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Slouching Towards WCAG 2.1

The updated rule to Title II of the Americans with Disabilities Act becomes effective April 24. What then?

3/18/2026 4:06:24 PM

Man on road just past a checkpoint looking ahead. The road forward is lined with unchecked markers.

In the past two years, cities, counties, and states have accelerated their efforts to prepare their organizations for the upcoming Title II rule deadline. (Don't know what I'm talking about? Check out the recap of our article series.) Here's the reality: digital accessibility isn't something you can check off and then put on the shelf. It requires ongoing commitment and full integration into your organization's culture. The work doesn't end on April 24, 2026 — it continues beyond that date.

Accessibility is an ongoing practice

Accessibility has a lot in common with cybersecurity. In both cases, the goal posts continue to move. Technology evolves, presenting new challenges. Organizations succeed when they treat the work as an ongoing practice rather than a one-time project.

For example, security teams:

  • Continuously train employees to watch for phishing.
  • Partner with other organizations to improve security.
  • Carefully evaluate vendors for their ability to support security requirements.

Accessibility teams take a similar approach:

  • Continuously train employees to apply accessibility best practices.
  • Partner with other organizations to improve accessibility.
  • Carefully evaluate vendors for their ability to support accessibility requirements.

Both are full-fledged professions. Employees in both fields can obtain federal and institutional certifications. For accessibility professionals this includes:

Many organizations are rightly focused on meeting the April 24 deadline for digital accessibility compliance. But the work cannot stop there. Accessibility is a professional discipline that must be integrated into every phase of organizational operations.

Vendor dependency

Back in the 90s, I built a website from scratch in a text editor. Nowadays, web developers select a development platform, then may add libraries from other vendors. Application developers, GIS specialists, and other technologists similarly depend on platforms built by others.

Then there are the "as-a-service" services – software as a service, platform as a service, etc. More organizations rely on such services to run their operations, as well as provide services to others.

When the U.S. Department of Justice requires state and local governments to make their public services accessible, that same urgency must extend to vendors. At the State of Minnesota, all IT contracts have included accessibility requirements since 2010.

The Title II rule has helped encourage more public organizations to include similar requirements. Vendor awareness and responsiveness continue to improve.

Content creation

Organizations continue to create content – documents, web pages, social media posts. Employees change roles. New employees come on board. Everyone needs to learn how to apply accessibility to what they do. And, again, vendors need to provide tools to make the content accessible.

The path forward

Over the past 5–10 years, the accessibility profession has grown significantly. More vendors now recognize the need to incorporate accessibility into their products and services.

After April 24, if an organization receives an accessibility complaint, the organization needs to show:

  • Awareness – they have already documented the issues.
  • Accountability – who needs to be involved.
  • Action – there's a plan for improvement.

It's also important to recognize that not all accessibility issues carry the same impact. An automated checking tool might flag a half dozen issues, but just one truly presents a barrier for people with disabilities. Organizations and their vendors need to focus on removing barriers to ensure that individuals with disabilities can:

  • Access the same information.
  • Engage in the same interactions.
  • Conduct the same transactions.
  • Participate in or benefit from the same services, programs, and activities.

(See § 35.205 in the Title II web rule (PDF).)

Organizations are mobilizing for the April 24 deadline. Like security, accessibility does not operate in a vacuum. Organizations must embed it in governance, project management, training, communications, and other core processes. Maturity models offer one tool to help organizations align their efforts. They provide a structured way to ensure teams across the organization work toward the shared goal of enabling people with disabilities to fully access and engage with services — just like everyone else.

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