ADA compliance checklist for a small business website

An ADA compliance checklist for a website is, in practice, a WCAG checklist. The Americans with Disabilities Act doesn’t mention alt text or colour contrast. The Department of Justice points businesses to the Web Content Accessibility Guidelines, and the settlements and court orders use WCAG level AA as the measure.

This is the short version for a small business: the eight things that come up most in complaints, with the WCAG rule behind each one, what version 2.2 added, and a way to check your own site on your phone. It ends with the EU and the UK, which ask for the same level under different names.

What the ADA asks of a website

The DOJ’s web guidance of 18 March 2022 says the ADA applies to businesses that are open to the public, and names retailers, banks, hotels and hospitals as examples. On how to get there it says that “existing technical standards provide helpful guidance”, and it names two: WCAG, and the Section 508 standards the federal government uses for its own websites.

The same page lists the barriers it sees most. Poor colour contrast. Colour used on its own to give information. Images without text alternatives. Videos without captions. Forms a screen reader can’t read. Pages that only work with a mouse. Those six are the backbone of the checklist below.

For state and local governments there’s now a rule with a number in it. The DOJ’s fact sheet on the Title II rule says it adopted WCAG 2.1 level AA as the technical standard. An interim final rule of April 2026 moved the dates: 26 April 2027 for governments serving 50,000 people or more, 26 April 2028 for smaller ones and special districts. There’s no equivalent rule for private businesses yet. The settlements fill that gap: CVS agreed to WCAG 2.1 AA in 2022, and a museum agreed to WCAG 2.0 AA in 2015. Both are below.

The ADA compliance checklist, item by item

Each item names the WCAG 2.1 success criterion behind it and its level. A is the floor; AA is what the rule and the settlements use. If you’re skimming, the phone check at the end is the part to keep. This section is the why.

1. Alt text on images

Criterion 1.1.1, level A: all non-text content “has a text alternative that serves the equivalent purpose”. A photo of your shopfront gets a short description. A chart gets its point in words. A purely decorative swirl gets an empty alt attribute so a screen reader skips it. The thing to avoid is a file name, or “image”, as the description.

2. Everything works from a keyboard

Criterion 2.1.1, level A: all functionality “is operable through a keyboard interface”. Menus that open on hover, sliders, date pickers and custom checkboxes are where this fails. If someone can’t reach the “buy” button with the Tab key, the page doesn’t work for them.

3. Colour contrast

Criterion 1.4.3, level AA: text has “a contrast ratio of at least 4.5:1” against its background, or 3:1 for large text. Criterion 1.4.11, also AA, asks for 3:1 on the parts of controls you need to see, like a button’s edge or a form field’s border. Light grey on white is the usual failure. So is placeholder text used as a label.

4. A visible focus ring

Criterion 2.4.7, level AA: any keyboard-operable interface has a mode where “the keyboard focus indicator is visible”. A lot of themes remove the outline for looks. Someone using a keyboard then has no idea where they are on the page.

5. Form labels and error messages

Criterion 3.3.2, level A: “labels or instructions are provided when content requires user input”. Criterion 3.3.1, also level A: when an error is detected, the field in error is identified and the error described in text. A red border on its own isn’t text, and a label that isn’t linked to its field isn’t read out.

6. Captions on video

Criterion 1.2.2, level A: captions are provided for all prerecorded audio in video. Auto-generated captions count only if you’ve corrected them. A product video with a voiceover and no captions fails this one, and it’s the item the Teachers Test Prep settlement below turned on.

7. Headings in order

Criterion 1.3.1, level A: the structure and relationships in the content “can be programmatically determined”. Criterion 2.4.6, level AA: “headings and labels describe topic or purpose”. In practice: one H1, H2s for the sections, H3s inside them, and no bold paragraph standing in for a heading. Screen reader users jump by heading the way sighted people skim.

8. An accessibility statement

Not a WCAG criterion, but it’s the page people look for when something doesn’t work. The W3C’s guidance says a statement contains at least a commitment to accessibility, the standard applied and contact information, and suggests adding known limitations. Put the standard and the version. “WCAG 2.1 AA” tells a reader exactly what you aimed at.

What WCAG 2.2 added

WCAG 2.2 keeps everything in 2.1 except criterion 4.1.1 Parsing, which it removed as obsolete. It adds nine criteria. The ones at level A and AA that touch a small business site:

• Target size (minimum), 2.5.8, AA: the target for pointer inputs “is at least 24 by 24 CSS pixels”, with exceptions for inline links and spaced-out small targets.
• Focus not obscured (minimum), 2.4.11, AA: a sticky header or cookie banner shouldn’t hide the element that has focus.
• Redundant entry, 3.3.7, A: information a person already entered in the same process is auto-populated or available to select.
• Accessible authentication (minimum), 3.3.8, AA: a cognitive function test, such as remembering a password or solving a puzzle, is not required for any step of logging in unless there’s another way.
• Consistent help, 3.2.6, A: a help link or contact method that repeats across pages stays in the same place.
• Dragging movements, 2.5.7, AA: anything that works by dragging also works with a single pointer press.

The DOJ rule names 2.1. The UK’s public sector regulations name WCAG 2.2 AA. If you’re building new, build to 2.2 and you’ve covered both.

Where the complaints come from

Three settlements on ada.gov read like the checklist above, in reverse.

In 2022 the Justice Department reached an agreement with CVS Pharmacy after a review of its vaccine registration portal. The Department determined that screen reader users met form fields that were labelled incorrectly, and that people not using a mouse would need to press the Tab key hundreds of times to get past one control. CVS denied wrongdoing and agreed to bring its vaccine content to WCAG 2.1 AA and test it regularly.

In 2018 the Department settled with Teachers Test Prep, a company whose online video courses had no closed captions. The company agreed to ensure all its online video content has captions, consistent with WCAG 2.0 AA criterion 1.2.2, and paid $5,000 to the complainant. It didn’t admit fault.

In 2015 the National Museum of Crime and Punishment agreed to make its website conform to WCAG 2.0 level AA within 120 days, after the Department found the site lacked features that let people who use assistive technologies reach information, links, ticket purchases and online shopping.

The private lawsuits turn on the same items, and they’re the subject of website accessibility lawsuits.

The same checklist in the EU and the UK

The EU’s European Accessibility Act applies to a list of services provided to consumers after 28 June 2025, and e-commerce services are on it. Annex I asks service providers to make their websites and apps accessible “in a consistent and adequate way by making them perceivable, operable, understandable and robust”. Those four words are WCAG’s four principles. The European standard behind the Act, EN 301 549, says that conforming to WCAG 2.1 level AA is equivalent to meeting all of its web clauses. The Act exempts microenterprises providing services. The detail is in EU-10.

The UK takes a different route to the same place. The Equality Act 2010 asks a service provider to take reasonable steps where a practice puts a disabled person at a substantial disadvantage, and for information, that can mean providing it in an accessible format. GOV.UK’s guidance says all UK service providers have a legal obligation to make reasonable adjustments under the Act. Public sector bodies also have to meet WCAG 2.2 AA and publish an accessibility statement. The rest is in UK-12.

None of the three names the same document in the same words. The DOJ rule and the EU standard point at WCAG 2.1 AA. The UK’s public sector rules point at 2.2 AA, and the Equality Act names no version at all.

Check your own site on your phone

Your phone has a screen reader built in: VoiceOver on an iPhone, TalkBack on Android. Nothing to install.

1. Turn the screen reader on and swipe through your home page. Each image should be read as a description, not a file name or “image”.
2. Keep swiping into the menu. Every item you can tap should be announced with a name and what it is, like “button” or “link”.
3. Open your contact or checkout form with the screen reader on. Each field should be read with its label. If you hear “edit text” and nothing else, the label isn’t linked.
4. Submit the form with a field empty. The error should be read out in words and say which field it’s about.
5. Turn the screen reader off and play any video with the sound off. If you can’t follow it, it needs captions.
6. Find the lightest text on the page, often a caption or a footer line. If you have to tilt the phone to read it, the contrast is short.
7. Set the phone’s text size to the largest setting and reload. Nothing should be cut off or overlap.
8. Look for an accessibility statement in the footer. If there isn’t one, write three lines: the standard you aim at, what you know doesn’t work yet, and how to reach you.

Peeky reads the public pages of your site. For keyboard and screen reader barriers, the checks are US-06, EU-10 and UK-12 in the Handbook.

Questions people ask

What comes up most in ADA website complaints?

The Justice Department's own list of common barriers is short: poor colour contrast, colour used on its own to give information, images without alt text, videos without captions, forms a screen reader can't read, and pages that only work with a mouse. It's in the DOJ's web guidance from March 2022, and the settlements on this page match it.

What does ADA compliance require for a website?

For businesses open to the public there's no technical standard written into a rule yet. The DOJ's guidance says existing standards such as WCAG and Section 508 provide helpful guidance, and its settlements have used WCAG level AA as the measure. Working to WCAG 2.1 AA is the practical answer.

What are the ADA website requirements for 2026?

The 2024 rule for state and local governments adopted WCAG 2.1 AA as the standard. The DOJ's fact sheet says an interim final rule of April 2026 moved the dates, so governments serving 50,000 or more people now have until 26 April 2027, and smaller ones and special districts until 26 April 2028. Private businesses aren't covered by that rule, but it's the clearest signal of the level the DOJ has in mind.

Should I follow WCAG 2.1 or WCAG 2.2?

Meet 2.1 AA first, because that's what the DOJ rule and most settlements name. WCAG 2.2 keeps everything in 2.1 except one criterion it removed, and adds a handful of items at level A and AA, like a minimum target size for buttons. The UK's public sector rules already use 2.2 AA, so if you also sell in the UK, read the 2.2 section below.

Do I need an accessibility statement?

For a US business it isn't written into a rule, but it's where you say which standard you work to and how to reach you when something doesn't work. The W3C says a statement should hold at least a commitment, the standard applied and contact information. UK public sector bodies have to publish one.