April 24 marked a material shift in US digital compliance obligations.

State and local government bodies serving populations of 50,000 or more are now required to meet updated accessibility standards under Title II of the Americans with Disabilities Act (ADA).

The rule, finalised by the US Department of Justice in 2024, formally extends Title II obligations to websites, mobile applications, digital documents, and online services. From April 24, compliance is no longer advisory. It is enforceable.

What has changed

Title II already required public entities to ensure equal access to services. The change clarifies that digital services are explicitly in scope and sets a defined technical benchmark.

Public entities must now ensure that digital content conforms to WCAG 2.1 Level AA, covering usability for people using assistive technologies across sight, hearing, motor, and cognitive needs.

This applies to:

•    Public websites and mobile apps
•    PDFs and downloadable documents
•    Embedded video and audio
•    Third-party platforms and tools used to deliver public services

Smaller jurisdictions serving fewer than 50,000 people have until April 26, 2027 to comply. For larger entities, the obligation is now active.

Why this matters now

Accessibility enforcement has moved from principle to practice. Regulators and courts no longer accept uncertainty or partial progress as a defence. 

Public bodies are expected to demonstrate:

•    Awareness of obligations
•    Evidence of assessment
•    A structured plan showing what is achieved, what is underway, and what may be classed as disproportionate burden

Failure to do so increases exposure to complaints, investigations, and litigation.
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Our answer: a practical compliance pathway

The response does not start with remediation. It starts with clarity, evidence, and control.

Step 1. Ensure you have an independent audit. Do this first. Do it independently.

This must not be conducted by your web services supplier or incumbent vendor.

You can do this free now at www.AAAnow.ai.
The objective is simple. Understand which of the compliance fundamentals you have addressed and which remain unresolved.

Without this, every other step is speculative.
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Step 2. Share an internal compliance note

Ensure all staff are aware that Title II applies to digital services. This includes communications, IT, procurement, and leadership.
Consistency matters. Compliance fails most often through fragmentation.
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Step 3. Conduct a formal risk assessment

This must be independent of delivery teams and suppliers.

The assessment should identify:

•    Areas of confirmed compliance
•    Known gaps
•    Areas creating unnecessary risk
•    Dependencies on third parties

This forms the evidence base for decisions that follow.
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Step 4. File an ADA SOP (Standard Operating Procedure)

Document your position clearly:

•    What has been achieved
•    What is actively being worked towards
•    What may reasonably be classed as disproportionate burden

This is critical in demonstrating intent, governance, and proportionality.
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Step 5. Apply secure tagging and automated controls

Use AI and automation to remove a material percentage of exposure and barriers across live content.
This does not replace remediation. It reduces immediate risk while longer-term work proceeds.
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Step 6. Issue formal notices to suppliers

Under multiple US laws, vendors and service providers have their own compliance obligations.

Suppliers should be:

•    Put on notice
•    Made aware of their responsibilities
•    Informed of potential liabilities

Silence here transfers risk back to the public body.
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Step 7. Review insurance and litigation coverage

Engage your broker to confirm:

•    Coverage related to accessibility litigation
•    Claims handling capability
•    Access to litigation support platforms

This is a risk management step, not an admission of failure.
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A shift from intention to evidence

Title II enforcement is no longer theoretical. Public entities are expected to show that they understand their position, are acting proportionately, and are managing risk in a structured way.

Independent assessment is the foundation. Everything else builds on it.
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Sources and further reading

•    US Department of Justice. Final Rule on Accessibility of Web Content and Mobile Apps Provided by State and Local Governments
https://www.ada.gov/resources/2024-03-08-web-rule/
•    US Department of Justice. Web Rule First Steps
https://www.ada.gov/resources/web-rule-first-steps/
•    3Play Media. ADA Title II Website Accessibility Requirements
https://www.3playmedia.com/blog/ada-title-ii-for-public-entities/
•    University of California, Berkeley. ADA Title II Updates Explained
https://dap.berkeley.edu/ada-title-ii-updates/title-ii-ada-what-does-it-mean-us