Compliance Deadline

April 24, 2026

State and local government entities with populations of 50,000+ must conform to WCAG 2.1 Level AA.

Entities under 50,000 population: April 24, 2027

ADA Title II & Web Accessibility for GIS

What Is ADA Title II?

Title II of the Americans with Disabilities Act (ADA) prohibits discrimination on the basis of disability by state and local government entities. In April 2024, the U.S. Department of Justice published a Final Rule that specifically requires state and local government web content and mobile apps to conform to WCAG 2.1 Level AA.

This is the first time ADA has established a specific technical standard for web accessibility. Previously, courts applied WCAG informally. The Final Rule makes WCAG 2.1 AA the legally binding benchmark.

Why This Matters for GIS Applications

State and local government agencies are among the largest users of ArcGIS Experience Builder. Public-facing web maps — zoning viewers, permit trackers, emergency evacuation zones, transit maps, property assessment tools — are “web content” under the Final Rule and must meet WCAG 2.1 AA.

Interactive maps present unique accessibility challenges that go beyond typical web content. Map interactions are gesture-heavy, spatial data is inherently visual, and GIS interfaces often lack the text alternatives and keyboard support that WCAG requires.

Common Experience Builder Compliance Gaps

1.1.1

No data table alternative for map content

Screen reader users cannot access spatial data without a text-based alternative.

1.4.1

Color-only map symbology

Choropleth maps and categorized layers rely on color alone to convey information.

1.4.3

Low-contrast text on map overlays

White text on light basemaps or semi-transparent panels fails contrast requirements.

2.1.1

Keyboard-inaccessible map controls

Custom widgets and toolbar buttons often respond only to mouse clicks.

2.4.7

Missing focus indicators

EB themes frequently suppress or low-contrast focus outlines on map controls.

2.4.2

Generic page titles

Default 'Experience' title instead of a descriptive app name.

3.3.2

Form inputs without labels

Search and filter widgets with placeholder text but no programmatic label.

2.4.1

Missing ARIA landmarks

EB layouts lacking main, nav, and complementary landmark regions.

WCAG vs. ADA: Technical Standard vs. Legal Requirement

WCAG 2.1 is a technical specification published by the W3C. It defines what accessible web content looks like — contrast ratios, keyboard operability, text alternatives, and 49 other testable criteria at Level A and AA.

ADA Title II is a federal civil rights law. The DOJ's Final Rule adopts WCAG 2.1 AA as the specific technical standard that state and local government web content must meet.

In practice: WCAG tells you what to fix. ADA tells you you must fix it, and by when.

Legal Disclaimer

This page provides general information about ADA Title II web accessibility requirements. It does not constitute legal advice. Compliance obligations depend on your specific circumstances. Consult your organization's legal counsel for guidance on your compliance obligations and timeline.