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DOJ Title II Digital Accessibility Guidance: What Dev Teams Need to Know

MarcusSeattle area
title iidoj guidancegovernment accessibilitywcag compliancedigital accessibility
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The Department of Justice released comprehensive guidance on Title II digital accessibility requirements in September 2024, providing state and local governments with official direction on making their websites and mobile apps accessible to disabled people after decades of uncertainty and inconsistent enforcement.

As someone who's worked with dozens of government dev teams, I can tell you this guidance couldn't come at a better time. The technical debt around accessibility in the public sector is staggering. Legacy systems built without any consideration for screen readers, mobile apps that assume everyone can see and tap precisely, procurement processes that don't even mention WCAG compliance—these barriers prevent disabled people from accessing essential government services that other citizens take for granted.

What Changed in DOJ Digital Accessibility Requirements

This isn't just another policy document. The DOJ guidance establishes that Title II entities—which includes everything from city websites to state university portals—must provide "effective communication" through their digital channels. That means if you can renew your business license online, someone using assistive technology needs to be able to do the same thing. This is about equal access to government services that people depend on.

The guidance references WCAG 2.1 Level AA as the technical standard, which gives development teams something concrete to work with. No more guessing whether alt text is "good enough" or whether that custom dropdown component will work with keyboard navigation. There's an actual specification to follow that helps ensure disabled people can actually use these services.

What strikes me about this guidance is how it acknowledges the reality of government technology operations while keeping the focus on equal access. Accessibility advocates have been saying this for years—accessibility isn't about perfection, it's about systematic progress and removing barriers so disabled people can participate equally in civic life.

The Developer Reality Check

Here's what I'm seeing in government dev shops: teams that want to do the right thing but lack the tools, training, and organizational support to make it happen. They're often working with:

  • Content management systems chosen five years ago with zero accessibility consideration
  • Third-party integrations that dump inaccessible widgets into otherwise compliant pages
  • Procurement processes that evaluate vendors on cost and features, but never ask about keyboard navigation or screen reader compatibility
  • QA workflows that test across browsers but never with actual assistive technology

These operational challenges create real barriers for disabled people trying to access government services. The new guidance doesn't magically solve these problems, but it does provide the regulatory backing that accessibility advocates need to push for systematic changes that will actually serve disabled users.

Building Sustainable WCAG Compliance

The most significant aspect of this guidance isn't just the legal requirement—it's the opportunity to build government services that actually work for everyone. Smart government technology leaders will use this moment to build accessibility into their development lifecycle, ensuring disabled people can access services from the start rather than being excluded by afterthought fixes.

Start with your content management workflow. If content creators can't add proper alt text or heading structure through your CMS, you're preventing disabled users from accessing essential information. The DOJ's technical requirements are clear about semantic markup and keyboard navigation—make sure your publishing tools support these basics so disabled people can actually use your services.

Next, look at your procurement language. Every RFP should require WCAG 2.1 Level AA compliance and include accessibility testing in the acceptance criteria. Vendors who can't demonstrate their accessibility capabilities are essentially asking you to exclude disabled users from your services—they shouldn't make it past the first round of evaluation.

Then tackle your QA process. Automated testing tools like axe-core can catch about 30% of accessibility issues, according to accessibility testing research, but you need human testing with actual assistive technology to find the barriers that really impact disabled users. Budget for this expertise, whether internal or contracted, because it's essential for ensuring equal access.

The Integration Challenge

What makes government digital accessibility particularly complex is the ecosystem problem. A single city website might integrate:

  • A third-party payment processor for utility bills
  • A vendor-managed permit application system
  • Social media feeds and embedded content
  • Maps and location services
  • Document management systems
  • Public meeting streaming platforms

Each integration point is a potential barrier that could prevent disabled people from accessing essential services. The DOJ guidance makes clear that government entities remain responsible for ensuring disabled people can use their digital services, even when using third-party vendors.

This means procurement teams need to start asking different questions. Not just "Does this integration work?" but "Does this integration work for people using screen readers, voice control software, or alternative input devices?" Because if it doesn't work for disabled people, it's not really working.

Strategic Implementation for Government Websites

The organizations that will succeed with this guidance are the ones that treat accessibility as fundamental to serving all citizens, not a checklist item. They'll invest in:

Developer training that goes beyond WCAG basics to cover real-world assistive technology usage patterns. Understanding how someone navigates with a screen reader changes how you structure information architecture and helps you build services that actually work for disabled users.

Design system integration that bakes accessibility into reusable components. If your button component handles focus management correctly, every developer using it gets that functionality for free, ensuring disabled users can navigate consistently across your services.

Content strategy alignment that considers accessibility from the information design phase. The most technically compliant page in the world is useless if disabled people can't understand or act on the content.

Vendor management processes that evaluate accessibility capabilities as seriously as security requirements. If you wouldn't deploy software with known security vulnerabilities, why accept software that excludes disabled users?

Looking Forward

This guidance represents a maturation of digital accessibility policy. Instead of vague requirements about "reasonable accommodations," government technology teams now have specific technical standards and clear expectations for ensuring disabled people can access the same services as everyone else.

The real test will be implementation. Government development teams that embrace this as an opportunity to build better, more inclusive digital services will find themselves ahead of the curve. Those that treat it as just another compliance checkbox will struggle with both the technical requirements and the underlying goal of equal access for disabled people.

For developers working in the public sector, this is your moment. You now have the regulatory backing to advocate for accessibility-first development practices, proper tooling, and the time needed to build inclusive digital services that actually serve disabled users. Use it wisely.

The DOJ's comprehensive guidance isn't just about legal compliance—it's about building digital government services that actually work for everyone, including the disabled people who have been excluded for too long. That's a technical challenge worth solving.

About Marcus

Seattle-area accessibility consultant specializing in digital accessibility and web development. Former software engineer turned advocate for inclusive tech.

Specialization: Digital accessibility, WCAG, web development

View all articles by Marcus

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This article was created using AI-assisted analysis with human editorial oversight. We believe in radical transparency about our use of artificial intelligence.