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How detailed does Title II get for the public site?

  • vendor
  • wcag
  • method
Title II The ADA rule that city and township public websites must work for people with disabilities. What Title II is
points at WCAG 2.1 Level AA for covered public web content — dozens of success criteria, not a single color check. Automated tools see only part of that list. A city still needs a dated look at the real pages and PDFs, and tickets someone can fix without a legal stamp.

Who this is for

Website vendors, agency partners, and city IT or communications staff who ask how deep this goes. Clerks who heard “Double-A” once and need plain language.

The yardstick in one sentence

Title II is the legal duty. WCAG 2.1 Level AA is the technical standard the 2024 rule wrote into 28 CFR 35.200.

Version (2.1) and level (AA) are not the same thing as ADA Title II. On the citation pages we keep that split short; this post is the longer version.

What “detailed” means in practice

  1. Pages residents use — home, payments, licenses, agendas, department forms — not every forgotten archive URL on day one.
  2. Public PDFs in scope — inventory under 28 CFR 35.201; ticket what is currently used. See PDFs.
  3. Automated findings are partial — see Method for how much automation covers and why the pack still does not stamp conformance.
  4. Tickets the vendor can run — shaped for the city’s website system when we know it; plain language otherwise (How it works).

Promises to push back on

  • “You will be compliant after this crawl.”
  • “The overlay fixed Title II.”
  • “Here is our WCAG certificate.” (ActaPack does not stamp conformance.)

ActaPack is a dated monthly file plus tickets — $8,400/year — independent of whoever maintains the public site.

For the clerk reading over your shoulder

You do not need to memorize success-criterion IDs. You need a file you can attach and a list you can forward. That is the pack.

For implementers

Published Deque research is often summarized as about 16 of 50 WCAG 2.1 AA criteria checked automatically (~57% of issue instances in their sample). Plan for manual review on the pages residents use. Inventory public PDFs under 35.201; ticket packets and forms people still need. Write tickets the city’s website system can act on when you know it.

This month

Work the ticket list from the latest dated file. Prefer source fixes over overlays. We do not certify that the site meets WCAG.

Questions people ask

Do we need every page perfect before the start date?
The duty is to meet the standard for covered content. Prioritize what residents use. Keep a dated monthly record and a working ticket list. ActaPack does not certify “perfect.”
Is an accessibility overlay enough detail?
No. An overlay is not the WCAG method for the underlying content under Title II. See the Overlay page.