The technical standard · Written into 28 CFR §35.200
What Is WCAG 2.1 AA? A Plain-English Guide for Public Agencies
Last updated June 11, 2026
The ADA Title II web rule requires your websites and mobile apps to meet something called WCAG 2.1 Level AA. If that phrase means nothing to you, you are in the right place. This page explains what the standard actually asks for, in language written for administrators, not developers.
The Short Version
WCAG stands for Web Content Accessibility Guidelines. It is a set of testable requirements for making websites, apps, and documents usable by people with disabilities, published by the World Wide Web Consortium (W3C), the organization that maintains web standards. Version 2.1 came out in 2018 and has been the working standard for accessibility professionals ever since.
In April 2024, the Department of Justice wrote WCAG 2.1 Level AA directly into the Title II regulations at 28 CFR §35.200. That made it the first specific technical standard ever placed in the ADA's state and local government rules. Your entity's deadline to meet it is either April 26, 2027 or April 26, 2028, depending on your population. Check your deadline here.
What A, AA, and AAA Mean
Every WCAG requirement, called a success criterion, is assigned one of three levels. Think of them as floors of a building.
- Level A is the ground floor. These are the basics without which some people cannot use your site at all. Example: video content needs captions for prerecorded audio.
- Level AA is the standard floor. It includes everything in Level A plus requirements that remove the most common, most serious barriers. Example: text needs enough contrast against its background to be readable. This is the level DOJ chose.
- Level AAA is the penthouse. It is the most demanding level, and even the W3C says it is not achievable for all content. The rule does not require it.
When the rule says WCAG 2.1 AA, it means all of Level A plus all of Level AA: 50 success criteria in total. DOJ picked this level because it is the same target used by the federal government's own Section 508 standard, it is widely supported by tools and testing services, and years of court settlements had already made it the de facto benchmark. The department chose a bar that was demanding enough to matter and established enough to be practical.
What WCAG 2.1 AA Asks of Your Website, in Human Terms
You do not need to memorize 50 criteria. Most of the standard comes down to nine practical ideas.
- Text alternatives. Every meaningful image needs a short written description, called alt text, so that a person using a screen reader knows what the image shows. A photo of the new fire station needs words. A purely decorative border does not.
- Keyboard access. Everything a mouse can do, a keyboard must be able to do. Many people with motor disabilities, and all screen reader users, navigate with the Tab key instead of a mouse. If your permit application traps keyboard users halfway through, it fails.
- Color contrast. Text has to stand out clearly from its background. Light gray text on white, or gold on pale yellow, can be unreadable for people with low vision. Contrast is measured with free tools, so this is one of the easiest things to check.
- Captions. Prerecorded videos need accurate captions, and live video, like a streamed council meeting, needs live captions. Auto-generated captions are a starting point, but someone has to fix the errors. "Bored meeting" is not the same as "board meeting."
- Forms and labels. Every field on a form needs a label that screen readers can announce, so a resident knows whether the box they are typing in wants a name, an address, or an account number. This applies to everything from contact forms to utility payments.
- Headings and structure. Pages need real headings, marked up in the code, not just bold text. Screen reader users skim a page by jumping from heading to heading, the same way sighted users skim visually. Good structure helps everyone, including search engines.
- Accessible PDFs and documents. Documents posted on your site count as web content. A scanned PDF is just a photograph of paper, and a screen reader finds nothing in it. Documents need real, selectable text, a logical reading order, and tags that convey structure.
- Clear error messages. When someone makes a mistake on a form, the site has to say what went wrong and where, in text. A field that simply turns red tells a blind user nothing, and tells a colorblind user very little.
- Mobile usability. WCAG 2.1 added requirements for phones and tablets: content must work in portrait and landscape, text must be able to enlarge without breaking the page, and controls must not depend on complex gestures alone.
Where the Standard Lives in the Regulation
The requirement appears in Subpart H of 28 CFR Part 35, the web and mobile accessibility subpart added by the 2024 final rule. Section 35.200 sets the WCAG 2.1 AA requirement and the two deadlines. Section 35.201 lists the five narrow exceptions, and 35.202 covers conforming alternate versions.
The rule incorporates WCAG 2.1 (June 5, 2018) by reference. 89 FR 31320, April 24, 2024.
Common Questions
Do I need to read the actual WCAG document?
Probably not. WCAG is written for developers and testers. As an administrator, you need to know what it covers, who on your team is responsible, and how to ask vendors the right questions. Leave the success criteria numbers to the people doing the technical work.
Is WCAG 2.1 AA a law?
WCAG itself is a voluntary standard published by the W3C. But the DOJ's 2024 Title II rule adopted WCAG 2.1 Level AA as the legal technical standard for state and local government web content and mobile apps, in 28 CFR 35.200. For public entities, meeting it is now a regulatory requirement.
What about WCAG 2.2 or WCAG 3.0?
The rule names WCAG 2.1 AA specifically. Newer versions like 2.2 build on 2.1, so meeting them generally satisfies the older version too. The rule's equivalent facilitation provision allows newer or alternative standards that provide equal or greater accessibility. If your team works to 2.2 AA, that is a safe path.
Does WCAG 2.1 AA apply to our PDFs and documents?
Yes. Documents posted on your website, including PDFs, Word files, spreadsheets, and presentations, are web content under the rule. There is a limited exception for certain preexisting documents, but anything currently used to apply for or access your services must be accessible.
How do we find out if our website meets WCAG 2.1 AA?
Start with an automated scan to surface the most common problems, like missing alternative text, low contrast, and unlabeled form fields. Then have a person test the high-traffic pages with a keyboard and a screen reader. Automated tools catch roughly a third of issues, so a real assessment combines both.
Want to know how your site measures up?
The standard is testable, which means your gap is measurable. An assessment against WCAG 2.1 AA tells you exactly what to fix and in what order, before the deadline decides for you.