Is Your Website ADA Compliant? A Guide to WCAG 2.2
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TL;DR:
Most websites are not fully ADA compliant. There’s no formal certification, but courts and demand letters measure your site against WCAG 2.2 at the AA level, and gaps like missing alt text, low color contrast, and keyboard traps show up even on well-designed sites. This guide walks through what WCAG 2.2 actually requires and how to find out where your specific site stands.
What ‘ADA Compliant’ Actually Means for a Website
The Americans with Disabilities Act was written in 1990, long before most businesses had websites, so it never spelled out a technical standard for digital accessibility. Courts have filled that gap by treating the Web Content Accessibility Guidelines, known as WCAG, as the practical benchmark. When a lawsuit or demand letter alleges that a website isn’t accessible, it’s almost always measuring the site against WCAG 2.1 or 2.2 at the AA conformance level, even though the ADA itself never mentions WCAG by name.
There’s no government body that hands out an “ADA compliant” seal for a business website. What exists instead is a body of case law and DOJ guidance that treats WCAG AA as the working definition of accessible. A restaurant’s online ordering page, a law firm’s contact form, a healthcare practice’s patient portal: all of it falls under the same general expectation, that someone using a screen reader, a keyboard instead of a mouse, or a switch device should be able to use your site to get what they need.
For public entities, the rules are more explicit. The Department of Justice’s 2024 Title II rule required state and local government websites to meet WCAG 2.1 AA, though an interim rule issued in April 2026 pushed those deadlines back a year, to April 2027 for larger jurisdictions and April 2028 for smaller ones. Private businesses fall under Title III instead, and there’s no equivalent federal rule with a specific deadline. That absence of a bright line is part of what makes this confusing for business owners, and part of why lawsuits keep filling the gap where regulation hasn’t.
Why This Isn't Just a 'Big-Company' Problem
It’s tempting to assume this only affects national retailers with deep pockets and complicated e-commerce platforms. The numbers say otherwise. According to Seyfarth Shaw’s annual tracking, 3,117 federal website accessibility lawsuits were filed in 2025, up 27% from 2024, and website claims now make up roughly ⅓ of all ADA Title III filings. On top of that, tens of thousands of demand letters go out every year that never turn into a filed lawsuit, but still cost businesses legal fees and remediation work to resolve.
We’ve seen this play out with clients across very different industries: a Richmond area contractor whose booking form couldn’t be operated by keyboard alone, a nonprofit whose donation page had color contrast too low for low-vision visitors to read, a retail client whose product images had no alt text at all. (None of these businesses were intentionally trying to exclude anyone.)
The DOJ’s own position is that Title III applies to almost any business that serves the public, regardless of size, and there’s no small business carve-out written into the statute. That doesn’t mean every small business gets sued. It means size alone isn’t protection, and the businesses getting targeted are often selected because a scan turned up easy, visible violations rather than because of anything unique about the company.
What WCAG 2.2 Actually Changed
WCAG 2.1, published in 2018, is still the version most courts cite directly, largely because it’s the version the DOJ’s Title II rule formally adopted. WCAG 2.2, released by the W3C in October 2023, is the current standard, and it’s backward compatible: if your site already meets 2.1 AA, you only need to address the newer criteria to be fully current. WCAG 2.2 added nine new success criteria and removed one, the old parsing requirement, because modern browsers and screen readers handle imperfect HTML well enough that it stopped being a meaningful accessibility signal.
It’s worth noting:
Focus Not Obscured requires that when someone tabs through your site with a keyboard, the element currently in focus can’t be hidden behind a sticky header, a cookie banner, or a chat widget. This is one of the single most common failures we see, because sticky navigation and popup consent banners are everywhere and almost nobody tests what happens when a keyboard user tabs behind them.
Target Size requires that clickable elements, buttons, and links be at least 24×24 CSS pixels, or have enough spacing around them that a person with limited fine motor control can tap the right one. Mobile menus and icon-only buttons are frequent offenders here.
Consistent Help and Redundant Entry are aimed at reducing cognitive load, requiring that help mechanisms like a chat link or contact info appear in the same place across pages, and that users aren’t forced to re-enter information they already provided earlier in a multi-step form, like a quote request or appointment booking flow.
Where Most Small Business Websites Fail
In practice, the failures we run into most often are simple, high-frequency issues: images without alt text, form fields without visible labels, color combinations that don’t meet the 4.5:1 contrast ratio WCAG requires for normal text, video content with no captions, and interactive elements that only work with a mouse.
A law firm’s intake form that can’t be completed with a keyboard alone will fail an audit just as surely as a missing alt tag will, and both are common on sites built years ago on page builders that were never designed with accessibility in mind.
The other pattern we see is businesses that assume their website platform handles this automatically. WordPress, Squarespace, and similar platforms give you the tools to build an accessible site, but they don’t enforce it. A theme can be technically compliant out of the box and still end up inaccessible once a business owner adds custom fonts, low-contrast brand colors, or a booking widget from a third-party vendor that wasn’t built with WCAG in mind.
What to Do About It
Start with an in-depth technical audit rather than a guess. Automated scanning tools can catch a meaningful chunk of issues, roughly a third to half of common WCAG failures, but they miss things that require a human to evaluate, like whether alt text actually describes an image usefully or whether a form makes sense when read aloud by a screen reader. A combination of automated scanning and manual review, ideally including someone who actually uses assistive technology, gives you a realistic picture of where you stand.
From there, prioritize fixes based on both legal exposure and actual user impact. Missing alt text, poor color contrast, and keyboard traps tend to be quick wins that meaningfully reduce risk.
Deeper structural issues, like a checkout flow that can’t be completed without a mouse, take more time but matter more to the people who actually run into them.
If you want a starting point, our team can run a website quality audit that flags accessibility gaps alongside performance and SEO issues, since the two are more connected than people expect: a site structured well enough for a screen reader to parse is usually a site Google can crawl and understand more easily too.
Not sure how your site would hold up if someone filed a demand letter tomorrow?
We run website audits that flag accessibility gaps.
Documentation matters here too! Keep a record of the audits you run, the fixes you make, and the date you made them. If a demand letter does show up, being able to show a documented, ongoing effort toward accessibility puts you in a meaningfully better position than having nothing to point to, even if your site isn’t perfect.
Accessibility work isn’t a one-time project you finish and forget. Every new blog post, every new landing page, every new form you add is a chance to reintroduce an issue you already fixed once.
Building accessibility checks into your regular website maintenance, the same way you’d handle broken links or outdated plugins, is what actually keeps a site compliant over time rather than compliant for one audit and drifting after that.
This is also a place where good web design pays for itself twice. A site built with semantic HTML, proper heading structure, real form labels, and sufficient contrast from the start is both more accessible and easier to maintain, update, and optimize for search.
Ready to find out where your website actually stands?
Reach out to our team at FreshMove Media for a free exploratory meeting, and we’ll walk through what an accessibility check would look like for your unique website.
Do I need to be fully WCAG 2.2 AA compliant to avoid a lawsuit?
There's no federal rule that says a private business must hit 100% conformance, and no single number guarantees safety from a lawsuit. What courts and settlements generally look for is a good faith, ongoing effort toward WCAG 2.1/2.2 AA, meaning you've identified issues, you're actively fixing them, and you're not ignoring known problems.
Can I just install a widget that claims to make my site ADA compliant?
These tools alleviate surface issues but do not fix any underlying website code, and some untrusted widgets can interfere with the assistive technology. They're not a 100% substitute for audits and remediations, though some can be a reasonable supplement. Finding an ADA widget provider that provides legal support if needed, ADA documentation, and custom tools to fit your business and your customers is the way to go if deciding to use one of these widgets.