The new web accessibility rule under Title II of the Americans with Disabilities Act requires websites along with mobile apps and other web content are WCAG 2.1 AA conformant.
Full WCAG 2.1 AA conformance just for one website can easily take 3 months – even if you contract with a service provider for audit, remediation, and user testing services. And 3 months is on the very fast side.
This process can take several more months, especially if there are difficulties such as reliance upon third-party code (where there is no access to code) or if the client must take care of remediation themselves (e.g., for security or compliance reasons).
Based on my experience, it’s best to plan for eight months from project start to project finish. This is because accessibility projects typically run over time rather than finish faster.
Let’s first go over a practical timeline for the first year with expectations for different activities and then discuss the different phases.
Table of Contents
1st Year Monthly Timeline
- Month 1: Understanding and Preparing
- Begin by studying the DOJ’s Fact Sheet and the Accessible.org ADA Title II Guide to fully understand the ADA Title II web accessibility compliance requirements as well as WCAG 2.1 AA. During these initial months, form your accessibility committee by selecting key personnel from IT, legal, finance, and other relevant departments.
- Appoint an accessibility coordinator to oversee the entire project and act as the main point of communication and accountability.
- Month 1: Budget Planning
- Create a detailed budget that covers all aspects of the ADA Title II compliance project, including audits, remediation, training, and unforeseen costs.
- Month 1: Inventory and Prioritization
- Conduct a detailed inventory of all digital assets, including websites, mobile apps, electronic documents, and any other relevant digital content. Evaluate these assets based on usage and visibility.
- Month 1-3: Training
- Begin WCAG 2.1 AA training for the accessibility committee and extend this training to anyone involved in digital content management and development. This includes web developers, content creators, and marketing teams to ensure everyone understands the accessibility guidelines and their implications.
- Month 3-6: Audit
- With the foundation set, move forward with audits on website(s) and mobile apps(s).
- Month 4-10: Remediation
- Start prioritized remediation. Remediation is completed in the first year for prioritized digital assets. Content remediation will likely continue into Year 2.
- Month 11: Review and Adjust Budget
- Revisit the initial budget estimates based on the costs accrued in the audit and remediation phases. Adjust the budget as necessary to accommodate for the next phases of the compliance journey, ensuring that funds are allocated efficiently.
- Month 12: Documentation and Reporting
- Document all actions taken during the year, from committee decisions and training sessions to audit results and remediation steps. Prepare a detailed report that outlines the progress made, problems encountered, and plans for the following year.
With the first year’s timeline in mind, let’s go over the phases involved in compliance with the new ADA Title II website accessibility rule.
Initial Assessment and Planning
The moment the DOJ made their official ADA Title II press release, the clock began ticking on state and local governments. There should be a sense of urgency to get this project done as soon as possible because waiting even just six months can increase your timeline by a factor of 1.5 or 2.
ADA Title II compliance starts with a thorough understanding of the legal requirements and technical standards. Begin by studying the Department of Justice’s Fact Sheet and the Accessible.org guide. It is crucial to form an accessibility committee early in the process. This committee should ideally include members from IT, legal, and finance departments. An accessibility coordinator should be appointed to lead the project, ensuring that there is a clear point of responsibility.
Inventory and Prioritization
Once your team is familiar with the requirements, take inventory of all digital assets, including websites, mobile apps, and electronic documents. This step is vital for understanding the scope of the project. Prioritization should follow, focusing on assets that are most frequently used and those that pose the highest legal risk if not compliant. This approach helps in allocating resources more effectively, addressing the most critical areas first.
Budgeting
Next, you’ll need to create a budget is a foundational step. Include costs for audits, remediation, training, and ongoing compliance checks. Anticipate higher costs than initial estimates to avoid budget shortfalls. Consider also the long-term costs associated with maintaining WCAG compliance, not just the initial outlay. Planning financially for these expenses well in advance will prevent surprises and ensure that adequate funds are available throughout the compliance process.
Training
Training your team on WCAG 2.1 AA guidelines is essential. This training should start as soon as possible and be comprehensive, including not just the IT staff but anyone involved in content creation and management. Understanding WCAG 2.1 AA will help the team make informed decisions and set a realistic timeline for achieving compliance.
Start Work
Don’t get mired in organizing, budgeting, and training too long. Begin making tangible progress on compliance by sourcing out an audit to a reputable digital accessibility service provider. Following the audit, the next step is to immediately progress into the remediation phase to fix issues reported in the audit. After remediation, conduct a re-audit to ensure full WCAG 2.1 AA conformance.
Continued WCAG 2.1 AA Conformance
Making your website WCAG 2.1 AA conformant is a huge milestone, but maintaining conformance is equally as important. This is where training begins to really pay dividends – your team will be much less likely to introduce accessibility issues because your digital staff is now proficient in accessibility and should now have experience.
Yearly Timeline
Earlier we covered a monthly timeline to hyper focus on where to start immediately, but zooming out, here is a more general timeline for public entities who have three years for compliance.
- Year 1: Organize efforts, form accessibility committee, create accessibility policy, budget, begin training, and start service work as soon as possible.
- Year 2: Complete digital asset remediation and continue to review and refine policies, procedures, processes, and budget. Content and documents should be remediated early in the year. Advance accessibility training to the point where your digital team is not only proficient but gaining real momentum in becoming experts.
- Year 3: Finalize all projects. Hone accessibility integration and processes in place. Reassess costs. Plan on reducing accessibility service budget.
Title II Compliance Services
Do you need help with ADA Title II compliance? Accessible.org provides audit, remediation, and user testing services to ensure your digital assets are WCAG 2.1 AA conformant.
