On March 3, 2026, the Department of Justice published a resource that every government IT director, ADA coordinator, and compliance officer needs to read immediately: 'State and Local Governments: First Steps Toward Complying with the ADA Title II Web and Mobile Application Accessibility Rule.'
This is not a blog post or an FAQ. This is official DOJ guidance on ada.gov, laying out exactly what state and local governments must do to comply with the April 24, 2026 deadline. It outlines 11 specific steps, from assigning responsibility to creating vendor procurement policies.
The timing is deliberate. With 15 days until mandatory compliance for entities serving 50,000+ residents, the DOJ is telling you: we expect compliance, here is exactly how to do it, and enforcement is coming.
This matters especially because the DOJ simultaneously has an Interim Final Rule under review at OIRA that could modify the rule. Publishing compliance guidance while reviewing the rule sends a clear signal: comply now regardless of what might change.
→ **Check your status now:** Run a free WCAG 2.1 AA compliance scan before the deadline.
The 11 Steps: What the DOJ Expects
The guidance lays out 11 sequential steps. Here is each one with what it means for your organization:
Step 1: Learn the Requirements Review the DOJ's Fact Sheet, Small Entity Compliance Guide, or the full rule text. The DOJ is explicitly saying 'ignorance is not a defense.' If you have not read the rule, start there.
Step 2: Determine Your Compliance Timeline Use Census Bureau data to calculate your entity's population. Entities serving 50,000+ must comply by April 24, 2026. Under 50,000 gets until April 26, 2027. Special districts follow the 2027 timeline.
Step 3: Assign Responsibility The DOJ says to 'think broadly about who should be involved' — web developers, IT staff, procurement personnel, content creators, and department heads. This is not just an IT problem. It is an organizational responsibility.
Step 4: Train Staff Foundational training on accessibility importance for all staff, plus specialized training for designers, developers, content authors, and procurement staff. Training records become part of your good faith defense.
Step 5: Inventory Digital Assets Identify ALL websites, web pages, PDFs, videos, mobile apps, and social media accounts. Most entities underestimate their digital footprint. Department microsites, archived PDFs, and embedded third-party widgets all count.
Step 6: Understand Exceptions Five categories of content are excepted from the rule: archived web content, preexisting conventional electronic documents, content posted by third parties, individualized password-protected documents, and preexisting social media posts. Know what qualifies — and what does not.
Step 7: Determine Compliance Scope Classify your content: what requires full WCAG 2.1 AA compliance versus what falls under an exception. This is your triage step.
Step 8: Evaluate Current Accessibility Conduct accessibility testing using both automated tools and manual evaluation. The DOJ specifically references W3C resources for evaluation methodology. A free accessibility scan gives you a baseline score and identifies violations.
Step 9: Prioritize Fixes Focus first on content that enables key tasks (payments, applications, permits), frequently accessed materials, and new content. This is triage — fix what matters most to residents first.
Step 10: Review Vendor Contracts Ensure vendors provide accessible content. Require accessibility warranties and standards in all agreements. The DOJ is explicitly putting vendor accountability on the table.
Step 11: Create Policies Develop organizational accessibility policies addressing testing, content updates, and ongoing compliance. This is your institutional commitment — and your documentation for good faith defense.
Why the Timing Matters
The DOJ published this guidance on March 3 — 52 days before the April 24 deadline. Consider the context:
• February 2, 2026: DOJ blocked a $5M ADA class settlement, demanding real remediation instead of paper compliance
• February 13, 2026: DOJ submitted an Interim Final Rule to OIRA that could modify the Title II rule
• March 3, 2026: DOJ publishes step-by-step compliance guidance on ada.gov
• March 5, 2026: National Federation of the Blind submits letter to OIRA opposing any changes
• March 17, 2026: Converge Accessibility publishes 'Red Alert' that the rule may be pulled entirely
The contradiction is the signal. The DOJ is simultaneously reviewing whether to modify the rule AND publishing guidance telling you how to comply with it. For government entities, the message is: comply regardless. Even if the specific Title II deadline shifts, the underlying ADA obligation has existed since 1990, private lawsuits are at 8,667 per year, and state-level enforcement is accelerating independently.
The compliance guidance also supports enforcement. If the DOJ publishes a detailed playbook and your entity ignores it, that makes enforcement easier, not harder. You were told exactly what to do.
What This Means for Your Good Faith Defense
The DOJ's 11 steps double as a good faith compliance checklist. Every step you complete and document strengthens your legal position.
Minimum documentation to create this week:
• Accessibility audit report with date and score — run a free scan now
• Digital asset inventory — list every website, app, and PDF library
• Responsibility assignment — who owns accessibility in your organization
• Remediation plan — prioritized list of violations to fix, with timeline
• Vendor review — which contracts include accessibility requirements
Why this matters in court:
Organizations with documented good faith efforts settle for 40-60% less than those with no documentation. The DOJ's published guidance creates a clear benchmark: did you follow the steps they told you to follow? If yes, you have a defense. If no, you chose not to.
A Good Faith Compliance Certificate formalizes this documentation with dated, verifiable evidence of your compliance status and remediation plan.
The 15-Day Action Plan
With 15 days until the April 24 deadline, here is the compressed version of the DOJ's guidance:
This Week (Days 1-3):
• Scan your website and save the dated results (DOJ Step 8)
• Assign an accessibility lead (DOJ Step 3)
• Start a digital asset inventory (DOJ Step 5)
• Review which content falls under exceptions (DOJ Step 6)
Next Week (Days 4-10):
• Prioritize violations by service importance (DOJ Step 9)
• Fix critical issues: missing alt text, contrast failures, form labels, keyboard traps
• Review vendor contracts for accessibility clauses (DOJ Step 10)
• Schedule staff training sessions (DOJ Step 4)
Final Push (Days 11-17):
• Continue fixing high-priority violations
• Draft and publish an accessibility policy (DOJ Step 11)
• Post an accessibility statement with contact information
• Get a compliance certificate documenting your efforts
• Save ALL documentation with dates
The goal is not perfection. Full WCAG 2.1 AA compliance in 15 days is unrealistic for most entities. The goal is documented good faith effort following the DOJ's own guidance. That is your defense.
15 Days Left: Follow the DOJ's Step 8
The DOJ's guidance says to evaluate your current accessibility using automated tools and manual testing. Our free scanner checks your website against WCAG 2.1 Level AA — the exact standard the April 24 deadline requires. Get your baseline score, identify violations, and start building your compliance record today.
Scan Your Website FreeThe DOJ does not publish step-by-step compliance guidance for rules it plans to abandon. Whatever happens with the Interim Final Rule at OIRA, this guidance on ada.gov is a permanent record of what the federal government considers necessary for ADA web accessibility compliance.
For government entities, the calculus is simple: follow the 11 steps, document everything, and comply regardless of political uncertainty. The organizations that will be safest are those that can show they followed the DOJ's own playbook.
The deadline is 15 days away. The guidance is published. The steps are clear.
• Scan your website for free — WCAG 2.1 AA compliance check (DOJ Step 8) • Get compliance documentation — Good Faith Compliance Certificate • Read the full Title II deadline analysis • Understanding good faith compliance • DOJ's original guidance on ada.gov — official source
**Disclaimer:** This article provides general information about ADA compliance. It is not legal advice. Consult with a qualified ADA attorney for guidance specific to your organization.