Meeting the DOJ Title II Compliance: Don’t Forget Your Accessibility Policy

For state and local governments working toward DOJ Title II compliance, much of the attention is on websites, PDFs, mobile apps, and WCAG testing.

But another piece belongs on your compliance roadmap. And that’s your organization’s web accessibility policy.

In the DOJ’s First Steps resource, one of its non-mandatory steps toward compliance is to create web and mobile accessibility policies.

I want to stop here for a minute to share a critical issue in meeting Title II compliance and to thank Dax Castro (LinkedIn)for bringing it into the ADA / Title II compliance conversation.

Here is a direct quote from his article titled What No One’s Telling You About Meeting the Title II Deadline (LinkedIn), published on Oct. 30, 2026 on LinkedIn.

But there’s another question that deserves just as much attention: What is your organization publishing today?

Because while you’re working through last year’s documents, someone is creating next month’s accessibility problems. A department is updating a form. A designer is exporting a report. Someone is posting a video, purchasing a new platform, or uploading a document from an outside vendor.

I’m not going to paraphrase his entire article, but I do recommend you give it a read, as well as the comments.

I do, however, want to point out why I felt it was important to include the message from his article in this blog post.

The DOJ deadline did not create a cease-and-desist order for updating or creating new content on your website. Those activities never stop. Daily updates are required, new class schedules must be posted, new employee profiles need to be added, and there are the daily / weekly maintenance items that are part of running a website.

But how people in your organization are currently creating that web content is a direct reflection of your organization’s web accessibility policy or the absence of one.

The message in Mr. Castro’s article can be directly related to having a web accessibility policy in place. As you move through your compliance activities, make sure your web accessibility policy works in tandem with those activities and gets updated as your accessibility work reveals new processes, workflows, and responsibilities.

And if you don’t have a policy currently in place, there’s no time like the present.

Now, back to the topic at hand.

What is a Web Accessibility Policy?

A web accessibility policy is a clear, internal framework that spells out your organization’s commitment to making its digital content and services accessible to everyone.

Why Do You Need a Web Accessibility Policy?

An effective accessibility policy does more than just document an organization’s intentions. It establishes the strategic foundation for making digital accessibility an ongoing organizational priority. It outlines the standards that guide accessibility efforts, clarifies team roles and accountability, and sets expectations for meeting legal requirements.

What Should You Include in Your Web Accessibility Policy?

The World Wide Web Consortium (W3C) recommends defining your accessibility standard and conformance level, establishing the policy’s scope, setting measurable milestones, addressing third-party content, and creating processes to monitor, review, and collect user feedback.

A strong web accessibility policy should include the answers to these, and other, critical questions:

What needs to be accessible?

Public websites and web apps, including marketing sites, product pages, and login-gated experiences like dashboards, portals, and checkout flows.
Mobile apps and any embedded or third-party tools your users engage with, such as chat widgets, scheduling tools, payment forms, and cookie banners.
Subdomains, microsites, campaign landing pages, and legacy pages that are still live. These are the most commonly forgotten elements.
Archived content. Best practices say to define the archive date, provide an email address and phone number, and offer an accessible alternative on request.

Don’t forget to include specific content types. Some examples are:

Text should include proper headings, lists, tables, links, and reading order.
Images, icons, and charts should include meaningful ALT text or text alternatives.
Video and audio need captions, transcripts, and audio descriptions where needed.
Downloadable documents such as PDFs, Word files, slide decks, and spreadsheets.
Forms, error messages, and interactive components like menus, modals, carousels, and custom widgets.
Dynamic content, including notifications and live updates.

Which accessibility standard are we following?

For public entities adhering to the DOJ Title II rule, the required technical standard is WCAG 2.1 Level AA. The current compliance deadlines are April 26, 2027, for public entities serving populations of 50,000 or more, and April 26, 2028, for smaller entities and special district governments.

Who’s Responsible for Creating and Maintaining Website Accessibility?

Everyone who contributes to your website has a role in making it accessible, but your organization is ultimately responsible for keeping accessibility a priority.

Website accessibility isn't a task that belongs exclusively to your developers or accessibility compliance officer. It's an ongoing organizational commitment that involves leadership, designers, developers, content creators, procurement teams, and anyone who contributes to or makes decisions affecting your digital presence.

The key is making sure everyone understands their responsibilities and that accessibility is built into your organization's processes, not treated as a final checkpoint before something goes live.

Think about ownership across your organization like this:

The Ultimate Accountability

Your organization is ultimately responsible for the accessibility of its entire digital experience, regardless of who creates, manages, or maintains the content.

That includes everything from your own website content to third-party applications, embedded tools, and other digital services. You can outsource development, purchase software, or rely on vendors to provide accessible products, but you can't outsource accountability.

As highlighted in Third-Party Tools, First-Party Responsibility: When Your Vendor Isn't Listening, your organization remains accountable for accessibility issues within its digital experience, even when the underlying code is managed by a third-party vendor.

Your organization should set clear accessibility expectations, assign ownership, provide training and resources, and create processes to identify and address accessibility barriers.

Designers

Designers influence accessibility long before a website or application is developed. Their decisions determine how information is presented, what colors are used, how users navigate an interface, and how easily people with different abilities can interact with digital content.

Accessibility shouldn't be something designers are asked to fix after a design is complete. It should be part of the creative process from the beginning.

Developers

Developers are responsible for translating accessible designs into functional, usable digital experiences. Even a well-designed interface can introduce accessibility barriers if it's not implemented correctly.

Developers also play an important role in maintaining accessibility as websites evolve. New features, design changes, and code updates should be evaluated for accessibility rather than assuming previously accessible functionality will remain that way.

Content Creators and Editors

Anyone who writes, uploads, or publishes website content has a responsibility to make that content accessible.

This includes marketing teams, communications professionals, department editors, and anyone with publishing privileges.

Your organization should provide content creators with accessibility training, publishing guidelines, and tools to help them identify potential issues before content goes live.

Procurement and Third-Party Vendors

Your website's accessibility doesn't stop with the content and technology your organization creates internally.

Third-party applications, embedded widgets, payment platforms, scheduling tools, video players, and other vendor-provided services can all introduce accessibility barriers.

That's why procurement teams need to be part of the accessibility conversation.

Requiring an Accessibility Conformance Report (ACR) will provide valuable information to help organizations evaluate a product's conformance and make informed purchasing decisions.

Organizations should evaluate a vendor’s accessibility practices and establish clear accessibility requirements before selecting or purchasing a product. These expectations should be documented in the RFP and built into contract terms so accessibility is considered part of the procurement decision.

How will accessibility be monitored and maintained?

Your accessibility policy should outline the processes and practices your organization uses to monitor, maintain, and continually improve digital accessibility. This includes establishing a schedule for regular automated scans and manual accessibility audits, identifying how issues will be documented, prioritized, and remediated, and assigning responsibility for tracking progress.

Your policy should provide contact information or a process outline for each of your accessibility feedback channels. Each channel must have a designated owner and a documented process for responding to reported issues. Remember, not everyone communicates the same way, so offering varying feedback channels that accommodate different needs and preferences goes a long way in helping people help you.

Your policy should also address ongoing staff training, accessibility reviews during website updates and new content development, and opportunities to incorporate user feedback.

By defining these expectations, your policy creates a framework for keeping accessibility efforts consistent, measurable, and sustainable.

Why Finalize the Policy Now?

Without documented ownership, publishing requirements, procurement standards, testing processes, and review cycles, you risk remediating just enough to meet the DOJ Title II deadline without establishing accessibility practices that will keep you in compliance.

Your accessibility policy is what will prevent you from repeating that cycle.

This is especially important as organizations work toward the DOJ Title II compliance deadline. While the pressure to identify and remediate accessibility issues is understandable, focusing exclusively on meeting the deadline can create new accessibility debt if the underlying processes that allow those issues to happen remain unchanged.

Don't let the rush to meet the DOJ Title II deadline create new accessibility issues. Your accessibility policy should do more than document your current efforts. It should establish the framework that keeps accessibility a priority long after the deadline has passed.

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A human author creates the DubBlog posts. The AI tools Gemini and ChatGPT are sometimes used to brainstorm subject ideas, generate blog post outlines, and rephrase certain portions of the content. Our marketing team carefully reviews all final drafts for accuracy and authenticity. The opinions and perspectives expressed remain the sole responsibility of the human author.