What are the ADA website requirements?

ADA website requirements depend on whether the website is operated by a state or local government or a private business open to the public. State and local governments are now subject to a specific federal technical standard and deadlines; private businesses remain subject to the ADA’s general nondiscrimination and effective-communication duties, but there is no generally applicable federal regulation prescribing a specific website standard for them.

State and local governments

Title II covers public entities’ online services, programs, and activities. The ADA provides:

“No qualified individual with a disability shall, by reason of such disability, be excluded from participation in or be denied the benefits of the services, programs, or activities of a public entity, or be subjected to discrimination by any such entity.”[3]

The Department of Justice’s rule requires covered public entities’ web content and mobile apps to conform to WCAG 2.1 Level AA, subject to the rule’s exceptions and defenses. The rule covers content provided or made available directly or through contractual, licensing, or other arrangements.[1]

28 C.F.R. § 35.200[1] The Department extended the earlier deadlines in an interim final rule effective April 20, 2026.[1] The extension changes the technical-rule deadlines, not the underlying Title II duty to provide accessible services and effective communication.[1]

The regulation recognizes exceptions and limits, including fundamental alteration and undue financial and administrative burdens. Those are fact-specific and do not eliminate the entity’s broader Title II obligations.[1][2]

Private businesses and public accommodations

Title III applies to businesses open to the public. The statute requires:

“No individual shall be discriminated against on the basis of disability in the full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations of any place of public accommodation.”[4]

DOJ’s guidance takes the position that ADA duties reach goods and services offered on the web, and identifies practical accessibility features such as text alternatives for images, captions, keyboard navigation, and accessible form labels and error messages.[5] That guidance is nonbinding: it does not establish a mandatory technical standard for private websites.[5] There is also a circuit split over when Title III applies to websites that have no physical location or connection to a physical business.[6][7]

Where a website is tied to a physical public accommodation, some courts have applied Title III to online services that impede access to the physical business’s goods or services. For example, the Ninth Circuit held that the ADA applied to a restaurant’s online ordering website and app because they connected customers to the goods and services of its physical restaurants.[8] The Eleventh Circuit, by contrast, has held that a website is not itself a “place of public accommodation” and rejected a claim on the facts before it involving a limited-use grocery-store website.[9] The governing rule therefore depends in part on jurisdiction and the website’s function.

Practical accessibility steps

For a public entity subject to the technical rule, plan for WCAG 2.1 Level AA conformance by the applicable deadline. For a private business, WCAG 2.1 Level AA is a commonly used technical benchmark, but DOJ has not made it a general, binding Title III requirement.[5][10] In either setting, useful steps include:

• Make key functions operable by keyboard and compatible with screen readers.
• Provide meaningful text alternatives for images and captions for video and audio.
• Use accessible headings, links, form labels, instructions, and error messages.
• Test important user journeys, such as registration, purchasing, appointment scheduling, and account access.
• Provide an accessible way to report barriers and a timely process for addressing them.

The specific legal exposure depends on the entity type, location, services offered online, applicable exceptions, and relevant circuit law. If you share the state or federal circuit and whether this concerns a government entity or private business, I can narrow the requirements and deadlines.