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ADA website compliance checklist: 12 points, each with how to verify it
Mapped to WCAG 2.1 and 2.2 Level AA, the criteria courts and the DOJ use. Printable.
What "ADA compliant" means for a website. Title III of the ADA has no technical web standard. The courts, the Department of Justice and every settlement we have read use WCAG: the DOJ's rule for state and local governments adopts WCAG 2.1 Level AA, with deadlines of 26 April 2027 and 2028, and private cases are measured against the same criteria. This checklist covers the twelve areas that decide most of those cases, each with a way to verify it yourself.
How to use this checklist
Pick the five pages a customer, or a plaintiff's tester, would use: the home page, one product or service page, the form that matters most (checkout, booking, contact), login if you have one, and one long content page. Run each item on each page. Most items take two to five minutes once you know what to look for. Write down what fails and the date; that log becomes the "known limitations" section of your accessibility statement and the evidence your counsel will want if a letter arrives. Items 1 to 6 are the ones template complaints cite; do them first.
1. Every image has appropriate alt text WCAG 1.1.1
Why it matters: missing alt text is the most cited barrier in ADA complaints, from Robles v. Domino's onward, and WebAIM found it on 53.1 percent of home pages in 2026.
Verify: paste the page URL into the alt text checker. It lists every image with its alt attribute and flags missing, empty on informative images, filename like ("IMG_2041.jpg") and over long values. Then read the ones it passed: does the text say what the image is for on this page?
Fix: informative images get a short description of their purpose; decorative images get alt=""; image links describe the destination, not the picture.
2. Text and controls meet contrast minimums WCAG 1.4.3, 1.4.11
Why it matters: low contrast text is on 83.9 percent of home pages (WebAIM 2026), 34 instances per page on average, and it is the first thing a scanner reports.
Verify: normal text needs 4.5:1 against its background, large text (24px, or 18.66px bold) 3:1, and input borders, focus rings and icons 3:1 against adjacent colors. Test any pair in the color contrast checker; the full scan measures every element on the page. Check dark mode separately if you offer it.
Fix: change the color token, not the element. #767676 is the lightest grey that passes on white.
3. Everything works with a keyboard and focus is visible WCAG 2.1.1, 2.1.2, 2.4.7
Why it matters: the Domino's plaintiff could not complete an order by keyboard. Keyboard traps in cookie banners, modals and carousels are in most complaints.
Verify: put the mouse aside. Tab from the top of the page: can you see where focus is at every step, reach every link, button and field, open and close menus, and does Escape close dialogs? Can you get out of embedded maps and video players? Do this on the checkout.
Fix: use native buttons and links, never div click handlers; keep a visible :focus-visible style; trap focus inside open dialogs and return it on close.
4. Every form field has a label, and errors are explained WCAG 1.3.1, 3.3.1, 3.3.2, 4.1.2
Why it matters: 51 percent of home pages have unlabeled inputs (WebAIM 2026). A screen reader announces "edit text" and nothing else.
Verify: click each label; if the field does not focus, the label is not associated. Icon only buttons (search, cart, close) need an accessible name; the full scan lists every control without one. Submit the form empty: is the error described in text next to the field, not only by a red border?
Fix: <label for> on every field, aria-label on icon buttons, error text linked with aria-describedby. Placeholder text is not a label.
5. Links say where they go WCAG 2.4.4
Why it matters: screen reader users navigate by pulling up a list of links. "Click here", "Read more" and image links with no text are useless in that list; empty links are on 46.3 percent of home pages.
Verify: the full scan flags empty links. For the rest, read only the link text out loud: "Read more about our returns policy" works, "Read more" does not.
Fix: put the destination in the link text, or add visually hidden text; give icon links an aria-label.
6. Headings and landmarks describe the structure WCAG 1.3.1, 2.4.6
Why it matters: headings are how screen reader users skim. A page with bold paragraphs instead of headings, or five h1 elements, cannot be skimmed.
Verify: open the browser's accessibility tree or the headings list in a screen reader. Is there one h1, do levels nest without skipping, and are the main content, navigation and footer marked as landmarks (main, nav, footer)?
Fix: use heading elements for headings and CSS for size; add the landmark elements; one h1 per page.
7. The page language is declared WCAG 3.1.1
Why it matters: without lang a screen reader may read English with a French voice, or vice versa. Still missing on 13.5 percent of home pages.
Verify: view the page source; the html element should carry lang="en" (or the correct code). Passages in another language get their own lang.
Fix: one attribute in the template.
8. Video has captions and audio has a transcript WCAG 1.2.1, 1.2.2, 1.2.5
Why it matters: an uncaptioned product video is an exclusion for deaf users and a routine secondary claim in complaints.
Verify: play every video with the sound off. Are captions available and accurate (auto captions count only if corrected)? Is there a transcript for audio only content? Does the player itself work by keyboard?
Fix: upload caption files; publish transcripts under the player; prefer players with accessible controls.
9. The page works at 200 percent zoom and on a narrow screen WCAG 1.4.4, 1.4.10
Why it matters: low vision users zoom rather than use a screen reader. Text that gets cut off, or a layout that needs horizontal scrolling at 320 CSS pixels, fails.
Verify: press Ctrl or Cmd and plus until the browser shows 200 percent. Is all text readable, do buttons still work, does anything overlap? Then resize the window to 320 pixels wide: no horizontal scrollbar except for data tables and images that need it.
Fix: relative units, flexible layouts, no fixed height containers with hidden overflow.
10. Users can skip repeated content and pages have titles WCAG 2.4.1, 2.4.2, 2.4.3
Why it matters: a keyboard user should not tab through 40 navigation links on every page to reach the content, and the page title is the first thing announced.
Verify: press Tab once on page load; a "Skip to content" link should appear and work. Read the browser tab: does the title describe the page and not just the brand? Is the focus order the same as the visual order?
Fix: add a skip link as the first focusable element; unique, descriptive titles; do not reorder elements with CSS in ways that break tab order.
11. Nothing moves, flashes or times out without control WCAG 2.2.1, 2.2.2, 2.3.1
Why it matters: auto playing carousels and background video distract and can be impossible to read; content flashing more than three times a second can trigger seizures; a checkout that times out silently loses the sale.
Verify: anything that auto plays for more than five seconds needs a pause, stop or hide control. Look for flashing. Fill the checkout slowly: are you warned before a session expires and can you extend it?
Fix: pause controls on carousels, respect prefers-reduced-motion, session warnings with an extend option.
12. No overlay, and a process that keeps the site this way ongoing
Why it matters: an accessibility widget does not change the code any of the eleven checks above test, and around a quarter of the sites sued in early 2026 had one installed. The FTC ordered accessiBe to pay $1 million in January 2025 over compliance claims. Meanwhile every deploy can reintroduce a failure.
Verify: is there a third party accessibility script on the page? Does your team re-run this list, or a scanner, after releases? Is there a dated statement with a monitored contact? Are PDFs on the site tagged, or offered as HTML?
Fix: remove overlays or restrict them to a preference panel, schedule automated re-scans, publish the statement, assign an owner.
Summary table
| # | Item | WCAG | Automated? | Free tool |
|---|---|---|---|---|
| 1 | Alt text | 1.1.1 | Presence yes, quality no | Alt text checker |
| 2 | Contrast | 1.4.3, 1.4.11 | Yes | Contrast checker, site scan |
| 3 | Keyboard and focus | 2.1.1, 2.1.2, 2.4.7 | Partly | Tab key |
| 4 | Labels and errors | 1.3.1, 3.3.1, 3.3.2, 4.1.2 | Presence yes | Site scan |
| 5 | Link text | 2.4.4 | Empty links yes | Site scan |
| 6 | Headings and landmarks | 1.3.1, 2.4.6 | Partly | Site scan, accessibility tree |
| 7 | Language | 3.1.1 | Yes | Site scan |
| 8 | Captions and transcripts | 1.2.x | No | Manual |
| 9 | Zoom and reflow | 1.4.4, 1.4.10 | No | Browser zoom |
| 10 | Skip link, titles, focus order | 2.4.1, 2.4.2, 2.4.3 | Partly | Site scan, Tab key |
| 11 | Motion, flashing, timeouts | 2.2.1, 2.2.2, 2.3.1 | No | Manual |
| 12 | No overlay, process | n/a | n/a | Scheduled scans |
What automated testing can and cannot tell you
Items 2, 4 (presence), 5 (empty links), 7 and most of 1 are caught reliably by a scanner, and those categories are where the volume is: WebAIM reports that six error types (contrast, alt text, labels, empty links, empty buttons, language) account for 96 percent of all detected errors. But "detected" is doing work in that sentence. When the UK Government Digital Service built a page with 143 deliberate barriers, the best automated tool found 41 percent. The rest, the keyboard walk, the reading of alt text and link text, the zoom test, needs a person. AdaClear's free scan handles the automated part on any page in about 30 seconds and lists the failing elements with their code, and the paid plans re-check on a schedule; the optional Expert Fix has specialists cover the manual items. Use this checklist for the parts in between. If your product is a web app sold to businesses, the SaaS accessibility guide covers the VPAT side.
To print or save this checklist as a PDF, use your browser's print function; the navigation and footer are hidden in print.
What this looks like in the wild: we audited every theme in the Shopify Theme Store against this checklist's automated items. 99 percent failed at least one, and 29 add-to-cart buttons fail WCAG AA contrast. Read the Shopify theme accessibility report.
Run items 1, 2, 4, 5 and 7 in 30 seconds
Free scan of any page: score, every failing element and its code. No overlay, no signup.
Scan my site free →Frequently asked questions
Is there an official ADA website compliance standard?
Not in the statute. Title III of the ADA does not name a technical standard for websites. The Department of Justice adopted WCAG 2.1 Level AA in its 2024 rule for state and local government websites, with compliance dates now set at 26 April 2027 and 26 April 2028, and courts and settlements involving private businesses reference the same WCAG 2.1 AA criteria. WCAG 2.2 AA is a superset and the safe target.
Can I check ADA compliance with a free tool?
You can check the machine-detectable parts. Contrast, missing alt text, unlabeled fields, empty links and buttons and missing language make up 96 percent of detected errors, and AdaClear's free scan, contrast checker and alt text checker cover them. The keyboard walk, zoom test, captions and the meaning of alt text need a person; the best automated tool found 41 percent of barriers in the UK government's test.
Which items on the checklist come up most in ADA complaints?
The first five: alt text, contrast, keyboard operation, form labels and link text. They are the barriers cited in template complaints and in Robles v. Domino's, and they are the most common failures on the web according to WebAIM's 2026 study. Fix those on the home page, a product page and the checkout before anything else.
Does an accessibility widget satisfy the checklist?
No. A widget adds a toolbar and does not change the HTML that items 1 to 11 test. About a quarter of sites sued in the first quarter of 2026 had a widget installed, and the FTC ordered accessiBe to pay $1 million in January 2025 over claims that its widget made sites compliant. Item 12 is there for that reason.
How long does it take to work through the checklist?
Roughly 30 to 45 minutes per page for a first pass once you know what to look for, faster with a scanner doing items 2, 4, 5 and 7. Testing the five most important pages is an afternoon. Fixing what you find depends on the platform; contrast and alt text are usually a day's work in any CMS.
Do I need to re-check after the site passes?
Yes. Every deploy, theme update, new product photo or embedded widget can reintroduce a failure. Scheduled automated re-scans catch the machine-detectable regressions; repeat the manual items after any redesign or platform change and update your accessibility statement when limitations change.
Sources
- ADA.gov, First Steps Toward Complying with the Title II Web and Mobile Application Accessibility Rule (WCAG 2.1 AA; 26 April 2027 and 2028): https://www.ada.gov/resources/web-rule-first-steps/
- Troutman Pepper Locke, DOJ Extends Title II ADA Web Accessibility Rule Compliance Deadlines (April 2026): https://www.consumerfinancialserviceslawmonitor.com/2026/04/doj-extends-title-ii-ada-web-accessibility-rule-compliance-deadlines-for-state-and-local-governments/
- W3C, Web Content Accessibility Guidelines (WCAG) 2.2: https://www.w3.org/TR/WCAG22/
- WebAIM Million 2026: accessibility of the top 1,000,000 home pages: https://webaim.org/projects/million/
- GOV.UK accessibility blog, What we found when we tested tools on the world's least-accessible webpage (best tool found 41 percent of 143 barriers): https://accessibility.blog.gov.uk/2017/02/24/what-we-found-when-we-tested-tools-on-the-worlds-least-accessible-webpage/
- Robles v. Domino's Pizza, LLC, 913 F.3d 898 (9th Cir. 2019): https://cdn.ca9.uscourts.gov/datastore/opinions/2019/01/15/18-55144.pdf
- Bureau of Internet Accessibility, 5 Web Accessibility Barriers Frequently Cited in ADA Lawsuits: https://www.boia.org/blog/5-web-accessibility-barriers-frequently-cited-in-ada-lawsuits
- FTC press release, 3 January 2025: order requires accessiBe to pay $1 million over deceptive WCAG compliance claims: https://www.ftc.gov/news-events/news/press-releases/2025/01/ftc-order-requires-online-marketer-pay-1-million-deceptive-claims-its-ai-product-could-make-websites
- EcomBack, Q1 2026 ADA Website Lawsuit Report (1,037 suits; 265 against sites with widgets): https://www.ecomback.com/ada-website-lawsuits-recap-report/q1-2026