An ADA Title II website compliance checklist is a governance framework that helps public agencies document audits, remediation, monitoring, and accountability required for defensible digital accessibility.
This is the checklist public agency IT directors, web managers, and leadership teams actually need. Not a list of WCAG technical criteria. Not a developer-facing code review framework. A governance checklist — the operational items that determine whether your agency has a defensible ADA compliance program or just a website that may or may not have had some accessibility work done at some point.
The distinction matters because ADA Title II enforcement evaluates both. Technical accessibility of the digital environment matters. The existence of a documented, structured, ongoing governance program matters at least as much. Agencies that can demonstrate both are in a fundamentally stronger position than agencies that have done informal remediation work with nothing to show for it.
This checklist is organized into nine categories that together constitute a complete public agency accessibility governance program. Each item links to deeper guidance where it exists in the Hounder resource hub. Work through it sequentially if you are starting from scratch. Use it as an audit of your current program if you have existing work in place.
Print it. Bring it to a leadership meeting. Use it to show your boss exactly where your agency stands and exactly what needs to happen next.
Quick ADA Title II Compliance Checklist
- Assign an accessibility program owner
- Publish an accessibility policy
- Publish an accessibility statement
- Conduct a baseline WCAG audit
- Establish a remediation log
- Fix high-risk service workflows
- Implement a PDF accessibility strategy
- Review vendor accessibility compliance
- Establish ongoing monitoring and reporting
How to Use This Checklist
Each item is labeled as one of three types and those labels appear on every item throughout the checklist.
[Foundation] items are the non-negotiable starting points. Nothing else in the program is defensible without these in place. If you are starting from scratch, address every Foundation item before moving to anything else. These are what enforcement bodies look at first.
[Governance] items are the ongoing operational structures that sustain compliance over time. These are what transform a completed project into a running program. They define ownership, set standards, and create the institutional architecture that makes compliance person-independent.
[Maintenance] items are the recurring activities that keep the program current and the documentation record growing. These are what enforcement bodies look for when they evaluate whether a compliance program is real or theoretical. A program with strong Foundation and Governance but no Maintenance is a program that peaked on day one and has been drifting ever since.
For each item, mark your status: Complete | In Progress | Not Started | Not Applicable
Category 1: Governance Ownership
A compliance program without a named owner is not a compliance program. It is a shared hope that someone will handle things when a question arises. Governance ownership defines who is responsible, at what level, and for what.
[Foundation] 1.1 Accessibility coordinator or program owner assigned A named individual or role with explicit responsibility for the agency's digital accessibility compliance program. This person does not need to be a WCAG technical expert. They need to be the accountable owner who ensures that monitoring happens, that the remediation log stays current, that vendor reviews occur, and that executive reporting gets delivered. The role should be documented — in a job description, in the governance framework, or in a formal policy — not just understood informally.
Status: ___
[Governance] 1.2 Department-level accessibility responsibilities defined Each department that publishes content to the agency website or uploads public documents needs a named content owner with documented accessibility responsibilities. Decentralized publishing without distributed accountability is one of the primary drivers of compliance drift in public agencies. The department coordinator who uploads board agendas needs to know that accessible document creation is part of their job function, not a request from IT.
Status: ___
[Governance] 1.3 IT and web team accessibility responsibilities documented Beyond the program coordinator, the web and development team needs explicit documented responsibilities: template accessibility maintenance, monitoring execution, remediation log management, vendor testing. These should not exist as informal understanding. They should be in writing.
Status: ___
[Governance] 1.4 Executive-level accountability established A named executive — city manager, CIO, department director, or equivalent — who receives regular accessibility reporting and is accountable for organizational compliance posture. Executive visibility is what sustains budget and organizational attention through staff turnover and competing priorities. It also creates the reporting record that demonstrates institutional accountability in enforcement proceedings.
Status: ___
Related resource: Hounder's ADA Governance Roles Guide
Category 2: Policy and Public Commitment
A policy is the organizational foundation of the compliance program. Without it, every other governance element lacks the institutional authority to function across departments.
[Foundation] 2.1 Formal digital accessibility policy adopted A written policy, formally adopted by the relevant authority — city council, county board, university board of trustees, or executive order — that defines the agency's commitment to digital accessibility, identifies the governing standard (WCAG 2.1 AA), assigns governance responsibilities, and establishes the scope of the policy across all agency digital properties including third-party embedded tools and departmental subdomains.
The policy does not need to be long. It needs to be specific, formally adopted, and accessible to all staff who publish content or make technology decisions.
Status: ___
[Maintenance] 2.2 Policy reviewed and updated within the past 24 months An outdated policy that references superseded standards or does not account for the DOJ's 2024 final rule is a liability rather than an asset. The policy should be reviewed on a defined schedule and updated when regulatory guidance changes.
Status: ___
Related resource: Good Faith Compliance Explained
Category 3: Accessibility Statement
The accessibility statement is the public-facing documentation of your agency's commitment and current compliance posture. It is frequently the first thing enforcement bodies look for. It is required, not optional.
[Foundation] 3.1 Accessibility statement published on the agency website A public accessibility statement must be published on the primary agency website and be reachable from the homepage — typically linked in the footer. The statement must be accessible itself, meaning it must meet the same WCAG 2.1 AA standards it references.
The statement should include: the standard the agency is working toward (WCAG 2.1 AA), the date it was last reviewed, a description of known limitations and what the agency is doing to address them, contact information for reporting accessibility barriers, and the complaint intake process.
Status: ___
[Foundation] 3.2 Statement includes a working accessibility complaint contact The contact information in the accessibility statement — email address, phone number, or online form — must be functional and monitored. A statement with a broken email address or an unmonitored inbox is worse than no statement, because it documents the existence of a complaint process that does not actually work.
Status: ___
[Maintenance] 3.3 Statement reviewed and updated within the past 12 months An accessibility statement that has not been updated in years signals that the compliance program is not active. The review date on the statement should reflect the currency of the compliance posture it describes.
Status: ___
[Governance] 3.4 Statement linked from every primary website property For agencies with multiple subdomains, departmental sites, or microsites, the accessibility statement should be accessible from each property — either through a direct link or a link back to the primary institutional statement with clarification of scope.
Status: ___
Related resource: How to Write an ADA Accessibility Statement for Government Websites
Category 4: Baseline Audit
The audit is the foundation of the documentation record. Without it, the agency cannot demonstrate that it assessed its compliance posture, prioritized issues intelligently, or made any remediation decisions based on actual findings.
[Foundation] 4.1 Comprehensive accessibility audit completed within the past 18 months A governance-focused audit that covers the primary website templates, core transactional workflows, a representative sample of the document library, and embedded third-party tools. Not an automated scan report only. A real audit that includes manual testing of transactional workflows with keyboard navigation and screen reader software.
If the last audit is more than 18 months old, the baseline no longer accurately reflects the current state of the digital environment. A new audit is needed.
Status: ___
[Foundation] 4.2 Audit findings documented by WCAG criterion and severity The audit report needs to map every finding to its specific WCAG 2.1 AA success criterion and classify it by severity — critical, major, or minor — with the operational risk layer that distinguishes high-impact service barriers from low-risk cosmetic issues.
Status: ___
[Foundation] 4.3 Audit scope includes transactional workflows The permit application, payment portal, public records request system, license renewal, and any other workflow residents must complete to access government services must be specifically included in the audit scope. Homepage-only or top-page audits miss the highest-risk surfaces.
Status: ___
[Foundation] 4.4 Audit scope includes document sampling A representative sample of publicly accessible PDFs classified by type — active service forms, meeting documents, regulatory publications, archival content — with accessibility findings documented for each category.
Status: ___
[Governance] 4.5 Audit scope includes vendor and third-party tool review Every embedded third-party tool — payment gateway, permit portal, scheduling system, GIS tool, chat widget — reviewed for WCAG 2.1 AA conformance with VPAT documentation requested and on file.
Status: ___
Related resource: How to Conduct a WCAG 2.1 AA Audit for a Public Agency
Category 5: Remediation Log
The remediation log is the primary evidence document of the compliance program. It is what transforms remediation activity into a defensible record.
[Foundation] 5.1 Centralized remediation log established and active A single, centralized log covering all agency digital properties — not siloed by department or system — with standardized fields and a named owner responsible for maintaining it. The log must be active, meaning entries are being added as issues are identified and addressed, not updated periodically in batches.
Status: ___
[Foundation] 5.2 Log includes required fields for each entry Each entry captures: unique issue ID, date identified, source of identification, WCAG criterion reference, risk classification, affected page or template, plain-language description, remediation plan, assigned owner, date remediated, validation method, and verification date. Entries without timestamps or without validation records are incomplete.
Status: ___
[Maintenance] 5.3 Log is reviewed monthly The remediation log should be reviewed by the program owner monthly to confirm entries are current, validate that completed remediations have been tested and confirmed, and identify any patterns or priority shifts in outstanding issues.
Status: ___
[Maintenance] 5.4 Log is archived and maintained long-term The full history of the remediation log — from the baseline audit forward — should be preserved and accessible. Enforcement inquiries can reference events that occurred years in the past. The historical record is what demonstrates sustained effort over time.
Status: ___
Related resource: How to Build an Accessibility Remediation Log That Protects Your Agency
Category 6: High-Risk Workflow Remediation
The audit tells you where the highest-risk barriers are. This category tracks whether those barriers have been addressed in the order they should be.
[Foundation] 6.1 Transactional workflows tested with keyboard navigation Every core service workflow — permit application, payment portal, public records request, license renewal, scheduling system — tested end-to-end using keyboard-only navigation. Tab order verified. Focus indicators confirmed visible. No keyboard traps identified.
Status: ___
[Foundation] 6.2 Transactional workflows tested with screen reader Core workflows tested using NVDA on Windows and/or VoiceOver on macOS. Form fields confirmed labeled and announced correctly. Error messages confirmed programmatically announced. Confirmations confirmed accessible.
Status: ___
[Foundation] 6.3 Critical form barriers remediated Unlabeled form fields corrected. Inaccessible error messaging fixed. Keyboard traps resolved. Date picker and custom component accessibility validated. These are the fixes that most directly prevent residents from completing government service transactions.
Status: ___
[Foundation] 6.4 Template-level navigation issues resolved Skip navigation links implemented. Focus indicators visible on all interactive elements. Tab order logical and consistent. Global navigation keyboard accessible including any dropdown submenus. These fixes affect every page on the site.
Status: ___
[Foundation] 6.5 Color contrast failures remediated on primary content areas Primary body text, navigation text, button and call-to-action text, and form element text confirmed meeting WCAG 2.1 AA contrast ratios. Template-level contrast fixes implemented.
Status: ___
Related resource: ADA Risk Triage: If You Only Fix 5 Things, Fix These
Category 7: PDF and Document Strategy
Documents are the most consistently underestimated source of ADA compliance exposure in public sector environments. This category addresses both the backlog and the going-forward standard.
[Foundation] 7.1 Document inventory completed A comprehensive inventory of all publicly accessible PDFs and downloadable documents on all agency digital properties. Classified by type — active service forms, meeting documents, regulatory publications, archival content — and by accessibility status.
Status: ___
[Foundation] 7.2 High-priority documents identified and remediation queued Based on the inventory: active service forms, public notices, current meeting agendas, and any document required for public participation have been identified as the highest priority for remediation and are in an active remediation queue with assigned ownership and timelines.
Status: ___
[Governance] 7.3 Scanned PDFs identified and OCR processing initiated Scanned flat-image PDFs identified in the inventory. OCR processing and accessibility tagging in progress for all high-priority scanned documents. A plan for addressing the lower-priority scanned document backlog documented.
Status: ___
[Governance] 7.4 Accessible document creation standards distributed Written standards for accessible document creation distributed to all staff who create or upload documents. Standards cover: accessible export settings in Word, PowerPoint, and Google Docs; heading structure requirements; alternative text for embedded images; table header associations; reading order for multi-column layouts.
Status: ___
[Maintenance] 7.5 Pre-upload accessibility review process established A documented process for reviewing new documents against accessibility standards before they are published. For high-volume publishing environments, this may be a self-certification checklist. For high-visibility documents, a peer or coordinator review.
Status: ___
Related resource: Where Public Agencies Are Most Exposed Under ADA Title II
Category 8: Procurement and Vendor Governance
Vendor tools represent one of the most commonly unmanaged sources of ADA compliance exposure. This category addresses both the existing vendor portfolio and the going-forward procurement process.
[Foundation] 8.1 Vendor VPAT inventory completed Current VPAT documentation collected and on file for every third-party tool embedded in the agency's digital environment. For tools that cannot produce a current VPAT, the accessibility gap is documented and either an accessible alternative is in place or remediation is being pursued through the vendor relationship.
Status: ___
[Governance] 8.2 Accessibility requirements in new vendor contracts All new contracts for vendor tools that touch the agency's digital public-facing services include explicit accessibility requirements — WCAG 2.1 AA conformance expectation, notification obligations when updates introduce regressions, and remediation timelines with defined accountability. Accessibility is evaluated as a scored criterion in RFP processes.
Status: ___
[Governance] 8.3 Existing vendor contracts reviewed for accessibility provisions Existing vendor contracts for embedded tools reviewed for accessibility language. Contracts without provisions identified. Renewal opportunities flagged for accessibility requirement insertion. Vendor relationships without contract coverage documented as open compliance exposure.
Status: ___
[Maintenance] 8.4 Vendor tools tested after major platform updates A defined process for testing embedded vendor tools after major platform releases. The person responsible for initiating retesting is named. The tools covered are listed. The testing cadence is documented.
Status: ___
Related resource: What DOJ Scrutiny Actually Looks Like for Public Agencies
Category 9: Ongoing Monitoring and Reporting
Monitoring is what catches regression. Reporting is what creates organizational accountability. Neither is optional in a governance-grade compliance program.
[Maintenance] 9.1 Automated monthly monitoring scans implemented Automated accessibility scans running on a monthly schedule across the primary website and key subdomains. Scan results reviewed by the program owner — not just generated and archived. Findings triaged and fed into the remediation queue.
Status: ___
[Maintenance] 9.2 Manual QA cadence established for core workflows Quarterly manual QA of core transactional workflows using keyboard navigation and screen reader testing. Results documented and added to the monitoring record. Failures that emerge through monitoring logged in the remediation log.
Status: ___
[Maintenance] 9.3 Monitoring history archived All scan results, manual QA records, and monitoring reports archived in a format that can be produced in response to a documentation request. The monitoring history is part of the compliance record.
Status: ___
[Maintenance] 9.4 Quarterly executive reporting delivered A quarterly accessibility status report delivered to relevant executive leadership — covering current compliance posture, remediation progress, risk trends, monitoring results, and outstanding items. Records of report delivery and leadership acknowledgment maintained.
Status: ___
[Foundation] 9.5 Complaint intake and response process documented A written process for receiving, logging, investigating, and responding to accessibility complaints from the public. Named owner. Defined response timeline. Documentation of every complaint received, what was found, what was done, and how the complainant was notified of the outcome.
Status: ___
[Governance] 9.6 Staff training documented Records of accessibility training completed by content editors, web staff, developers, and relevant leadership. Training topics, dates, and completion rates documented. A refresher cadence defined for new hires and recurring annual updates.
Status: ___
Related resources: ADA Compliance as Infrastructure, Not a Project | 90-Day ADA Stabilization Roadmap for Public Agencies
The Checklist Summary: Where Does Your Agency Stand?
Count your responses.
If most items are Complete: Your agency has a governance-grade compliance program. The priority is maintaining the monitoring cadence, keeping documentation current, and ensuring the executive reporting record grows. Schedule a program review every 12 to 18 months.
If most items are In Progress: Your agency has started the right work. The priority is closing out foundation items first — the audit, the accessibility statement, the remediation log — before expanding into governance and maintenance items. Consider whether a governance retainer would accelerate completion and sustain the program going forward.
If most items are Not Started: Your agency's current compliance posture is unknown and indefensible under scrutiny. The starting point is a baseline audit and the 90-day stabilization roadmap. Start there. Do not try to address all nine categories simultaneously from a standing start.
A Note on Prioritization
This checklist has 31 items across nine categories. No agency starting from scratch addresses all 31 simultaneously. The sequence that creates the most defensibility in the shortest time is:
First, establish governance ownership so there is a named person driving the program. Second, conduct the baseline audit so the program is built on actual knowledge of the compliance posture rather than assumptions. Third, open the remediation log and start documenting from day one. Fourth, publish the accessibility statement so the public-facing commitment exists. Fifth, address the highest-risk transactional workflow barriers identified in the audit. Then build outward from there into document strategy, vendor governance, and monitoring.
That sequence produces a defensible program faster than working through the checklist in the order it is written.
The Recommended Sequence If You Are Starting From Scratch
This checklist has 31 items across nine categories. The sequence that creates the most defensibility in the shortest time is not the order the checklist is written in. It is this:
Week 1: Assign governance ownership (1.1). Initiate the baseline audit (4.1 through 4.5). Open the remediation log (5.1, 5.2).
Month 1: Receive audit findings. Build the risk-based prioritization model. Begin remediating the highest-risk transactional workflow barriers (6.1 through 6.5). Publish the accessibility statement (3.1, 3.2). Brief executive leadership.
Month 2: Execute template-level fixes. Launch the document inventory and accessible document standards (7.1 through 7.4). Complete vendor VPAT review (8.1). Begin staff training (9.6).
Month 3: Implement monthly monitoring (9.1). Formalize the governance framework — department responsibilities (1.2, 1.3), policy (2.1), vendor contract language (8.2). Deliver the first executive report (9.4). Document the complaint intake process (9.5).
Ongoing: Monthly scans (9.1). Quarterly manual QA (9.2). Quarterly executive reports (9.4). Annual policy and statement review (2.2, 3.3). Vendor post-update testing (8.4). Pre-upload document review (7.5).
Using This Checklist With Leadership
This checklist is designed to travel. Print it. Bring it to a budget conversation. Bring it to a council or board presentation. Use it to show the specific, concrete items that constitute a real compliance program rather than asking for resources to address an amorphous "ADA compliance problem."
Leadership who can see exactly what is complete, what is in progress, and what is not started have a much clearer basis for resource allocation decisions than leadership who are asked to fund accessibility in general. The checklist turns a compliance conversation into an operational conversation — which is the conversation that gets resourced.
FAQ: ADA Title II Compliance Checklist for Public Agencies
What does ADA Title II require for public agency websites? ADA Title II requires state and local government agencies to provide equal access to their programs, services, and activities — including digital services — to individuals with disabilities. The DOJ's 2024 final rule establishes WCAG 2.1 Level AA as the technical standard for digital accessibility. In practice, compliance requires a documented governance program including a baseline audit, risk-based prioritization, ongoing remediation, continuous monitoring, and executive accountability — not just a website that has had some accessibility work done. We actually wrote a whole blog about this... check it out: What ADA Title II Requires for Public Agencies by April 24th, 2026
Is there an official ADA Title II compliance checklist for government agencies? The DOJ has not published a specific checklist, but the documentation it requests in enforcement proceedings reveals what a complete compliance program requires. That documentation consistently includes: an accessibility policy, a published accessibility statement, a dated baseline audit, a remediation log with timestamps, monitoring records, vendor accessibility documentation, training records, and executive reporting history. This checklist is organized around those requirements and the governance structures that produce them.
What is the most important first step in ADA Title II compliance for public agencies? Assigning a named governance owner and conducting a baseline audit are the two most critical starting points. Without an owner, nothing is accountable. Without an audit, nothing is known. An agency that has both — a named program owner and a documented understanding of where its compliance exposure actually lives — has the foundation that every other compliance activity is built on. The 90-day stabilization roadmap provides a practical sequencing of steps from that foundation.
How often should public agencies conduct accessibility audits? A comprehensive accessibility audit should be conducted at least every 18 months, with interim monitoring through monthly automated scans and quarterly manual QA of core transactional workflows. The 18-month audit cycle ensures the baseline documentation reflects the current state of the digital environment, which changes continuously through content updates, vendor changes, and platform modifications. Agencies that have not had a formal audit in more than 18 months are working from an outdated or nonexistent compliance baseline.
What is an accessibility statement and do all public agencies need one? An accessibility statement is a public-facing document published on the agency website that identifies the accessibility standard the agency is working toward, describes known limitations and remediation efforts, provides contact information for reporting accessibility barriers, and describes the complaint response process. All public agencies covered under ADA Title II should publish an accessibility statement. It is one of the first items enforcement bodies look for when evaluating a compliance program and one of the simplest, highest-value governance items to have in place.
How does a public agency demonstrate good faith ADA compliance? Good faith compliance is demonstrated through a documented record of structured, ongoing effort — not through claims or intentions. The specific documentation that demonstrates good faith includes a dated baseline audit, a risk-based prioritization framework, a timestamped remediation log, monitoring records, training documentation, vendor review records, and executive reporting history. An agency that can produce this documentation has built the compliance narrative that enforcement proceedings evaluate. An agency that cannot produce it — regardless of how much informal accessibility work has been done — cannot demonstrate good faith in any verifiable way.