Accessibility & ADA Compliance at N.C. A&T

• Deadline: April 24, 2026.

• Who is Examined: Public entities (state and local governments) with a population of 50,000 or more. (Entities <50,000 have until April 2027).

• The Standard: You are being examined on WCAG 2.1 Level AA.

• The Scope: This standard requires passing exactly 50 Success Criteria. This includes the original 38 criteria from WCAG 2.0, plus 12 new criteria introduced in version 2.1 that specifically target mobile accessibility and low-vision users.

The DOJ does not issue a percentage grade (e.g., "85% compliant"). The legal standard is full compliance, but the final rule includes specific nuances for auditing:

1. Binary Technical Standard: A page technically "fails" if it misses any of the 50 criteria listed below.

2. The "Minimal Impact" Safety Net: The DOJ rule states that a public entity will not be penalized for minor noncompliance if they can demonstrate that the error "does not prevent a person with a disability from enjoying the same access, rights, and benefits."

   • Pass Example: A color contrast ratio of 4.4:1 (instead of 4.5:1) on a footer link that is still legible.

   • Fail Example: A "Submit" button that cannot be reached via keyboard.

3. The 30/70 Audit Rule: Automated tools (like WAVE or Axe) can only detect about 30% of these criteria (mostly programmatic syntax). The remaining 70% (such as logical focus order, meaningful error messages, and consistent navigation) requires manual human testing.

Criteria marked with 🆕 are the 12 additions in WCAG 2.1 that were not present in 2.0.

Principle 1: Perceivable

Information and UI components must be presentable to users in ways they can perceive.

Principle 2: Operable

User interface components and navigation must be operable.

Principle 3: Understandable

Information and the operation of user interface must be understandable.

Principle 4: Robust

Content must be robust enough that it can be interpreted reliably by a wide variety of user agents.

Note on 4.1.1 Parsing: While modern browsers often correct parsing errors automatically (leading to this rule being deprecated in the newer WCAG 2.2), the DOJ law specifically cites WCAG 2.1. Therefore, you must technically still pass 4.1.1, though many auditors treat it lightly under the "Minimal Impact" rule.

The DOJ rule includes five specific exceptions where content does not need to be remediated by April 2026:

1. Archived Web Content: Content meant only for reference/research, not updated, and clearly marked as archived.

2. Pre-existing Electronic Documents: PDFs, Word docs, etc., posted before April 24, 2026, unless they are currently being used to apply for or participate in a service/program.

3. Third-Party Content: Content posted by others (e.g., public comments) that isn't under the entity's control/contract.

4. Individualized Password-Protected Docs: Documents securely shared with a specific person (e.g., a water bill or medical record).

5. Pre-existing Social Media Posts: Posts made before the deadline.

1. The Official DOJ Mandate (Title II Rule)

• Primary Source: ADA.gov: Fact Sheet on the New Rule

  • This is the most readable official summary from the DOJ, outlining the April 2026 deadline, the population thresholds, and the exceptions.

• The Full Legal Text: Federal Register: Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services

  • This is the binding legal document published in the Federal Register (Vol. 89, No. 79).

2. The Technical Standard (WCAG 2.1)

• The Full Standard: W3C WCAG 2.1 Recommendation

  • This is the technical manual for the 50 success criteria. The DOJ rule incorporates this specific document by reference.

• Quick Reference Guide: How to Meet WCAG (Quick Reference)

  • A filterable W3C tool that allows you to select "WCAG 2.1" and "Level AA" to see exactly what is required.

3. Implementation Guidance

• Small Entity Guide: ADA.gov: Small Entity Compliance Guide

  • Specific guidance for local governments with populations under 50,000 (who have until 2027) and smaller special districts.