Let's be honest: If your government website isn't already substantially compliant with WCAG 2.1 Level AA standards, you cannot achieve full compliance before the April 24, 2026 deadline. Comprehensive accessibility remediation takes 12-18 months. You have 62 days.
But that doesn't mean you're helpless. This emergency guide provides a realistic triage approach: what to fix, what to document, and how good faith compliance documentation can be your most powerful legal defense when full compliance isn't achievable.
Who Faces the April 24, 2026 Deadline?
The DOJ's Title II rule requires WCAG 2.1 Level AA compliance by April 24, 2026 for:
• State government agencies (all, regardless of size)
• Counties with populations of 50,000+
• Cities with populations of 50,000+
• School districts serving populations of 50,000+
• Public universities and colleges (all)
• Special districts (transit, water, utilities) serving 50,000+
Smaller entities (under 50,000 population) have until April 26, 2027—but don't let that create false comfort. Lawsuits don't wait for deadlines.
No Extensions Available:
The DOJ has confirmed multiple times: there will be no deadline extensions. The rule is final. April 24, 2026 is immovable.
Why Time Isn't on Your Side (The Math)
Standard Remediation Project (12-18 months):
• Comprehensive audit: 2-4 weeks
• Remediation planning: 2-3 weeks
• Code-level fixes: 3-6 months
• PDF remediation: 2-4 months
• Video captioning: 1-3 months
• Testing and validation: 4-8 weeks
• Third-party vendor coordination: 2-4 months
Your Reality (62 days):
• Everything above compressed into weeks
• Vendors fully booked (everyone waited)
• Emergency rates: 4-5x normal costs
• Still won't finish everything
The Honest Assessment:
If your website has 500+ pages, thousands of PDFs, hundreds of videos, and third-party integrations—full compliance by April 24 is mathematically impossible.
But Here's What You CAN Do:
You can make substantial progress. You can document every effort. You can demonstrate good faith. And that documented good faith is often the difference between a $150,000 settlement and a $60,000 settlement.
The Good Faith Strategy: Your Best Defense
Courts and the DOJ distinguish between two types of non-compliant entities:
Type 1: Willful Ignorance
• No accessibility audits ever conducted
• No documentation of any compliance efforts
• No budget allocated to accessibility
• No response to complaints
Type 2: Good Faith Effort
• Documented accessibility audits with dates
• Compliance certificates showing current status
• Remediation tracking with evidence of fixes
• Budget allocation records
• Staff training documentation
The Settlement Difference:
Entities demonstrating Type 2 characteristics see settlement reductions of 40-60%. Why? Because plaintiff attorneys know courts view good faith favorably, DOJ enforcement prioritizes willful violators, and documented effort changes the narrative.
Your Documentation Checklist:
✅ Good Faith Compliance Certificate with current score and date ✅ Remediation tracking spreadsheet with timestamps ✅ Before/after evidence of fixes made ✅ Budget allocation documentation ✅ Staff training records ✅ Accessibility policy statement
Learn more about what good faith means in ADA law.
Document Your Good Faith Effort Today
The Government Compliance Action Kit provides a professional Good Faith Compliance Certificate, remediation roadmap, and documentation package. When you can't achieve perfect compliance, documented good faith effort is your best legal defense.
Get Your Compliance CertificateEmergency Triage: What to Fix First
You can't fix everything. Focus on violations that trigger the most lawsuits and are fastest to fix.
WEEK 1-2: Critical Quick Wins
• Alt Text - Found on 67% of non-compliant sites, primary lawsuit trigger
• Form Labels - Blocks users from payments/applications
• Color Contrast - Easy CSS fixes, affects 52% of sites
WEEK 3-6: High-Impact Fixes
• PDF Accessibility - Fix most-downloaded PDFs first (95% of sites have issues)
• Keyboard Navigation - Test all interactive elements
• Video Captions - Focus on most-viewed, recent content
WEEK 7-13: Systematic Remediation
• Work through remaining pages by traffic priority
• Continue PDF remediation
• Document everything you're doing
• Maintain remediation tracking log
What Happens on April 25, 2026?
Immediate Lawsuit Surge:
• Plaintiff attorneys have been preparing
• Lawsuits filed within days of deadline
• Settlement demands at maximum leverage
• Class action attempts using $5.15M precedent
DOJ Enforcement Actions:
• Department of Justice begins enforcement
• Federal penalties up to $150,000 per violation
• Consent decrees with monitoring
The Good Faith Difference:
Even post-deadline, documented good faith matters. Courts consider when efforts began. DOJ prioritizes willful violators. Compliance certificates dated before deadline prove proactive effort.
Budget Realities: What This Will Cost
Proactive Compliance (Started 2024): $37,000-$135,000
Emergency Compliance (Starting Now): $130,000-$475,000 (4-5x normal rates)
Post-Lawsuit Compliance:
• Settlement: $50,000-$200,000
• Legal fees: $50,000-$150,000
• Remediation: $100,000-$400,000
• Total: $225,000-$800,000+
The Math is Clear:
Even emergency compliance costs less than post-lawsuit remediation. And good faith documentation costs a fraction—but can reduce settlements by 40-60%.
Your Emergency Action Plan
THIS WEEK (Days 1-7): □ Run accessibility scan today □ Document current state with timestamps □ Get Good Faith Compliance Certificate □ Brief leadership on deadline + risks □ Start fixing alt text and form labels immediately
WEEK 2 (Days 8-14): □ Complete quick wins (alt text, contrast, labels) □ Begin PDF audit □ Post accessibility statement □ Start remediation tracking spreadsheet
WEEKS 3-6 (Days 15-42): □ Systematic page-by-page remediation □ PDF accessibility fixes (priority documents) □ Keyboard navigation testing □ Document every fix with evidence
WEEKS 7-13 (Days 43-93): □ Continue remediation by priority □ Complete staff training and document it □ Update compliance certificate with progress □ Prepare response protocol for post-deadline inquiries
State-Specific Considerations
Highest Risk States:
• California: 2,650+ lawsuits, $5.15M class action
• New York: 1,950+ lawsuits, $71k average
• Florida: 1,175+ lawsuits, serial plaintiffs
• Illinois: 746% lawsuit increase
• Texas: DOJ election website enforcement
Emerging Risk:
• Pennsylvania: Shadow litigation, demand letters 3x lawsuits
• Michigan: 2,400 school complaints
Review your state's specific requirements.
Start Your Emergency Plan Now
Every day you wait is a day lost. Scan your website now to understand your violations, then get your Good Faith Compliance Certificate to build your legal defense. 62 days isn't enough for perfection—but it IS enough to demonstrate documented good faith effort.
Scan Your Website Now62 days until the April 24, 2026 ADA deadline is not enough time for most government entities to achieve full WCAG 2.1 Level AA compliance. That's the uncomfortable truth.
But what you CAN do in 62 days:
• **Document everything** - Good faith compliance certificates, remediation tracking, training logs • **Fix high-impact violations** - Alt text, form labels, color contrast, keyboard navigation • **Triage ruthlessly** - Focus on pages and PDFs with highest traffic • **Build your defense** - Documentation is your shield when enforcement comes
The organizations that will fare best post-deadline are those that can prove they took accessibility seriously. Courts and the DOJ distinguish between willful ignorance and good faith effort.
Start today. Not tomorrow. Run your accessibility scan. Get your compliance certificate. Begin remediation immediately. Document everything.
The clock is running. Make every day count.