Insights
A WCAG 2.1 AA checklist for city & county websites, and the checks software can't do.
What good looks likeBy Whitelam Media8 min read
All insightsThe ADA Title II rule asks city and county websites to pass 50 WCAG 2.1 success criteria. This checklist covers the 16 checks that matter most, what software can find, what needs a person and who on staff fixes each.
To meet the ADA Title II web rule, a city or county website has to pass the Level A and Level AA success criteria of WCAG 2.1, the standard the Justice Department's rule names (28 CFR 35.200). That is 50 criteria in all, 30 at Level A and 20 at Level AA (WCAG 2.1, W3C). Most failures on public sites come from a short list: faint text, images with no description, form fields with no label, links with no name, pages you can't use without a mouse and documents nobody checked. The checklist below covers the 16 checks that matter most on a local government site. For each one it says how much an automated test can tell you, how to check the rest by hand and who on staff usually fixes it.
We built the checklist in October 2026 from the rule, WCAG 2.1, Google's Lighthouse checks and our own look at city and county websites. It isn't legal advice. Whether you comply is a call for your ADA coordinator and counsel.
What the rule asks of your website.
The rule covers the web content and mobile apps a state or local government provides or makes available, directly or through a contract, a license or another arrangement (ada.gov). So a payment portal, a permit system or an agenda tool run by a vendor counts as yours. Places with 50,000 people or more must comply by April 2027. Smaller places and every special district have until April 2028. Our guides cover the deadlines and what to fix first, the special district date and which old PDFs, agendas and vendor tools are covered.
A gap so small that disabled people can still use the site with much the same ease, speed, privacy and independence still counts as meeting the rule (28 CFR 35.205). The example on ada.gov is text with a contrast ratio of 4.45:1 where 4.5:1 is required, and the government has to prove the gap is that small. Plan to meet the standard.
Where city and county sites fail most often.
WebAIM tests the home pages of the top million websites every year. In its February 2026 report, 95.9% of home pages had detected WCAG failures, and six problems made up 96% of the errors found: low contrast text (on 83.9% of pages), images with no text alternative (53.1%), form fields with no label (51%), empty links (46.3%), empty buttons (30.6%) and a missing page language (13.5%). Government sites did better: the 1,987 .gov home pages averaged 18.5 errors each, against 56.1 overall.
Our own check points the same way. In October 2026 we looked closely at 30 US city and county websites (what we found). Of those 30, 24 had no skip-to-content link on a page we checked, 16 had links with no text, 14 had images with no text alternative and 12 had form fields with no label. They weren't a random sample, and we read the page code only, so the real totals are likely higher.
The checklist.
| Check | WCAG 2.1 criterion | Automated test? | How to check by hand | Who fixes it |
|---|---|---|---|---|
| Text contrast is at least 4.5:1, or 3:1 for large text | AA: 1.4.3 Contrast (Minimum) | Mostly, for text on plain colors | Check text over photos and banners with a contrast checker | Web team, in the templates |
| Images that carry information have a text alternative | A: 1.1.1 Non-text Content | Partly: finds missing ones, can't judge what they say | Does each one say what the image shows? | Content editors |
| Every form field has a label | A: 1.3.1 Info and Relationships, 3.3.2 Labels or Instructions | Partly: finds a missing label, not an unclear one | Is it clear what goes in each field? | Web team or the form's vendor |
| Links and buttons have names that say what they do | A: 2.4.4 Link Purpose, 4.1.2 Name, Role, Value | Partly: finds empty ones, not vague ones such as "Click here" | Read each link with its sentence. Can you tell where it goes? | Content editors, web team for icon buttons |
| The page language is set | A: 3.1.1 Language of Page | Partly: finds a missing or invalid language, not the wrong one | Check the language set is the one the page is written in | Web team, once in the template |
| Each page title says what the page is | A: 2.4.2 Page Titled | Partly: finds a missing title, not a vague one | Read the browser tab on your most used pages | Content editors |
| A skip link or landmarks let keyboard users pass the menu | A: 2.4.1 Bypass Blocks | Partly: finds whether one exists, not whether it works | Press Tab once, then Enter. Do you reach the main content? | Web team, in the templates |
| Everything works by keyboard, and focus never gets stuck | A: 2.1.1 Keyboard, 2.1.2 No Keyboard Trap | No | Put the mouse away, then pay a bill and find an agenda | Web team or the vendor |
| You can see where the keyboard is | AA: 2.4.7 Focus Visible | No | Tab through and watch for the outline on each link and button | Web team, in the templates |
| Focus moves in a sensible order | A: 2.4.3 Focus Order | No | Tab through. Does the order follow what you see? | Web team |
| Headings and lists are real headings and lists | A: 1.3.1 Info and Relationships. AA: 2.4.6 Headings and Labels | Partly: finds skipped levels, not bold text posing as a heading | List the headings with a browser extension. Do they read like a table of contents? | Content editors |
| Form errors say what went wrong and how to fix it | A: 3.3.1 Error Identification. AA: 3.3.3 Error Suggestion | No | Submit each form with a mistake on purpose | Web team or the form's vendor |
| Videos have captions, and live meetings live captions | A: 1.2.2 Captions (Prerecorded). AA: 1.2.4 Captions (Live) | Partly: finds a page video with no caption track, not an embedded player or wrong captions | Watch a minute of each recording with the sound off | Clerk's office or communications |
| Pages work at 400% zoom with no sideways scrolling | AA: 1.4.10 Reflow, 1.4.4 Resize Text | Partly: finds a page that blocks zoom on phones, not whether it reflows | Zoom a desktop browser window 1,280 pixels wide to 400% | Web team, in the templates |
| Documents people still use are accessible, or have a web version | The same criteria, applied to the document | No: page checkers don't open PDFs | Run your PDF editor's accessibility check, then try a screen reader | The department that owns it |
| Vendor tools pass the same checks | All of them: the rule counts these tools as yours | Partly: the same tests run on the vendor's pages | Run this checklist on its pages and ask for its Accessibility Conformance Report | Procurement, with the vendor |
What an automated test can and can't tell you.
In the table, software settles none of the 16 checks on its own. It does part of the job on 11, mostly by finding what's missing, and 5 need a person from start to finish. W3C, which writes WCAG, says tools can't check everything and human judgment is needed (Selecting web accessibility evaluation tools). Google lists keyboard focus, tab order and trapped focus among the checks Lighthouse leaves to a person (Lighthouse accessibility scoring). A perfect Lighthouse score still leaves the keyboard, the forms and the documents to a person.
An overlay widget doesn't change that. Our October check found one on 15 of the 30 sites (what we found). An overlay sits on top of the page and leaves the code underneath as it was, and the code is what WCAG tests. In April 2025 the Federal Trade Commission approved a final order requiring accessiBe, an overlay maker, to pay $1 million over claims that its AI tool could make any website WCAG compliant (FTC).
How to run the checklist on your own site.
- Start with what people come to do. List the tasks residents use most, such as paying a bill, applying for a permit and finding a meeting agenda.
- Run an automated test on every page in those tasks. Lighthouse has its own panel in Chrome's developer tools (Lighthouse overview), and WebAIM's WAVE extension works in Chrome, Firefox and Edge. Fix template problems first: one fix there clears every page that uses the template.
- Do each task with the keyboard alone, then with a screen reader. NVDA runs on Windows, and VoiceOver comes with every Mac and iPhone.
- Open the documents those tasks depend on. A permit form people download today has to meet the standard, even if it was posted years ago.
- Ask each vendor for its Accessibility Conformance Report (often a form called a VPAT) and compare it with your own test.
- Log every finding with an owner and a date, using the last column of the table. Then repeat the automated tests every month and the hand checks every quarter, because new pages and documents break things.
WCAG 2.1 or 2.2?
The rule names WCAG 2.1, so that is what your site is measured against. W3C published WCAG 2.2 in October 2023 with nine more success criteria, six of them at Level A or AA, on things like touch target size, dragging, focus hidden behind sticky headers and sign-ins that rely on memory (What's new in WCAG 2.2). W3C says the 2.1 criteria are essentially the same in 2.2, apart from 4.1.1 Parsing, which 2.2 removes. The current text of WCAG 2.1 says to treat 4.1.1 as always met for HTML.
For a new site, we'd write WCAG 2.2 AA into the contract. It covers what 2.1 AA asks for, plus those six checks. The rule lets a government use alternatives to WCAG 2.1 AA when it can show they give the same or more accessibility and usability (ada.gov). Our guide to writing a county website RFP for ADA Title II covers the rest of the scope.
When the list is longer than your team can fix.
If the checklist turns up problems in the templates, the forms and hundreds of documents, price the work. Our guide to what it costs to make a city or county website meet WCAG 2.1 AA sets out what drives the number. Our ADA website compliance program starts with an audit against every WCAG 2.1 AA criterion, fixes what fails and checks the site every month after that. Where fixing the old site would cost more than replacing it, a rebuild made to the standard is the better buy. Or book a call and we'll go through your checklist with you.
