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Does your public library's website have to meet ADA Title II, catalog and all?

What good looks likeBy Whitelam Media7 min read

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Public library websites fall under ADA Title II, and the rule reaches the catalog, ebook apps, calendars and forms you license from vendors. Here is which deadline applies, what to ask vendors and what to fix first.

Almost certainly, yes. A public library run by a city, county or library district is part of local government. The Justice Department's 2024 rule under Title II of the ADA sets WCAG 2.1 AA as the standard for its websites and apps. The Connecticut State Library's guide on the rule says plainly that it applies to public libraries.

The harder questions are which deadline is yours, how far the rule reaches into the catalog and ebook apps you license and what to fix first. This guide answers those for a library director or board. It is general guidance. For legal advice on your library, talk to your city, county or district attorney.

Which deadline applies to your library.

The rule first gave larger governments until 2026 and gave smaller ones and special districts until 2027, as Reed Smith summarizes. In April 2026 the Justice Department published an interim final rule that moved both dates back a year. Governments with a total population of 50,000 or more now have until April 2027. Governments under 50,000 and any special district government have until April 2028, according to Jackson Lewis.

For a library, the date depends on who runs it:

  • A city or county library. The library is a department of that government, so it takes that government's date. If the city or county has a total population of 50,000 or more, plan for April 2027. If it is under that line, plan for April 2028 (thresholds per Jackson Lewis).
  • An independent library district. A district with its own board and taxing power is usually a special district government, which gets April 2028. Whether yours counts depends on state law and how it was formed, so confirm it with counsel. Our guide to special district websites and the 2028 date covers the rest.
  • A joint or shared library. If two governments run a library together, ask counsel which date applies. The safe plan is to meet the earlier one.

Don't treat the new dates as room to wait. The Justice Department said it may propose changes to the rule. If it does not, it expects to hold governments to the new dates, Reed Smith reports. The rule also sets a technical standard for obligations governments already have under the ADA, so a patron can raise a barrier today. Our post on the Title II website deadlines has the wider picture.

Most Title II guides are written for city halls. A library site has more moving parts, and vendors run most of them.

  • The online catalog. Search, results, item pages, holds and the patron account. Content the library gets through a license or subscription will mostly not fall under an exception and needs to meet the rule, the American Library Association explains. If you share a regional catalog, the library and the consortium may each carry obligations.
  • Ebook and audiobook platforms. The borrowing site and the app patrons use to read and listen. These are licensed services the library offers, so the same ALA reasoning applies.
  • Event calendars. These often run on an outside calendar tool. Filters, date pickers and sign-up forms are where problems hide.
  • Room booking. Time grids that only work with a mouse are common.
  • Library card sign-up. This is how people apply for the service. Labels, error messages, timeouts and puzzle-style CAPTCHAs all matter here.
  • Board agendas and minutes. These are usually PDFs. Our post on old PDFs, agendas and vendor tools covers which old files may fall under an exception and which do not.
  • Kids' and teen pages. Games, story time videos and animations need captions, keyboard access and controls to pause.

What to ask catalog and platform vendors.

The rule covers web content a government provides through an arrangement with someone else, the ADA.gov fact sheet says. So a catalog that a vendor runs is still your responsibility. Ask each vendor these questions in writing:

  • Have you tested the patron screens we use against WCAG 2.1 AA? When? Please send the report (an Accessibility Conformance Report, often built on a VPAT).
  • What fails today, and when will each item be fixed? Please give dates.
  • Does your mobile app meet the same standard as the website?
  • If we change the theme or add our own code, who is responsible for those parts?
  • How do patrons report a barrier, and how fast do you respond?

At the next renewal, put the answers in the contract:

  • WCAG 2.1 AA for every patron-facing screen and app
  • An updated conformance report with each major release
  • A set time to fix reported barriers
  • Notice before any release that changes the patron screens
  • Your right to test
  • A remedy if the vendor misses any of these

If a vendor can't answer, start looking at other options now. Changing catalogs takes time.

Who controls what, and what to fix first.

The rule reaches content provided through arrangements with others, and licensed catalog content will mostly need to meet it. So a library's list goes well beyond its own pages. We built this table to show who usually controls each part and the order we would fix them in. Start with what people need to get the service at all.

Part of the siteUsually controlled byFirst stepFix order
Library card sign-upLibrary web team or catalog vendorTest with keyboard and screen reader; fix labels and errorsFirst
Catalog search, holds and accountCatalog vendor, or the consortium if sharedGet a current conformance report and a dated fix planFirst
Homepage, hours, locations, contactLibrary or city web teamFix contrast, headings, image text and link namesFirst
Event calendar and sign-upCalendar vendor or pluginTest sign-up by keyboard; ask for the vendor reportSecond
Room bookingBooking vendor or libraryTest the time picker and confirmationSecond
Ebook and audiobook platformsPlatform vendorAsk for web and app reports; add terms at renewalSecond
New board agendas and minutesClerk or board secretaryPublish as web pages or tagged PDFs from a templateSecond
Kids' and teen pagesYouth services staffCaption videos; check games and animationsThird
Old minutes and archivesClerk and web teamCheck each set against the exceptions; move or label archivesThird

A short plan for the next twelve months.

  1. List everything. Every site, subdomain, vendor tool and app patrons touch, including the domains the catalog and ebook services run on.
  2. Test the core tasks. Get a card, find a book, place a hold, borrow an ebook, sign up for an event and book a room. Use only a keyboard, then a screen reader.
  3. Fix what you own. Your own pages and forms are the fastest fixes.
  4. Send the vendor questions. Write down every answer and date.
  5. Change how new content gets made. Use templates for agendas, caption new videos and give short training to staff who post.
  6. Publish an accessibility statement with a way to report problems. Our guide to writing an accessibility statement shows what to include.
  7. Check monthly. Catalog updates and new events change the site every week.

This is one of our ADA Title II guides, alongside the ones for cities, counties and special districts.

The next step.

Whitelam Media runs an ADA website compliance program for cities, counties and special districts, including library districts. It covers WCAG 2.1 AA audits, fixes, new accessible sites and monthly checks at fixed prices, planned around your Title II date. An audit shows you exactly where patrons get stuck and gives you a list of fixes your board and vendors can act on. No audit can promise a library will never get a complaint, and we won't claim otherwise.