Author: Jennie Delisi, Enterprise IT Governance Coordinator

Re‑Introduction

Cognitive accessibility plays an essential role in ensuring people with cognitive disabilities can equitably access digital government services. Clear, structured, and predictable digital experiences help people understand information, stay focused, and complete important tasks.

This supports everyday online activities such as:

• applying for benefits,
• renewing a license,
• scheduling an appointment, or
• navigating time-sensitive instructions.

As Minnesota updates its digital practices and prepares for the new ADA Title II requirements taking effect in 2027 (see "Update" at end of article), cognitive accessibility is moving beyond a best practice to a compliance expectation. Agencies that design digital spaces for clarity, predictability, and reduced cognitive load make their services easier for everyone while directly supporting Minnesotans who rely on these improvements.

This article

• highlights the core ideas introduced in a 2019 newsletter article.
• provides a practical, updated roadmap for cognitive-friendly digital services.
• shares resources for taking next steps.

Its purpose is to give actionable guidance and real-world examples that strengthen cognitive accessibility while helping meet emerging federal and state requirements.

These include:

• Minnesota Digital Accessibility Standard v4.0,
• Web Content Accessibility Guidelines (WCAG) 2.1 AA
• Cognitive and Learning Disabilities Accessibility Task Force (COGA) recommendations and best practices.

These principles and practices broadly apply across sectors and regions, supporting any organization seeking to improve clarity and independent use of digital information.

Updates Since 2019

Since the original 2019 article Closing the Accessibility Gap (Sims and Delisi), three major changes have reshaped cognitive accessibility.

ADA Title II

First, the American's with Disabilities Act (ADA) Title II Final Rule (PDF) now requires public entities to meet WCAG 2.1 AA, with compliance beginning in April 2027. This establishes a clear, enforceable accessibility baseline for digital services. WCAG 2.1 AA includes requirements such as text spacing, non-text contrast, and motion actuation. These improve access for people with certain cognitive and learning disabilities.

State of Minnesota's Digital Accessibility Standard, v4.0

Second, Minnesota's updated Digital Accessibility Standard v4.0 now fully aligns with WCAG 2.1 AA and places stronger emphasis on clarity, predictability, and content. This strengthens the overall ease of use by reducing cognitive load, making instructions and expectations more immediately understandable, and supports efficient decision-making throughout a task.

2025 Editor's Draft of Making Content Usable for People with Cognitive and Learning Disabilities

Third, updated guidance from the W3C's Cognitive and Learning Disabilities Task Force—through the 2025 Editor's Draft (Making Content Usable for People with Cognitive and Learning Disabilities)—identifies patterns that are critical enablers for helping users:

• stay oriented (know where they are within a site),
• avoid mistakes, and
• complete multi‑step processes successfully.

Impact of these changes

Together, these changes signal a shift where cognitive accessibility is no longer optional or aspirational but a core requirement for accessible digital spaces. With these updates shaping how we design digital spaces, many teams are already improving clarity and consistency across their content. At the same time, familiar challenges continue to appear across digital spaces, and most have simple, high-impact fixes.

Common Gaps and Fixes that Make a Big Difference

As teams continue improving accessibility across digital spaces, common trouble spots still show up again and again. Before we get into those, here's a quick refresher on seven practices that make digital spaces clearer and easier for everyone:

• Use clear language and clear presentation.
• Support people to successfully complete tasks.
• Strengthen orientation and navigation – Where am I within the site? How can I get to where I want to go?
• Help people maintain focus.
• Prevent errors and support easy recovery.
• Provide help and support at the point of need.
• Support personalization.

These practices form the foundation of cognitive-friendly design. While progress continues, some common gaps still create challenges. Here are clear, high-impact fixes teams can apply.

1. The Density Problem: Too Much Text, Too Little Structure

It's common to see long paragraphs, multistep instructions buried inside narrative text, or entire processes presented without headings or visual breaks. Readers often end up scrolling back and forth to find the part that tells them what to do next.

Try this:

• Add short, meaningful headings ("Before You Start," "What You'll Need," "Next Steps").
• Break complex ideas into bullets.
• Put the action first ("Submit your document by selecting 'Upload' below.").
• Keep one idea per sentence.
• Include a one-sentence top summary so the page "previews itself."

These small adjustments reduce cognitive load, help people stay oriented, and make your content usable even for readers who feel overwhelmed by text-heavy pages.

2. "Where Am I?" — Support Orientation

Navigation can present another common challenge when it doesn't clearly show progress or context. Pages may look visually similar without signposts, or actions like "Next" and "Submit" may shift position from page to page. Users may lose their place and aren’t sure what comes next.

Try this:

• Use clear page titles that state the task ("Apply for a Permit: Step 2").
• Add visible progress indicators ("Step 2 of 4").
• Keep buttons in consistent locations across pages.
• Avoid hiding content unless absolutely necessary — and label it clearly when you do.

These cues help users stay grounded, especially in multi‑step processes.

3. "Am I Doing This Right?" — Instructions and Feedback That Support Success

Sometimes forms or instructions assume the user will "just know" what to enter or how information must be formatted. When they guess wrong, error messages may be vague ("Invalid entry") or appear only after the mistake has already been made.

Try this:

• Add short examples ("MM/DD/YYYY").
• Use plain-language error messages that explain what to fix ("Please enter a 5-digit ZIP code").
• Provide hints before typing begins, following accessibility best-practices.
• Accept common format variations whenever possible.

Good guidance up front helps users successfully complete tasks — and it prevents frustration on both sides of the screen.

In Closing

These gaps are common, and simple changes can make a big impact. Start by:

• Breaking up dense text.
• Strengthening navigation cues.
• Offering guidance at the point of need.

With ADA Title II on the immediate horizon, now is the perfect time to build on the progress already underway. Each improvement increases clarity, reduces frustration, and supports greater access for Minnesotans. To continue that work, explore the resources below.

Update

The ADA Title II rule was expected to take effect for larger organizations April 24, 2026. On April 20, the US Department of Justice changed the deadline to April 26, 2027.

Resource List

Minnesota Office of Accessibility Resources

• Closing the Accessibility Gap — Cognitive Disabilities, Accessibility Standards, and Assistive Technology: Learn, Apply, Advocate
  Foundational guidance on cognitive accessibility, written for Minnesota digital teams.
• Editing for clarity: How to strengthen articles — with (and without) AI - How plain language principles support editing practices as well as the use of AI
  Practical steps for following plain language principles.
• WCAG 2.1 Addresses Needs for Users with Cognitive & Mobility Disabilities
  A Minnesota‑focused explainer connecting WCAG success criteria to cognitive needs.

Worldwide Web Consortium (W3C) Resources

• Stories of Web Users
  Several stories feature needs of people with cognitive and learning disabilities. Learn more about what the featured individuals experience and how accessibility supports them to be successful.
• Older Users and Web Accessibility – Meeting the Needs of Aging Web Users