Elfatrany Design

WCAG 2.1 AA compliance for Western North Carolina public entities

A federal rule now sets a hard technical standard and a fixed date for government websites. Counties and cities serving 50,000 or more people have until 26 April 2027. Towns, school districts, fire districts, water and sewer authorities, libraries, transit agencies and community colleges have until 26 April 2028. This page explains what the rule says, what conformance actually involves, and what an audit costs.

Elfatrany Design is a web design and technology studio in Asheville, North Carolina. We audit against WCAG 2.1 Level AA directly, in a browser and with assistive technology, and we do not sell accessibility overlay widgets.

Who has to comply, and by when

In April 2024 the Department of Justice published a final rule under Title II of the Americans with Disabilities Act. It requires state and local government websites and mobile apps to conform to WCAG 2.1 Level AA. Before this rule there was no federal technical standard for government web content. Now there is one, in writing, with a compliance date attached.

In April 2026 DOJ issued an interim final rule that moved both compliance dates back by one year. The current dates are:

26 April 2027 applies to public entities with a total population of 50,000 or more. In our region that is Buncombe County, the City of Asheville, Henderson County and Haywood County. Departments and programs of those governments inherit the same date, which catches out a few organisations that assume they have longer. A county library system, a city transit department and a county-run transit program are not separate special districts if they sit inside the parent government. They are covered on the parent’s date.

26 April 2028 applies to public entities with a total population under 50,000, and to special district governments regardless of size. That is the bucket almost everyone in Western North Carolina falls into: Waynesville, Brevard, Hendersonville, Fletcher, Black Mountain, Weaverville, Woodfin, Canton, Clyde, Maggie Valley, Montreat, Rosman, Mills River, Flat Rock, Laurel Park, Biltmore Forest. It also covers every school district, community college, sanitary and sewerage district, fire district, airport authority, housing authority, regional council of governments and tourism development authority, no matter how few people it serves.

What “your website” means under the rule. It covers the web content the entity provides or makes available, and mobile apps. That includes documents you publish, video you post, online forms, and third-party platforms you use to deliver a service. If residents pay a bill, search a catalogue, register for a programme or track a bus on a vendor’s platform that you link to as part of your service, the obligation follows the service. Buying a vendor product does not transfer the responsibility.

Some things are excluded. The rule carves out archived web content that is kept only for reference and is not altered, conventional electronic documents posted before the compliance date unless they are currently used to apply for or access a service, content posted by third parties who are not acting for you, individualised password-protected documents about a specific person, and pre-existing social media posts. The rule also keeps the long-standing limits where compliance would be a fundamental alteration or an undue financial and administrative burden, but those are documented determinations made by the head of the entity, not a default position.

We are describing what the rule says. We are not lawyers and this is not legal advice. The rule is 28 CFR Part 35, and DOJ publishes a plain-language fact sheet and small entity compliance guide at ada.gov. Your attorney should read the text before you make decisions based on it.

If you are a private business, this rule is not about you

Plenty of vendors are currently emailing private businesses about a 2027 “ADA website deadline.” That is not accurate and you should be sceptical of anyone who says it.

Private businesses are covered by Title III of the ADA, not Title II. Title III has no adopted federal technical standard for websites and no compliance deadline. The 2024 rule does not apply to you.

What private businesses face instead is litigation. Web accessibility demand letters and lawsuits are common, and when courts and settlement agreements need a benchmark they generally reach for WCAG 2.1 Level AA, because it is the only widely accepted standard available. So the practical target ends up being the same, but the pressure is a lawsuit rather than a date on a calendar, and the decision to invest is a risk judgement rather than a compliance obligation.

If you run a private business and want the work done anyway, the same accessibility audit applies. We will just be honest with you about why you are doing it.

What WCAG 2.1 AA actually requires

WCAG is written for developers. Here is the same thing in the language of someone who runs a town website.

Every image needs a text description, or an explicit marker saying it is decorative.

A screen reader announces the description. If the image is a flyer with the meeting time baked into the artwork, that text is invisible to a screen reader. Announcements as image-only graphics are one of the most common failures we see.

Every page needs a way to skip past the navigation.

A "skip to main content" link at the very top. Without it, a keyboard or screen reader user goes through your entire menu on every single page before reaching anything. It is one line of code and it is missing from a surprising number of government sites.

Everything must work without a mouse.

Tab through your own site. If you cannot open the menu, close a popup, get through a slideshow or submit a form using only the keyboard, that is a failure. Accordions, sliders and mobile menus from page builders are the usual culprits.

Text must have enough contrast against its background.

Light grey on white fails. Pale blue links on a coloured banner usually fail. This is a measurable ratio, not an opinion.

Headings must describe the real structure of the page.

One H1, then H2s, then H3s, in order. Screen reader users navigate by heading the way sighted users skim. Headings chosen because they looked the right size make a page unnavigable.

Video needs accurate captions.

Board and council meeting video is the single biggest exposure for cities, counties and school districts. YouTube auto-captions do not meet the standard. Pre-recorded video also needs an audio description or an equivalent text alternative where visual information is not spoken aloud.

Forms need real labels tied to their fields.

And errors need to say what went wrong in text, not just turn a box red.

Pages must survive zoom and reflow.

Content has to work at 200% zoom and on a narrow screen without horizontal scrolling and without losing anything.

PDFs count as web content.

Agendas, minutes, budgets, ordinances, water quality reports, permit forms, employment applications and rate schedules are all covered. A PDF produced by scanning paper is an image with no text at all and fails outright. A PDF exported from Word is usually better but still needs a proper tag structure, reading order, headings and alt text. Volume is the problem, not difficulty.

Nothing may flash more than three times a second.

And anything that moves, scrolls or auto-updates needs a way to pause it. Auto-rotating homepage carousels usually fail this.

Four things that catch entities out

An accessibility overlay is not conformance.

The widget that adds a floating accessibility icon with "vision impaired" and "epilepsy safe" profiles does not make a site conform to WCAG 2.1 AA. DOJ has been explicit that a third-party tool does not by itself satisfy the requirement, disability advocacy organisations reject overlays, and overlays have themselves attracted litigation. If you have already bought one, you have probably not bought what you think you bought.

An automated scan finds a minority of the problems.

Automated tools are useful and we run them, but they reliably detect only part of what WCAG covers. Whether alt text is accurate, whether the keyboard focus order makes sense, whether captions are correct, whether a heading structure describes the real page: those need a person. A clean automated report is not evidence of conformance.

Your vendors are inside the scope.

Catalogue platforms, event calendars, payment and utility billing portals, resident application systems, bus tracking apps, learning management systems, agenda management software. You are responsible for the service, and the vendor's accessibility conformance report is a document worth reading rather than filing.

The documents are the workload.

For most towns and districts the website itself is a few weeks of work and the PDF library is the real project. It is worth starting there, and worth deciding early which historical documents genuinely need remediation and which are covered by the archived-content exception.

What an audit involves

An audit is a fixed piece of work with a defined output. Here is exactly what happens.

  1. Scoping call, about 20 minutes. We establish which properties are in scope, how many templates the site uses, roughly how many documents you publish and where they live, which third-party platforms deliver services, and who inside the organisation will own the fixes. You get a written scope and a fixed price before anything starts.
  2. Automated scan across the site. Every reachable page, checked with industry tooling. This gives us the volume picture and the machine-detectable failures.
  3. Manual testing on a representative sample. We choose pages that cover each distinct template: homepage, department landing page, news article, staff directory, a form, a document listing, a search result. Each one gets full keyboard testing, screen reader testing, zoom and reflow testing, contrast measurement and a heading and landmark review.
  4. Document review. A sample of your PDFs by category, with an assessment of which are scanned images, which are untagged, and what remediation each category needs. Plus an estimate of total document volume, which is usually the number that determines your budget.
  5. Video and third-party review. Caption status on your published video, and an inventory of the vendor platforms in scope with their published conformance documentation where it exists.

What you receive

  • A WCAG 2.1 AA conformance report, listing each failure against its specific success criterion, with the affected pages, a plain-English description of who it affects and how, a screenshot or code sample, and a recommended fix.
  • A prioritised remediation plan, ordered by user impact and legal exposure rather than by how easy the fix is, and split into three groups: template-level fixes that resolve an issue everywhere at once, content fixes your own staff can do, and items needing a developer.
  • A cost and effort estimate for each group, so you can take a real number to a budget meeting rather than a guess.
  • A document remediation strategy, including which historical PDFs need work, which can be moved to HTML instead of remediated, and how to stop the backlog rebuilding.
  • A staff training brief covering the handful of habits that prevent most new failures: alt text, heading structure, meaningful link text, and exporting accessible documents.
  • A draft accessibility statement you can publish, describing your actual conformance status, known exceptions, and how someone reports a barrier. The rule expects a real feedback route, and an honest statement about work in progress is better than silence or a claim you cannot support.

Everything is written to be read by a manager, a board and an attorney, not only by a developer.

What happens after the audit

The audit is deliberately separable from the fixing. You can take the report to your existing web vendor, to internal IT, or to another contractor. It is your document and it is written to be usable by whoever does the work.

If you want us to do the remediation, it usually takes one of three shapes.

Template and code remediation. Most sites have a small number of defects repeating on every page: a missing skip link, a keyboard-inaccessible menu, contrast failures in the theme’s link colour, an unlabelled search field. Fixing those in the template fixes thousands of pages at once, and it is normally the cheapest large win available. Scope depends on what your platform lets you change.

A rebuild, when the platform is the problem. Some sites cannot reach AA without moving. Consumer website builders and 2010s hand-built templates often do not expose the markup you would need to change. If we find that, we will say so plainly and show you why, because it is a much bigger ask and you deserve the evidence.

Document remediation. Tagging, reading order and alt text on existing PDFs, or converting the highest-traffic documents to accessible HTML pages, which is usually cheaper long term and better for search as well as for screen readers.

Then ongoing monitoring, because accessibility is not a one-time project. Every new agenda, news post and staff photo is a new opportunity to fall out of conformance. Our care plans include scheduled automated scans, a periodic manual spot check, alerts on newly introduced failures, and a documented record of the work. That record matters. Being able to show a consistent, good-faith programme is a materially different position from being able to show a certificate from three years ago.

Pricing, honestly

We publish our rates and we will give you a fixed number before work starts.

Audit

From $1,500

Quoted after the scoping call. We do not list a single price, because a five-page fire district site and a county with a decade of PDF agendas are not the same job. The drivers are distinct page templates, total page count, document volume, separate properties in scope, and whether mobile apps are included.

Remediation

Quoted per finding group

Template and code fixes are priced from the audit, so you can approve the high-impact work now and schedule the rest across a budget cycle. Full redesigns run $3,500 to $7,500 when the content and structure are sound. New custom sites run $4,500 to $15,000.

Compliance Care

From $355/mo

Ongoing monitoring, periodic manual checks, alerts on new failures, and the documented record of the work that shows a good-faith programme.

Two things worth saying out loud. First, the cheapest path is almost always to audit early and remediate over two budget cycles rather than to discover the scope in the last quarter before your deadline. Second, if the audit shows your site is in better shape than you feared, we will tell you that and the invoice will be smaller. We would rather be the studio that told you the truth.

Why this studio

Elfatrany Design is a small web design and technology studio based in Asheville. Sammy Elfatrany does the work himself, which means the person who runs your audit is the person you talk to on the phone and the person who writes the report.

We are being straightforward about what we are: this is a design and development studio that tests against WCAG 2.1 AA, not a national compliance firm and not a law practice. What we bring is the ability to actually fix what we find, in the template and in the code, rather than hand over a PDF of problems and leave. And we are a short drive from most of the entities on this page, which matters more than it should when you want someone in the room for a board presentation.

We do not sell overlays. We do not certify anyone as ADA compliant, because no private company can. We test, we document, we fix, and we help you keep it fixed.

Request your accessibility audit.

Tell us your site and what’s driving this. We reply within one business day with next steps and a scoped quote.

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Frequently asked questions

Does the 2024 ADA rule apply to my business website?

Only if you are a state or local government entity. The rule sits under Title II of the ADA, which covers counties, cities, towns, school districts, community colleges, and special district governments such as fire districts, sanitary districts, housing authorities, airport authorities and regional councils. Private businesses fall under Title III, which has no adopted federal technical standard and no deadline. Private businesses still face accessibility lawsuits, and WCAG 2.1 Level AA is the benchmark courts and settlements generally use, but that is litigation risk rather than a regulatory deadline.

Is our ADA Title II deadline 2027 or 2028?

Public entities serving a total population of 50,000 or more must comply by 26 April 2027. Everyone else, plus every special district government regardless of population, has until 26 April 2028. Two things trip people up. A department or programme of a large county or city is not a separate special district, so it takes the parent government's earlier date. And a special district gets 2028 even if it serves far more than 50,000 people. If you are unsure which applies, ask your attorney now rather than in 2027.

We already installed an accessibility widget. Are we covered?

Almost certainly not. Overlay and widget products that add an accessibility toolbar to your site do not make it conform to WCAG 2.1 Level AA. The Department of Justice has been clear that using a third-party tool does not by itself satisfy the requirement, and disability advocacy organisations have consistently rejected overlays as a substitute for accessible code. If you have one installed, an audit will tell you what it is and is not doing for you.

Do our PDFs really have to be accessible?

Yes. Documents you publish are web content under the rule. Agendas, minutes, budgets, ordinances, water quality reports, permit applications, employment forms and rate schedules are all in scope. Scanned documents are the worst case, because a scan is an image and contains no readable text. There is an exception for conventional electronic documents posted before your compliance date, but it does not apply if the document is currently used to apply for, access, or participate in a service. For most towns and districts the document library is the largest part of the work, so it should be scoped first.

What about our board meeting videos on YouTube?

Pre-recorded video with sound needs accurate captions to meet WCAG 2.1 AA, and YouTube's automatic captions do not meet the standard. They are a starting point for a human to correct, not a finished product. Video that conveys information visually without saying it aloud also needs audio description or an equivalent text alternative. For cities, counties and school districts that stream meetings, this is often the most defensible single finding an auditor can raise.

Our website is run by a vendor. Is accessibility their problem?

The obligation stays with you. Vendor platforms affect what is technically possible, and a good vendor will already have done template-level work, but no contract moves your legal responsibility to them. That applies to your CMS and equally to the platforms delivering your services: payment and utility billing portals, library catalogues, event registration, resident applications and bus tracking apps. Mobile apps are explicitly covered by the rule. Ask each vendor for their accessibility conformance report, read it, and put conformance language in your next renewal.

Does the website have to be perfect to comply?

WCAG 2.1 Level AA is the target the rule sets. It does contain a limited provision for nonconformance so minimal in impact that it would not affect a disabled person's ability to use the content in a substantially equivalent way, and it preserves the existing limits where compliance would be a fundamental alteration or an undue financial and administrative burden. Those are narrow, require a documented determination by the head of the entity, and still require access to the maximum extent possible. The practical goal is a documented, good-faith programme that closes real barriers on a schedule you can show.

How long does an accessibility audit take, and what do we get?

For a small town or district site, usually two to three weeks from kickoff to delivery. For a county or school district with multiple subsites and a large document library, longer. You receive a WCAG 2.1 AA conformance report listing each failure against its success criterion with affected pages and a recommended fix, a prioritised remediation plan split into template fixes, staff content fixes and developer work, cost estimates per group for budgeting, a document remediation strategy, a short staff training brief, and a draft accessibility statement to publish. It is written for managers and boards as well as developers, and you can hand it to any contractor you choose.

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