What ADA compliance actually requires
WCAG 2.1 contains 50 success criteria at Level A and Level AA combined, organized under four principles the W3C calls POUR.
- Perceivable. Content must be presentable to users in ways they can perceive. Alt text on images. Captions on video. Sufficient color contrast (4.5:1 for normal text).
- Operable. Interface components must be usable. Every function reachable by keyboard. No content that flashes more than three times per second. Users can extend time limits.
- Understandable. Content and interface behavior must be predictable. Labels on every form field. Errors identified in text, not color alone. Language of the page declared.
- Robust. Content must work reliably with current and future assistive technologies. Valid HTML. Proper ARIA roles. No markup that breaks screen readers.
WCAG 2.2, published by W3C in October 2023, adds nine additional success criteria on top of WCAG 2.1. The DOJ currently points to WCAG 2.1 AA as the enforceable floor. Most businesses that target WCAG 2.1 AA now are well-positioned for whatever the DOJ settles on next.
WCAG Level A vs AA vs AAA: which does your business need?
| Level | Success Criteria | What it covers | Use case |
|---|---|---|---|
| A | 30 | Minimum floor. Basic keyboard access, alt text, no seizure triggers. | Nothing relies on Level A alone. Always combined with AA. |
| AA | 20 (50 cumulative) | Standard most regulations reference. Contrast, resize, consistent navigation. | DOJ-identified standard under ADA Title III. Target for almost every business. |
| AAA | 28 (78 cumulative) | Highest bar. Sign language for video, 7:1 contrast, reading-level guidance. | Only required in narrow contexts. W3C notes AAA is not required as a general policy. |
Source: W3C Web Content Accessibility Guidelines 2.1 (June 2018).
What triggers an ADA website lawsuit
More than 4,000 federal ADA Title III lawsuits over website accessibility were filed in 2024, according to UsableNet’s year-end tracking. The pattern is predictable. Plaintiff firms run automated scans against thousands of sites a week. They sort the results. They file.
The five failures that drive most of the volume:
- Missing or empty alt text on images. Screen readers cannot describe a product photo that says
<img src="shoe.jpg">with no alt attribute. - Keyboard traps. A modal or menu that traps focus and cannot be closed with the Escape key.
- Insufficient color contrast. Light gray text on a white background. WCAG AA requires 4.5:1 for normal text and 3:1 for large text.
- Forms without labels. A checkout page where the email field is unlabeled and invisible to a screen reader.
- Inaccessible PDFs. A menu or price list uploaded as an image-only PDF, unreadable by any assistive technology.
If your site has any of these and you sell to the public, you are the profile of a plaintiff firm’s next lawsuit. The WebAIM Million 2024 report found detectable WCAG failures on 95.9% of home pages surveyed. Most sites fail the same five criteria. Fix those five first.
Can I make my website ADA compliant myself?
Honestly, no. WCAG 2.1 AA has 50 success criteria, and automated tools catch roughly a third of them. The rest require manual expert review: keyboard testing, screen reader testing, reading-order audits, focus-order audits, semantic review of custom components.
“Automated accessibility testing is a good starting point, but it cannot replace human evaluation. Many WCAG success criteria require judgment that only a trained evaluator can provide.”
You can install a free scanner (ours is below) and catch the obvious failures yourself. You can fix alt text, contrast, and form labels from an engineering backlog. What you cannot do from a scanner alone is certify compliance. That takes manual testing against all 50 criteria, a report that names each failure and its fix, and usually a retest after remediation.
What a full ADA remediation engagement includes
We deliver four things:
- A full manual WCAG 2.1 AA review. Every page type, every interactive component, every form.
- A prioritized remediation plan that separates lawsuit-critical failures (the top five) from polish work. We clear the top five first, cover 80% of the lawsuit risk, and work the remainder on a reasonable schedule.
- Remediation by our team. We ship every fix the review identifies. We write the code, push it, and verify the result.
- A retest after remediation and an accessibility statement your legal team can stand behind.
One opinion, stated plainly: most sites fail the same five criteria. Fix those five before anything else. Anything that delays the top-five fix is the wrong priority.