Member Services

Accessibility 2.0

Digital accessibility ensures that websites, applications, documents, and online services are usable by individuals with disabilities. This includes people who rely on assistive technologies such as screen readers, voice navigation, or keyboard-only interaction.

For public entities in California, accessibility is not optional. It is a legal requirement under federal and state law, and it is increasingly being enforced in the context of digital services.

This resource library is designed to:

  • Provide a clear understanding of applicable laws and regulations
  • Point to authoritative technical standards
  • Offer free training resources
  • Provide practical tools and templates to support implementation

Disclaimer: This library is informational and does not constitute legal advice. Members should consult legal counsel to evaluate how requirements apply to their specific organization. This page contains links to external websites for informational purposes only. We do not control, endorse, or assume responsibility for the content, accuracy, suitability, or accessibility compliance of these external resources. Users access and rely on such third-party content at their own risk.

A. Federal Requirements

Americans with Disabilities Act (ADA) – Title II

Applies to state and local governments and requires equal access to programs, services, and activities, including those delivered digitally.

Learn more about ADA Title II requirements

U.S. Department of Justice (DOJ) Final Rule (2024) – Digital Accessibility

The U.S. Department of Justice adopted WCAG 2.1 Level AA as the required technical standard for web content and mobile applications.

  • Applies to websites, web applications, and mobile apps
  • Establishes compliance timelines based on entity size
    • April 24, 2026: Public entities serving 50,000 or more people
    • April 26, 2027: Public entities serving fewer than 50,000 and all special district entities

Read the 2024 DOJ digital accessibility final rule

Read the DOJ's Fact Sheet:  New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments

Read the DOJ's Small Entity Compliance Guide

Section 504 of the Rehabilitation Act

Applies to entities receiving federal financial assistance and requires nondiscrimination on the basis of disability.

Read Section 504 regulations

Section 508 of the Rehabilitation Act

Applies directly to federal agencies but is widely used as a benchmark and is referenced in California law for electronic and information technology.

Learn more about Section 508 and information and communication technology accessibility standards

B. California Requirements

California Government Code section 11135

Prohibits discrimination, including disability discrimination, in programs or activities that are conducted, operated, funded, or receive state financial assistance.

Read CGC § 11135

California Government Code section 7405

Requires state entities to ensure that electronic and information technology is accessible and aligns with Section 508 standards. Importantly, it also requires certain contractual commitments addressing accessibility.

Read CGC § 7405

Taken together, § 11135 and § 7405 ensure that California public entities cannot fall back on gaps in federal coverage. Where federal funding may be limited, stated funding triggers § 11135. Where procurement and technology contracting are involved, § 7405 establishes an affirmative state-law basis for the same accessibility requirements already present under federal law.

C. California Civil Rights Exposure

Unruh Civil Rights Act (California Civil Code section 51)

Provides an additional layer of liability in California by prohibiting disability discrimination and allowing private lawsuits.

  • Can be asserted alongside ADA claims
  • Provides for statutory damages in qualifying cases

Read CIV § 51

Key takeaway: Public entities in California operate within a layered legal framework. Even where one law may not apply directly, others may still create obligations or legal exposure.

This section provides templates and tools that can support implementation and ongoing program management.

The ADA National Network has created an ADA Title II Action Guide for State and Local Governments, including, 7 Steps to Implement the ADA

Access the Action Guide

A. Public-Facing Resources

W3C Accessibility Statement Generator

Create a standardized accessibility statement for your organization.

Use the W3C Accessibility Statement Generator

B. Evaluation and Reporting

W3C Accessibility Evaluation Report Template

Provides a standard structure for documenting audit results.

View the W3C accessibility evaluation report template

WCAG-EM Report Tool

Interactive tool for generating accessibility evaluation reports.

Use the WCAG-EM report tool

C. Procurement and Vendor Evaluation

VPAT (Voluntary Product Accessibility Template)

Industry-standard format for vendor accessibility conformance reporting.

Access VPAT resources

Section508.gov – Buy Accessible ICT

Guidance for incorporating accessibility into procurement processes.

Access Section508.gov procurement guidance

Access Accessibility Requirements Tool (ART) to generate procurement language

Develop a Procurement Plan

Developing a procurement plan establishes a structured approach to acquisition across the full contract lifecycle - helping the entity define requirements, evaluate vendors, manage performance, and ensure a more efficient and successful procurement process from initial solicitation through ongoing contract management.

Access additional guidance on procurement

Members may benefit from maintaining internal templates and working documents such as:

  • Accessibility policy
  • Accessibility statement
  • Vendor accessibility questionnaire
  • VPAT or accessibility conformance report review checklist
  • Accessibility audit intake form
  • Remediation roadmap
  • Issue tracking log
  • Exception or risk acceptance documentation
  • Certification checklist, where applicable

F. Tools

Rather than defining accessibility requirements independently, laws and regulations rely on established technical standards. The authoritative source for these standards is the W3C.

Core Standard - Web Content Accessibility Guidelines (WCAG)

WCAG defines how to make digital content more accessible to people with disabilities.

Review the WCAG overview

Read the WCAG 2.2 recommendation

These guidelines are not static - they evolve over time to reflect changes in technology, user needs, and best practices. As a result, WCAG published in versions, with each new version building on the previous one by adding or refining success criteria. This means organizations should pay attention not just to "WCAG compliant", but to which version and level they are aligning with, as expectations continue to advance. 

Important context:

  • The DOJ rule references WCAG 2.1 Level AA
  • W3C recommends using the most current version where feasible
  • WCAG is organized around four principles: Perceivable, Operable, Understandable, and Robust

Supporting Guidance

Review Understanding WCAG and related guidance

Learn how to evaluate web accessibility

These resources are especially useful for developers, designers, content creators, and quality assurance or testing teams.

Key takeaway: WCAG is the technical standard that organizations build and test against. Policies, audits, and remediation efforts all point back to it.

These resources provide foundational knowledge and practical skills at no cost.

W3C Digital Accessibility Foundations Course

A strong general introduction for both technical and non-technical staff.

Access the W3C Digital Accessibility Foundations Course

Section508.gov Training

Covers accessibility across roles including procurement, design, development, and content creation.

Access Section508.gov accessibility training

Department of Homeland Security (DHS) Section 508 Training Program

Practical training for creating and testing accessible digital content.

Access DHS Section 508 training

Key takeaway: Start with broad awareness training across staff, then move into role-specific training for developers, content authors, procurement teams, and others with implementation responsibilities.

Most organizations are at different stages of accessibility maturity. A substantial body of guidance, tools, and training already exists - so when you identify gaps or opportunities to improve compliance, leverage established resources and frameworks rather than starting from scratch.

  • ADA National Network (800) 949-4232
  • Department of Justice’s ADA Information Line (800) 514-0301
  • Colorado Governor's Office of IT - Digital Accessibility Law for Colorado State and Local Government - view their site and available resources
    • Colorado has taken a more prescriptive and proactive approach to digital accessibility than many states, establishing clear requirements and expectations for public entities. Even for organizations outside Colorado, their materials can serve as a useful benchmark and starting point for building or refining an accessibility program.

UsableNet Resources

PRISM has partnered with UsableNet for addressing website accessibility via their managed service offering (UsableNet Assistive) and is leverages their testing software - AQA.  In addition to these offerings, they can provide accessibility audits, manual expert testing, testing with assistive-technology users, training for design and development teams, and strategy and consulting. 

Key characteristics:

  • Developer-led (not automation alone)

  • AI-assisted testing and prioritization

  • Ongoing maintenance and regression prevention

  • Minimal lift required from internal teams

  • Initial improvements typically delivered with ~60 days

  • Deployment does not require backend or server access

  • Includes legal support and indemnity protections

WebAIM Resources

WebAIM (Web Accessibility In Mind) has provided comprehensive web accessibility solutions since 1999. These years of experience have made WebAIM one of the leading providers of web accessibility expertise internationally. WebAIM is a non-profit service center at Utah State University.  Their services include training, evaluation, and technical assistance and consulting.  PRISM has engaged with WebAIM for both training and evaluation services.  Additionally, they've developed and support WAVE (Web Accessibility Evaluation Tool) which is a suite of evaluation tools that help web authors evaluate accessibility of their web content.

Leveraging The State CIO and Statewide Accessibility Officer Partnership Across State IT Operating Structures publication