What the Mandate Requires
DOJ's April 2024 final rule (28 CFR Part 35) requires state and local government entities to ensure that their web content and mobile applications conform to WCAG 2.1 Level AA. Compliance deadlines are staggered by entity population — smaller entities have until April 2027. Entities must also maintain written accessibility policies, document undue burden and fundamental alteration determinations, maintain a grievance procedure and complaint log, and conduct periodic accessibility audits.
| Statutory Reference | Requirement |
|---|---|
| 42 U.S.C. § 12131 | ADA Title II — prohibition on discrimination by public entities on the basis of disability |
| 28 CFR § 35.200 | Web and mobile application accessibility requirements for public entities |
| 28 CFR § 35.204 | WCAG 2.1 Level AA as the applicable technical standard |
| 28 CFR § 35.205 | Specific exceptions including undue burden and fundamental alteration |
| W3C WCAG 2.1 | Web Content Accessibility Guidelines 2.1 — Level AA success criteria and conformance requirements |
Enforcement Authority & Penalties
DOJ enforces ADA Title II directly and through complaint investigation. The DOJ may initiate pattern-or-practice investigations and seek injunctive relief, compensatory damages, and civil penalties up to $107,613 for a first violation and $214,238 for subsequent violations. Private plaintiffs may also sue for injunctive relief. Complaint investigations are handled by the Disability Rights Section of the Civil Rights Division.
What VerdoCo Provides
Each document is delivered in both editable Word (.docx) format — with teal-bracketed fields for your organization's specific data — and a locked, forensically personalized PDF. Your organization's name, authorized representative, transaction ID, and canary reference code are injected into every page at the moment of purchase.
Establishes the foundational digital accessibility program — the written digital accessibility policy, digital asset inventory documenting all web content and mobile applications in scope, WCAG 2.1 Level AA gap analysis, accessibility risk assessment matrix, undue burden and fundamental alteration documentation, and ADA Title II self-evaluation report.
Delivers the operational accessibility compliance infrastructure — active remediation issue tracker with ownership and timelines, monitoring and testing protocol, grievance procedure and complaint log, training matrix and completion log, vendor and procurement accessibility agreement tracker, emergency and crisis communication accessibility plan, and annual compliance report.
Related Regulatory Series
Many organizations subject to VCO-ADA also have obligations under the following frameworks. VerdoCo provides a complete series for each.
VCO-ADA — Ready to Begin?
Select your phase or purchase the complete Command Kit. All documents delivered within minutes — personalized to your organization, forensically protected, and ready to complete.
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