ADA Requirements and Law Firm Websites: New Changes for 2026
On April 24, 2026, new DOJ regulations require state and local government entities (and businesses serving them) to strictly comply with WCAG 2.1 Level AA standards. For firms serving public agencies, ADA compliance is no longer just a suggestion—it is a mandatory standard for any digital tools or content provided on behalf of the government.
ADA For Government Agencies, Cities, and States
In 2024, the Department of Justice made a strict new rule. It says that all websites and apps run by cities, counties, and public schools must be easy for people with disabilities to use. You can see the ADA guidance and rules in this article from ADA.gov.
They use a specific rulebook called WCAG 2.1 Level AA. It’s basically a checklist that makes sure:
- Videos have captions for people who can’t hear
- Text is easy to read for people who can’t see colors well
- Images include alt text that describes the image
- The website works using only a keyboard (no mouse needed)
Important Dates:
- Big Cities (50,000+ people): Must be ready by April 24, 2026. <<<<<<<<<<<
- Small Towns: Must be ready by April 2027.
This applies to state and local government entities (including public universities, counties, and cities).
Does this Apply to You?
1. Your Law Firm Provides Services “On Behalf Of” the Government
If your firm’s website is used by the public to access a government program, it is legally required to meet WCAG 2.1 Level AA standards.
- The Rule: The DOJ’s new “Final Rule” says state and local governments are responsible for the accessibility of any digital service they provide, even if a private contractor (like a law firm) runs it for them.
- Example: If a city hires your firm to manage a class-action settlement and victims have to visit your firm’s website to file a claim or check their status, that website is now a “government service.” It must be accessible.
2. You Have a Government Contract
Even if your website isn’t used by the general public, the government agency you work for is now under massive pressure to meet the April 2026 deadline.
- Procurement Rules: Most government agencies are updating their contracts to include “Accessibility Riders.”
- The Result: They may refuse to hire any law firm whose digital tools or websites don’t meet the WCAG 2.1 AA standard. In this case, it’s not just a law—it’s a business requirement to keep your contract.
Note: This is the biggest change, as they will simply require your law firm to be ADA-compliant as part of their standard contracts. You could risk losing your contract with the government by not adhering to basic standards.
3. The “Title III” Risk (Private Business Law Firms)
Even if you don’t work for the government, you are still a private business (covered by Title III of the ADA).
- Courts and the DOJ now point to the new Title II rules as proof of what a “good website” looks like.
- If a person with a disability tries to use your firm’s website and it doesn’t work with their screen reader, their lawyer will use the April 2026 standards as evidence that your site is out of date and “discriminatory.”
Technical ADA Legal Requirements
Under Title II of the ADA, WCAG 2.1 Level AA is a mandatory technical standard (not just advisory guidelines) for covered public entities, including content provided by third-party vendors or contractors serving those entities (e.g., a private app used for government services like parking payments).
Businesses that Serve Them
The part about “many businesses serving them” aligns with this—private businesses or vendors that provide digital services directly tied to government programs must meet the same standards when acting on behalf of the public entity.
Even if you are a private law firm (or any purely private business not covered by Title II), the statement holds that WCAG 2.1 Level AA has become the effective “gold standard” in ADA-related demand letters and lawsuits under Title III (which covers private businesses open to the public).
- Private businesses aren’t directly subject to this new Title II rule (which is specific to public entities).
- However, in practice, plaintiffs’ attorneys and courts in Title III website accessibility cases overwhelmingly reference WCAG 2.1 (or sometimes 2.0) Level AA as the benchmark for what constitutes “accessible” under the ADA.
- Conformance to WCAG 2.1 AA significantly reduces litigation risk, while non-conformance is frequently cited in demand letters and complaints.
- With the Title II rule raising awareness and setting a clear federal precedent, experts anticipate even more emphasis on this standard in private-sector cases moving forward.
So while not legally mandated for private law firms, WCAG 2.1 Level AA is effectively:
- The litigation benchmark
- The settlement baseline
- The accessibility industry norm
Recap
The new federal requirements for government agencies regarding WCAG 2.1 Level AA compliance will take effect in April 2026 as part of broader ADA enforcement. If you have a private business, the new rule doesn’t directly bind you – but if you are a law firm serving a government agency, it may apply to you.
February 24, 2026
Categories:ADA and Bar Rule Compliance, Legal Industry News and Tips
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