wcag-title-ii-notes

name	wcag-title-ii-notes
description	Authoritative ADA Title II / WCAG 2.1 AA interpretation notes authored by Noah C. Benson (UW eScience). Use when agents need to reference ADA Title II compliance requirements, exceptions, or WCAG 2.1 AA rules.

ADA Title II Compliance Notes

Author: Noah C. Benson, February 2026

The author is not a lawyer; this is a good-faith attempt to read and understand the WCAG 2.1 level AA requirements. This document was written without the assistance of generative AI.

Resources

• The WCAG 2.1 requirements (AA are what is required)
• The ADA Fact Sheet
• UW's policy on minimum digital accessibility standards (uwconnect.uw.edu KB0036639)
• UW's digital accessibility checklist
• W3's quick-advice on meeting WCAG 2.1
• DubBot is UW's tool for compliance; AudioEye also checks for compliance. Not all requirements can be checked programmatically.

User Profiles

• Someone who is deaf — needs accurate captions; non-speech audio (like a bird call) must be explained in text.
• Someone blind from birth — needs screen-reader-friendly pages, useful alt-text, and audio descriptions of purely visual video content.
• Someone with severe color vision deficiencies — needs cues other than color alone to convey information, including in scientific plots.
• Someone paralyzed from the neck down — uses assistive tech or a keyboard, needs sites easy to navigate with a few buttons.
• Someone with cognitive disabilities like attention disorder — needs straightforward, well-organized, non-distracting sites.

Exceptions [L28-L68]

In all cases we must still provide any noncompliant content in an accessible format if anyone requests it. There are also general exceptions when compliance is unduly burdensome; this exception is likely narrow and may require a lawyer or court to interpret.

Archived Content

Exception for archived content [ADA Fact Sheet: Archived Content]. Content must meet all four criteria:

1. Created before April 24, 2026.
2. Only exists in areas of the website explicitly labeled as archival.
3. Used only for "reference, research, or recordkeeping" — not required as part of a course or to understand/use the site.
4. Not changed since it was archived.

Preexisting Documents

A document is exempt if both:

1. It is a word processing, presentation, PDF, or spreadsheet file, AND
2. It was available on the state or local government's website/app before April 24, 2026.

If a document is currently in use, this exception does not apply. Whether a document is "currently in use" requires human verification — the date alone is not sufficient to determine exemption. We must still provide an accessible version if requested.

Preexisting Social Media Post

Social media posts made before April 24, 2026 are typically exempt.

Password-Protected

Exempt if all three:

1. Word processing, presentation, PDF, or spreadsheet file, AND
2. About a specific person, property, or account, AND
3. Password-protected or otherwise secured.

This does not cover internal documents behind a firewall — only public password-protected documents for specific individuals.

Third-Party Content

Applies to third-party content posted on our websites (e.g., user comments), not to material we link to on third-party sites. User-posted content is partially exempt, but the page itself must conform and a notice of partial conformance must be provided [WCAG 5.4].

All embedded content must conform. If we link to an external website such as GitHub, we are required to ensure that the linked content conforms — regardless of whether we can control it. (GitHub mostly conforms to WCAG 2.1 AA.)

A/V Requirements [L70-L91]

• These requirements apply even to videos embedded in or linked from the site.
• Audio-only or video-only media must provide an alternative method of obtaining equivalent information [WCAG 1.2.1].
• Video needs captions [WCAG 1.2.2, 1.2.4]. AI/algorithmic captions are acceptable for live captioning [WCAG 1.2.4], but prerecorded videos must have human-checked captions [WCAG 1.2.2].
• Non-speech audio (like a sound effect) must be described in the captions.
• Audio descriptions must be provided for all prerecorded video [WCAG 1.2.5].
• AA compliance does not require audio descriptions for live talks [WCAG 1.2.9].
• Audio descriptions of prerecorded video need only fill pauses in existing dialog; if all pauses are filled, adding more is not required [WCAG 2.1 Technique F113].

Live vs. Prerecorded

Requirement	Live	Prerecorded
Captions [WCAG 1.2.2, 1.2.4]	Required; AI/algorithmic acceptable	Required; must be human-checked
Audio descriptions [WCAG 1.2.5, 1.2.9]	Not required at AA	Required (fill dialog pauses)
Alternative for audio/video-only [WCAG 1.2.1]	—	Must provide equivalent text alternative
Non-speech audio (sound effects, etc.)	Described in captions	Described in captions

Conforming Alternate Versions (CAVs)

"Conforming alternate versions" (CAVs) are allowed — separate conforming content on a conformance page. Strict requirements about labeling and access apply — see WCAG 2.1 CAV documentation.

Website Requirements [L93-L116]

• All non-text content should have a text alternative [WCAG 1.1.1]. Images need alt-text; icons/animations should use aria attributes.
• Page organization must be programmatically determinable [WCAG 1.3.1]. Use <h1> tags, not large bold <p>. Don't use whitespace to convey meaning — use lists [WCAG 1.3.2].
• Applies to linked Google Docs and Word documents — use "Title", "Heading 1", "Heading 2" styles instead of bold large text.
• Content shouldn't depend on landscape vs. portrait orientation [WCAG 1.3.4].
• Input widgets (radio buttons, text boxes) should be programmatically understandable and correctly HTML-labeled [WCAG 1.3.5]. Label-in-name [WCAG 2.5.3]. Instructions or a label indicating what is required should be provided [WCAG 3.3.2].
• Pages should have titles that describe their contents [WCAG 2.4.2] and descriptive headings and labels [WCAG 2.4.6].
• Link purpose should be determinable from link text alone or its programmatically determinable context [WCAG 2.4.4].
• Navigation elements consistent across pages [WCAG 3.2.3]. Similar components identified consistently [WCAG 3.2.4].
• Information required to operate or navigate must not rely on sensory information alone (color, sound) [WCAG 1.3.3]. No information conveyed using color alone [WCAG 1.4.1].
• If audio auto-plays, you must be able to stop it [WCAG 1.4.2].
• Contrast ratio must be at least 4.5:1 [WCAG 1.4.3].
• Text must be resizable up to 200% without loss of content [WCAG 1.4.4].
• Don't use images of text [WCAG 1.4.5]. Logos excluded; other exclusions must be "essential".
• Must be able to use a keyboard to navigate all content [WCAG 2.1.1], in an orderly way [WCAG 2.4.3], no keyboard trap [WCAG 2.1.2], visible keyboard focus [WCAG 2.4.7].
• A bypass block must exist for content repeated across multiple pages (e.g., nav bars) [WCAG 2.4.1]. These usually appear as a "skip to main content" link when the user presses tab.
• Must be able to pause auto-playing/scrolling content [WCAG 2.2].
• Don't use content that flashes [WCAG 2.3].
• Non-process web pages must be findable in more than one way [WCAG 2.4.5] (sitemap, navigation menu, search).
• Creative pointer input (gestures, zooming) has additional requirements [WCAG 2.5].
• Page language and part-language must be programmatically determinable [WCAG 3.1.1, 3.1.2] — typically via metadata.
• Don't programmatically change context [WCAG 3.2.1, 3.2.2].
• Forms that generate errors have additional requirements [WCAG 3.3.1, 3.3.3].

Document Requirements [L118-L126]

• Internal Google/Word documents, slides, and spreadsheets must be compliant. (Required by ADA Title I, not Title II — and not new. Any document an external user can find in their browser is covered by Title II.)
• Use built-in styles rather than bold/large normal text.
• Images in documents should have alt text.
• Rules that apply to websites also apply to documents.
• PDFs are complicated. A PDF rendered from a compliant Google doc is likely compliant, but this is hard to test. PDFs are required to be compliant.
• Source code rendered on a webpage via a language-tagged code block is considered compliant.
• Files that cannot be rendered in a browser and must be downloaded and viewed externally are likely not required to be compliant (WCAG 2.1 covers web content). But "conventional documents" — word processing files, spreadsheets, slides — are considered web content even when downloaded.