75 Days to the ADA Title II Deadline: Your Compliance Checklist for Municipal Contracts

75 Days

Over the past five weeks, we have covered the regulatory deadline, the overlay widget problem, how to read RFP accessibility requirements, what the 2025 lawsuit data means for contractors, and how to build an audit defense log. Each of those posts was designed to give you the knowledge foundation for what comes next.

This is the action post.

On April 24, 2026 — 75 days from today — the DOJ's Title II final rule takes effect for every municipality serving 50,000 or more residents. Every website, portal, application, document, and digital service those municipalities offer must conform to WCAG 2.1 Level AA. And every contractor who built, maintains, or delivers those digital services is exposed to the same compliance requirements through the procurement language, warranty clauses, and indemnification provisions that municipalities are embedding in their contracts.

There are 75 days. That is enough time to act. It is not enough time to start from scratch, discover problems, and fix everything. Which means the priority is not perfection — it is positioning. Getting a clear picture of where you stand, fixing the critical barriers, documenting your work, and establishing the processes that will keep you compliant and competitive after the deadline passes.

Here is how to use the next 75 days.

Week 1–2: Inventory and Baseline (Days 75–61)

Before you can fix anything, you need to know what you are responsible for and where it stands.

Inventory Your Active Municipal Deliverables

Make a list of every digital asset you have built, are currently building, or are maintaining for a municipal client. This includes websites, web applications, portals, forms, payment systems, document repositories, and any third-party integrations you implemented. For each one, note the municipality, the contract status (active, in maintenance, delivered and handed off), and whether the contract includes accessibility requirements, warranties, or indemnification language.

If you delivered a project and walked away, you may still have liability. Review your contract terms. Many municipal contracts include warranty periods that extend well beyond delivery, and indemnification clauses that survive contract termination. If the contract says you warrant WCAG conformance for the term of the agreement and the agreement is still active, you are still on the hook.

Run Baseline Scans

For each deliverable on your inventory, run a WCAG 2.1 Level AA scan using an automated tool. axe-core, WAVE, and Lighthouse are widely used engines that test against WCAG success criteria and report results with criterion references, severity levels, and element locations.

Automated scanning catches approximately 30 to 40 percent of WCAG issues — the ones that can be evaluated programmatically, like missing alt text, insufficient color contrast, empty form labels, and duplicate IDs. The remaining 60 to 70 percent require manual testing with keyboard navigation and screen readers. But automated scanning gives you a fast, documentable baseline that identifies the most common and most legally-cited barriers.

Record the results. Date, URL, tool used, total issues by severity, breakdown by WCAG criterion. This is the first entry in your audit defense log.

Prioritize by Exposure

Not every deliverable carries the same risk. Prioritize based on:

Public visibility. A city's main website or resident-facing portal has far more exposure than an internal administrative tool. Plaintiff firms and pro se filers target what they can access publicly.

Transaction volume. Payment portals, permit applications, court filing systems, and service request forms are high-traffic, high-impact surfaces. An inaccessible payment form affects more people — and generates more compelling complaints — than an inaccessible "about us" page.

Contract terms. Deliverables with explicit WCAG warranty or indemnification clauses represent direct financial exposure. These go to the top of the list regardless of public visibility.

Scan results. Deliverables with critical-severity issues — barriers that completely block access for screen reader users or keyboard-only users — take priority over those with moderate or minor issues.

Week 3–5: Remediate Critical Barriers (Days 60–40)

With your baseline established and priorities set, the next three weeks are for fixing the issues that matter most. You are not trying to achieve perfect conformance in 21 days. You are eliminating the barriers that generate the most complaints and the strongest legal claims.

The High-Impact Fix List

Based on the most commonly cited barriers in 2025 ADA lawsuits and the WCAG criteria that automated tools reliably detect, focus on these first:

Missing or empty alternative text (WCAG 1.1.1). Every meaningful image needs descriptive alt text. Decorative images need empty alt attributes (alt=""). This is the single most commonly cited violation in accessibility complaints and one of the easiest to fix.

Insufficient color contrast (WCAG 1.4.3). Text must have a contrast ratio of at least 4.5:1 against its background (3:1 for large text). Most automated tools flag this precisely and many modern design systems already meet these ratios — the issues are usually in legacy content, custom buttons, or branded elements with low-contrast color combinations.

Missing form labels (WCAG 1.3.1, 4.1.2). Every form input needs a programmatically associated label. If a screen reader user encounters a text field and hears nothing about what information to enter, that is a critical barrier. This applies to search fields, login forms, contact forms, filter controls, and every input element on payment and application forms.

Keyboard accessibility (WCAG 2.1.1, 2.1.2). Every interactive element — links, buttons, form controls, menus, modals, tabs — must be operable with a keyboard alone. No keyboard traps (elements you can tab into but not tab out of). Visible focus indicators so keyboard users can see where they are on the page. This requires manual testing: tab through every page and verify you can reach, operate, and leave every interactive element.

Page structure and headings (WCAG 1.3.1, 2.4.6). Pages need a logical heading hierarchy — one H1, followed by H2s for major sections, H3s for subsections, with no skipped levels. Landmark regions (header, nav, main, footer) should be properly defined. Screen reader users navigate by headings and landmarks; without them, a page is an undifferentiated wall of content.

Link purpose (WCAG 2.4.4). Links need to make sense out of context. "Click here" and "Read more" repeated throughout a page are barriers for screen reader users who navigate by pulling up a list of all links on the page. Each link should describe where it goes.

Document Every Fix

As you remediate each issue, log it. The original finding, the fix applied, who applied it, the date, and the retesting result. This is not administrative overhead — it is the remediation section of your audit defense log, and it is the documentation that demonstrates good faith effort if your deliverable is ever cited in a complaint.

Week 6–7: Manual Testing and Documentation (Days 39–26)

Automated scanning gets you partway there. Manual testing closes the gap on the issues that machines cannot evaluate.

Keyboard-Only Navigation Test

Set your mouse aside. Starting from the top of each priority page, use only the Tab key, Shift+Tab, Enter, Space, Escape, and arrow keys to navigate the entire page. Verify that you can reach every interactive element, that focus moves in a logical order, that focus is always visible, that no modal or dropdown traps your focus, and that all functionality — including dynamic content like accordions, tabs, and carousels — is fully operable without a mouse.

Document your findings. Note any elements that are unreachable, any focus traps, any instances where focus disappears or jumps unexpectedly, and any interactive elements that only respond to mouse events.

Screen Reader Spot Check

If you are not experienced with screen readers, this is not the time to develop full proficiency. But a basic spot check with NVDA (free, Windows) or VoiceOver (built into macOS and iOS) can reveal issues that no automated tool catches.

Navigate to your priority pages with the screen reader active and listen. Does the page title read correctly? Do headings announce in a logical order? Do images announce their alt text, and does that alt text actually describe the image content? Do form fields announce their labels? Do buttons and links announce their purpose? Do error messages announce when they appear?

You are listening for two things: silence where there should be information (missing labels, missing alt text, unannounced content changes) and confusion where there should be clarity (misleading labels, illogical reading order, redundant announcements).

Document what you find. Even if you cannot fix every issue within this window, documenting that you performed manual testing and identified issues for remediation is itself evidence of a thorough compliance process.

Compile Your Audit Defense Log

By this point, you should have baseline scan results, a remediation log covering your critical fixes, retesting results showing improvement, and manual testing findings. Compile these into a structured audit defense log following the framework from Post 5.

Generate a summary that a non-technical reader can understand: how many issues were identified, how many were remediated, what the current conformance status is, and what your ongoing monitoring plan includes. This summary is what you hand to your client, what your client hands to their attorney, and what you include in your next RFP response as evidence of your compliance methodology.

Week 8–9: Accessibility Statements and Client Communication (Days 25–12)

Draft Accessibility Statements

Under the Title II rule, municipalities are expected to publish accessibility statements on their digital properties. If your deliverables do not already include one, draft a statement for your client to review and publish.

An accessibility statement should include the standard the site targets (WCAG 2.1 Level AA), the date of the most recent accessibility evaluation, a summary of known limitations (if any remain), a contact method for reporting accessibility barriers, and a commitment to addressing reported issues within a specific timeframe.

This is not a legal document — it is a public commitment that also serves as evidence of good faith. Help your client get it published before the deadline.

Communicate With Your Municipal Clients

Do not wait for your clients to ask about accessibility. Reach out proactively. Share your scan results (at a summary level), describe the remediation work you have completed, outline your ongoing monitoring plan, and offer to discuss any accessibility requirements they are preparing to implement.

This proactive communication accomplishes three things. It demonstrates that you are ahead of the compliance curve, which builds trust. It positions you as a resource rather than a liability, which strengthens the relationship for contract renewals and future bids. And it creates a documented record of your compliance communication — another element of your defense log.

If your client has not yet addressed their broader digital accessibility obligations, this is an opportunity to help them understand the scope. Many municipalities are still in the early stages of inventorying their digital assets and developing compliance plans. Being the contractor who helps them navigate that process — not just for your deliverables but for their overall digital footprint — creates significant goodwill and positions you for additional work.

Week 10–11: Process and Future-Proofing (Days 11–1)

Establish Ongoing Monitoring

Compliance is not a destination you reach on April 24. It is a maintenance commitment. Before the deadline arrives, establish the monitoring process that keeps your deliverables conformant going forward.

Set a recurring schedule for automated rescans — monthly at minimum for active sites, quarterly for stable deliverables. Define a process for reviewing scan results, triaging new issues, and remediating them within a specific timeframe. Document the schedule and the process as part of your standard operating procedure.

If your contract includes a maintenance or support agreement, incorporate accessibility monitoring into it explicitly. If it does not, consider proposing an accessibility maintenance addendum to your client. This creates recurring revenue for your business while providing your client with ongoing compliance assurance — a genuine win for both parties.

Update Your Bid Materials

Every RFP you respond to from this point forward should reflect your accessibility capability. Update your standard proposal language to include your WCAG testing methodology (automated and manual), your remediation workflow, your documentation process (the audit defense log), and references to past accessible work.

If an RFP includes accessibility requirements — VPATs, warranties, indemnification — your response should address each one specifically rather than generically. Reference the tools you use, the standards you test against, the documentation you provide, and your approach to ongoing monitoring. Include a sample audit defense log or summary from a past project if you have one.

In a procurement environment where accessibility is becoming a gatekeeper, the contractor who responds with evidence and specificity will consistently outperform the one who responds with vague commitments.

Prepare for the Post-Deadline Landscape

After April 24, the municipal digital accessibility market changes permanently. Municipalities that missed the deadline will need emergency remediation. Municipalities that achieved compliance will need ongoing monitoring and maintenance. New projects will require accessibility from day one as a standard deliverable, not an optional add-on. And the litigation pressure that has been concentrated on private businesses will begin flowing toward government entities and their vendors.

The contractors who will thrive in this landscape are the ones who built their accessibility capability before the deadline — not because a client demanded it, but because they recognized it as a core professional competency. You have 75 days. That is enough time to scan, fix, document, and establish the processes that position your business on the right side of this shift.

The deadline is not the end of something. It is the beginning of a market where accessibility competence separates the contractors who keep winning municipal work from those who stop getting invited to bid.

Start today.

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This post is for informational purposes only and does not constitute legal advice. Consult with qualified legal counsel for guidance specific to your situation.