehabilitation Act — currently WCAG 2.0 AA.
HHS funding recipients under Section 504 — WCAG 2.1 AA by May 11, 2026 (15+ employees) or May 10, 2027 (under 15). HHS did not match the DOJ Title II extension.
Any business serving EU customers — European Accessibility Act (Directive 2019/882) is effective and enforcement-active since June 28, 2025.

How the technical standard differs by law

“ADA compliant” means a different technical standard, deadline, and enforcement path depending on which federal law actually applies to your organization.

Law	Who it covers	Technical standard	Deadline	Enforcement
Title II	State & local government (any size)	WCAG 2.1 AA	Apr 26, 2027 (50k+ pop.) / Apr 26, 2028 (smaller + special districts)	U.S. DOJ
Title III	Private businesses that are “places of public accommodation” (no size minimum)	No formal DOJ standard — courts + DOJ apply WCAG 2.1 AA	No formal regulatory deadline	DOJ + private plaintiffs
Section 508	Federal agencies, contractors, and ICT vendors	WCAG 2.0 AA	Refreshed standard in effect since Jan 18, 2018	GSA + individual agencies + DOJ (biennial reporting)
Section 504 (HHS rule)	Recipients of HHS funding (hospitals, clinics, HHS-funded schools)	WCAG 2.1 AA	May 11, 2026 (15+ employees) / May 10, 2027 (under 15) — not extended	HHS Office for Civil Rights

Notice that Section 508 still runs on WCAG 2.0 AA— one full version behind the 2.1 AA standard that governs Title II and the HHS Section 504 rule. There is ongoing discussion about refreshing Section 508 to match, but as of today it hasn't happened.

Private businesses have the least formal certainty: Robles v. Domino's Pizza(9th Cir. 2019) held that Title III's “full and equal enjoyment” requirement extends to websites and apps with a nexus to a physical location, while the 11th Circuit reached the opposite conclusion in Gil v. Winn-Dixie(2021) — a circuit split that means your exposure can depend on where you're sued. See the full Title III circuit-split breakdown.

The standard: WCAG 2.1 Level AA in plain English

WCAG 2.1 Level AA contains 50 success criteria (30 Level A + 20 Level AA), published by the W3C Web Accessibility Initiative in June 2018. The criteria are organized into four principles known as POUR.

PPerceivable

Information and UI must be presentable to users in ways they can perceive — alt text, captions, contrast, adaptable layout.

OOperable

UI components must be operable — keyboard accessibility, enough time, no seizure triggers, navigable.

UUnderstandable

Information and UI must be understandable — readable, predictable, input assistance.

RRobust

Content must be robust enough to be interpreted by current and future user agents, including assistive tech.

See all 50 success criteria, grouped by POUR

POUR in practice: what each principle actually catches

The one-line blurbs above are the theory. Here is what failing each principle looks like on a real page, per the WebAIM Million 2026 report's scan of the top 1,000,000 home pages.

Perceivable

Low contrast text(WCAG 1.4.3) — 83.9% of home pages fail this. The text is technically visible, but users with low vision, color blindness, or anyone reading a phone screen in sunlight can't make it out.
Missing alternative text(WCAG 1.1.1) — 53.1% of home pages fail this. A screen reader announces “image” or a filename instead of what the image communicates — on a product photo, that's the difference between “image” and “red leather ankle boot, size 8.”

Operable

Empty links(WCAG 2.4.4) — 46.3% of home pages fail this. A screen reader announces “link” with no indication of where it goes.
Keyboard traps in custom widgets — dropdown menus, modals, and carousels built to respond only to mouse clicks (no keyboard event handling) leave keyboard-only users able to tab onto the control but unable to activate or escape it. Automated scanners are weak on this layer, which is exactly why it slips through.

Understandable

Missing document language(WCAG 3.1.1) — 13.5% of home pages fail this. Without a declared language, screen readers guess at pronunciation rules and can make content sound like it's being read in the wrong language's cadence.
Missing form input labels(WCAG 1.3.1, 3.3.2, 4.1.2 combined) — 51% of home pages fail this. A sighted user sees hint text like “Email” fade away on click; a screen reader user gets no indication of what the field expects, and any validation error isn't tied back to the field that caused it.

Robust

Empty buttons(WCAG 4.1.2) — 30.6% of home pages fail this. Assistive technology has no accessible name to announce, so a screen reader user hears “button” with no clue what pressing it will do.
Non-semantic custom controls — interactive elements built from generic div or span tags with a JavaScript click handler, instead of a native button or a, and without the ARIA role and state to compensate. Assistive technology (and future browsers) can't reliably interpret what the control is or does.

Source: WebAIM Million 2026 (top 1,000,000 home pages scanned) — see the full 50-criterion breakdown for every other way each principle can fail.

WebAIM Million 2026 — Released March 2026

The Big Six: 96% of all accessibility errors

Six failure types account for 96% of all detected accessibility errors — for the seventh consecutive year. Fixing these in priority order will eliminate the vast majority of ADA exposure for most websites.

#1. Low contrast text
83.9% of pages
Text or images of text that do not meet a 4.5:1 contrast ratio against their background (or 3:1 for large text 18pt regular / 14pt bold).
WCAG: 1.4.3 Contrast (Minimum) (Level AA)
#2. Missing alternative text
53.1% of pages
Images without an alt attribute, or with alt text that does not convey the image's purpose. Decorative images need empty alt="".
WCAG: 1.1.1 Non-text Content (Level A)
#3. Missing form input labels
51% of pages
Form inputs without a programmatically associated <label>, or relying on placeholder text as a substitute for a label.
WCAG: 1.3.1 Info and Relationships · 3.3.2 Labels or Instructions · 4.1.2 Name, Role, Value (Level A)
#4. Empty links
46.3% of pages
Anchor elements with no accessible text — often icon-only links missing aria-label, or anchors whose only content is an image without alt.
WCAG: 2.4.4 Link Purpose (In Context) (Level A)
#5. Empty buttons
30.6% of pages
Button elements with no accessible name — often icon buttons missing aria-label.
WCAG: 4.1.2 Name, Role, Value (Level A)
#6. Missing document language
13.5% of pages
The <html> tag is missing a lang attribute. Screen readers need this to choose the correct pronunciation engine.
WCAG: 3.1.1 Language of Page (Level A)

Source: WebAIM Million 2026 (released late March 2026)

Industry-specific exposure: where requirements bite hardest

Every covered website needs WCAG 2.1 AA conformance, but litigation risk is not evenly distributed. In 2025, e-commerce and food & beverage accounted for 90% of digital accessibility lawsuits (EcomBack 2025).

See industry-by-industry requirements + exposure

The 50-item requirements checklist

We've flattened WCAG 2.1 AA into a 50-item, plain-English checklist a developer or content owner can run against any site.

Open the 50-item ADA requirements checklist

Run a free ADA compliance checker — an automated WCAG 2.1 AA scan against the WebAIM Big Six failure types.
How to make your website ADA compliant — the step-by-step remediation guide once you know what needs fixing.
Compliance deadlines by organization type — Title II, HHS Section 504, and EAA dates in one table.
Who is exempt from ADA website rules — the real, narrow exemptions, not the myths.

How to actually test for these requirements

Automated scanners can catch several of the failures above in seconds — contrast ratios, missing alt attributes, empty buttons and links, and missing document language are all machine-detectable. But automated tools alone catch an estimated 30-40% of WCAG 2.1 AA failures. They cannot tell you whether your custom dropdown works with a keyboard, whether an error message actually gets announced to a screen reader, or whether someone using a screen reader can complete checkout at all.

A real audit runs three layers: automated scanning as a baseline, manual structural review (heading hierarchy, landmark regions, form semantics, ARIA usage), and assistive-technology testing (screen readers, keyboard-only navigation, zoom/reflow at 200%). Each layer catches things the others miss.

Run the free automated compliance checker — get a baseline read on where your site stands on layer one before paying for anything.
Read the full ADA audit process breakdown — what a proper three-layer audit costs, how long it takes, and what a real deliverable looks like (criterion IDs, severity, location, recommended fix — not a PDF of scanner output).

Frequently asked questions

What are the ADA requirements for websites?: There is no single statute that lists ADA website requirements. Instead, courts and the DOJ apply WCAG 2.1 Level AA as the operative technical standard. WCAG 2.1 AA contains 50 success criteria — 30 at Level A and 20 at Level AA — organized under four principles: Perceivable, Operable, Understandable, and Robust (POUR). For ADA Title II (state and local government), the DOJ's 2024 rule codifies WCAG 2.1 AA as the required standard.
Is WCAG 2.1 AA legally required?: For state and local government websites under ADA Title II, yes — the DOJ's 2024 rule (89 Fed. Reg. 31320, with compliance dates extended one year by the April 2026 IFR at 91 Fed. Reg. 20902) requires WCAG 2.1 Level AA. For private businesses under Title III, there is no formal regulatory technical standard, but federal courts consistently apply WCAG 2.1 AA as the de facto benchmark. Section 508 still references WCAG 2.0 AA.
How many WCAG criteria are in Level AA?: WCAG 2.1 contains 78 success criteria total: 30 at Level A, 20 at Level AA, and 28 at Level AAA. To claim Level AA conformance you must meet the 50 criteria at Level A and Level AA. WCAG 2.2 (October 2023) adds 9 more criteria — 6 at Level A, 2 at Level AA, and 1 at Level AAA.
Which industries are most often sued for website ADA violations?: In 2025 EcomBack data: e-commerce/retail (~69%), food & beverage (~21%), entertainment (~2.5%), travel & hospitality (~1.8%), and banking/finance (~1.5%). E-commerce dominates because plaintiff firms can easily find barriers in checkout flows, product pages, and search.
What are the most common accessibility failures?: Per the WebAIM Million 2026 report, six failure types account for 96% of detected errors — for the seventh consecutive year. In order: low contrast text (83.9% of home pages), missing alternative text (53.1%), missing form input labels (51%), empty links (46.3%), empty buttons (30.6%), and missing document language (13.5%).