Website accessibility obligations in the United States and Canada depend on the organisation, jurisdiction, service, and audience. The laws do not all name the same WCAG version, but WCAG Level AA is the practical engineering baseline.
Use this guide to identify the framework that may apply, then confirm legal obligations with qualified counsel. For implementation, start with our plain-English WCAG guide, use the 30-point accessibility checklist, or review our accessibility audit and remediation service.
2026 update: Following an April 2026 extension, the general DOJ Title II compliance dates are April 26, 2027 for public entities serving 50,000 or more people and April 26, 2028 for smaller entities and special district governments.
United States: Separate the Frameworks
ADA Title II
ADA Title II covers state and local governments. The DOJ’s web and mobile app rule names WCAG 2.1 Level AA for covered content, subject to stated exceptions.
The rule should not be described as a universal April 2026 deadline. The current general dates are:
- April 26, 2027: public entities serving 50,000 or more people
- April 26, 2028: smaller public entities and special district governments
The official DOJ fact sheet explains the population rules, exceptions, and the obligation to provide effective communication even where conforming content does not meet an individual’s needs.
ADA Title III
ADA Title III covers businesses open to the public. The DOJ’s general web guidance explains that the ADA applies to the goods, services, privileges, and activities offered through websites.
Unlike the Title II rule, that guidance does not prescribe one universal WCAG version for every private business. WCAG Level AA is still the practical technical benchmark, but legal scope and litigation posture vary by jurisdiction. Confirm the applicable obligations with counsel instead of presenting an engineering checklist as legal certification.
Section 508 and federal procurement
Section 508 applies to US federal agencies and affects vendors supplying information and communication technology to the federal government.
Procurement teams may request an Accessibility Conformance Report (ACR) prepared using a VPAT template. These terms are not interchangeable:
- VPAT: the reporting template
- ACR: the completed product-specific disclosure
An ACR should document support, partial support, non-support, and explanatory remarks for the applicable criteria. It is not a badge or a promise that no barrier exists.
Canada: Federal and Provincial Rules Differ
Accessible Canada Act
The Accessible Canada Act applies within federal jurisdiction. The legislation and regulations establish planning, feedback, consultation, and progress-reporting duties for regulated entities.
The Government of Canada’s guidance describes a three-year planning cycle:
- Publish an accessibility plan and feedback-process description
- Publish progress reports in the intervening years
- Publish an updated plan within the required cycle
The plan is broader than a website checklist. It addresses identifying, removing, and preventing barriers across relevant areas of the organisation.
Ontario AODA website requirements
Ontario’s official guidance says covered public websites must meet WCAG 2.0 Level AA, with stated exceptions. The requirement applies to:
- Designated public-sector organisations
- Businesses and non-profits with 50 or more employees
Scope details matter, including control of the website, publication date, internal versus public content, and specific exceptions. A business should review the current Ontario guidance rather than assuming that WCAG 2.2 replaced the version named in the regulation.
Using WCAG 2.2 AA for new implementation can still be a sound best-practice decision because it incorporates later user needs, but the audit report should identify both the regulatory baseline and the broader test baseline.
WCAG 2.1 Versus WCAG 2.2
WCAG 2.2 became a W3C Recommendation in October 2023 and adds nine success criteria. The Level A and AA additions include:
- Focus Not Obscured
- Dragging Movements
- Target Size (Minimum)
- Consistent Help
- Redundant Entry
- Accessible Authentication (Minimum)
WCAG 2.2 generally includes the earlier WCAG 2.0 and 2.1 success criteria, apart from the obsolete Parsing criterion removed in 2.2.
A useful audit scope therefore states:
| Field | Example |
|---|---|
| Required baseline | WCAG 2.1 AA under a specific contract |
| Best-practice baseline | WCAG 2.2 AA |
| Technology | Website, web app, mobile app, documents |
| Representative journeys | Registration, search, checkout, support |
| Testing methods | Automated, keyboard, screen reader, zoom, manual review |
| Documentation | Findings report, retest status, ACR if required |
What a Credible Accessibility Audit Includes
Automated testing is useful for repeatable rules, but it cannot judge every text alternative, reading order, focus sequence, status message, or task outcome.
A credible audit combines:
- Automated rules across the agreed crawl scope
- Manual keyboard operation
- Screen-reader testing of representative journeys
- Zoom, reflow, and text-spacing checks
- Contrast and non-text contrast evaluation
- Forms, errors, instructions, and status announcements
- Review of PDFs and media included in scope
- Testing of third-party components where possible
Each finding should identify the affected user, WCAG criterion, URL or component, reproduction steps, evidence, and recommended fix.
Remediation and Retesting
Prioritise shared components and task blockers before isolated cosmetic findings. A corrected navigation, dialog, form control, or product template may resolve the same barrier across many pages.
After remediation:
- Retest using the original reproduction steps
- Record pass, partial, fail, or not-tested status
- Document remaining third-party or content dependencies
- Add regression checks to development and content workflows
- Provide an accessible feedback route for users
Do not describe a site as conformant unless the conformance claim defines the version, level, scope, date, technologies relied upon, and known limitations.
How eLan Technology Helps
Our accessibility work can include:
- WCAG 2.1 or 2.2 Level AA audit scoping
- Automated and manual testing
- Code-level remediation across React, Next.js, Astro, WordPress, Shopify, and custom stacks
- Retesting and criterion-level status reports
- Accessibility statements
- ACR preparation using the appropriate VPAT template when required
- Ongoing regression testing and team guidance
Review our ADA and WCAG audit and remediation service. If a demand letter or complaint has already arrived, use the emergency remediation route.