WCAG 2.1 AA Audits for Western NC Governments

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.

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, requiring state and local government websites and mobile apps to conform to WCAG 2.1 Level AA. An interim final rule in April 2026 moved both dates back a year.

Deadline	Who it covers
26 April 2027	Public entities serving 50,000 or more. Locally: Buncombe County, the City of Asheville, Henderson County, Haywood County. Their departments and programs inherit the same date.
26 April 2028	Public entities under 50,000, and special districts of any size. Almost every town here, plus school districts, community colleges, fire, water and sewer, airport, housing and tourism authorities.

What counts as “your website”. Web content the entity provides or makes available, plus mobile apps: documents you publish, video you post, online forms, and the third-party platforms you use to deliver a service. Using a vendor does not transfer the obligation.

What is excluded. Archived content kept for reference and not altered, pre-existing documents not currently used to access a service, third-party content not posted on your behalf, individualised password-protected documents, and pre-existing social posts. The long-standing limits for fundamental alteration or undue burden still apply, but those are documented determinations by the head of the entity, not a default position.

We are describing what the rule says. This is not legal advice. The rule is 28 CFR Part 35, and DOJ publishes a fact sheet and small entity compliance guide at ada.gov.

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.

Not sure how your site measures up? A scoping call tells you what an audit would cover.

Book a scoping call (828) 383-6488

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

A fixed piece of work with a defined output. You get a written scope and a fixed price before anything starts.

1

Scoping call, 20 minutes.

Which properties are in scope, how many templates, roughly how many documents and where, which third-party platforms deliver services, and who will own the fixes.

2

Automated scan.

Every reachable page checked with industry tooling. This gives the volume picture and the machine-detectable failures.

3

Manual testing.

A page per template, each given full keyboard and screen reader testing, zoom and reflow, contrast measurement, and a heading and landmark review.

4

Document review.

A sample of your PDFs by category: which are scanned images, which are untagged, and what each category needs. Volume usually determines the budget.

5

Video and third-party review.

Caption status on published video, plus an inventory of vendor platforms in scope and their conformance documentation where it exists.

What you receive

A WCAG 2.1 AA conformance report: every failure against its success criterion, the pages affected, who it affects, and a recommended fix.
A prioritised remediation plan, ordered by user impact and legal exposure, split into template fixes, content fixes your staff can do, and developer work.
A cost and effort estimate for each group, so you can take a real number to a budget meeting.
A document strategy: which PDFs need remediation, which should become HTML instead, and how to stop the backlog rebuilding.
A staff training brief and a draft accessibility statement you can publish.

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. Take the report to your existing vendor, to internal IT, or to another contractor. It is your document. If you would rather we did the work, it takes one of three shapes.

Template and code remediation. Most sites repeat a handful of defects on every page. Fixing them in the template fixes thousands of pages at once, and it is normally the cheapest large win available.
A rebuild, when the platform is the problem. Some sites cannot reach AA without moving. If we find that, we will say so plainly and show you the evidence, because it is a much bigger ask.
Document remediation. Tagging, reading order and alt text on existing PDFs, or moving the highest-traffic documents to accessible HTML, which is usually cheaper long term.

Then ongoing monitoring, because every new agenda, news post and staff photo is a chance to reintroduce a failure.

Why this studio

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

We are a 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 fix what we find, in the template and in the code, rather than hand over a PDF of problems and leave.

We do not sell overlays. We do not certify anyone as ADA compliant, because no private company can.

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.

WCAG 2.1 AA compliance for Western North Carolina public entities