Website Accessibility Audit: How to Prepare for the April 2026 ADA Compliance Deadline

The clock is ticking. On April 24, 2026, the Department of Justice's final rule on web accessibility for state and local governments takes full effect — and private businesses are next in line.

If you haven't run a website accessibility audit yet, you're running out of time. The legal landscape has shifted dramatically. Courts no longer debate whether websites fall under the ADA. They do. The only question is whether yours complies.

This guide walks you through exactly what a website accessibility audit covers, why the April 2026 deadline matters, and how to protect your business from the lawsuits that are already accelerating.

What Is a Website Accessibility Audit?

A website accessibility audit is a systematic review of your website against the Web Content Accessibility Guidelines (WCAG) 2.2 — the international standard that courts, regulators, and the DOJ reference when evaluating whether a website is accessible to people with disabilities.

The audit evaluates every element of your site:

• Visual design — color contrast, text sizing, focus indicators
• Navigation — keyboard accessibility, skip links, logical tab order
• Content — alt text for images, video captions, readable heading hierarchy
• Forms — labeled inputs, error messages, accessible validation
• Interactive elements — dropdown menus, modals, accordions, carousels
• Documents — accessible PDFs, downloadable content

A proper audit combines automated scanning tools with manual testing to catch issues that tools alone miss. Automated tools typically catch about 30-40% of accessibility issues. The rest require human evaluation — testing with screen readers, keyboard-only navigation, and cognitive accessibility review.

Why the April 24, 2026 Deadline Matters

In April 2024, the DOJ published its final rule under Title II of the ADA, requiring state and local government websites to conform to WCAG 2.1 Level AA. The compliance deadline for entities with populations under 50,000 is April 24, 2026.

But here's what most business owners miss: this isn't just a government problem.

Private businesses have been getting sued under Title III of the ADA for website accessibility since 2017. The DOJ rule for government websites has created a ripple effect:

1. It establishes WCAG as the legal standard. Courts that were previously ambiguous now have clear DOJ guidance pointing to WCAG 2.1 AA (with many already referencing WCAG 2.2).
2. Plaintiff attorneys are using the deadline as leverage. Demand letters now cite the DOJ rule even when targeting private businesses.
3. Insurance companies are starting to ask about compliance. Some carriers are including web accessibility questions in their coverage assessments.

The April 2026 deadline is the most significant web accessibility milestone since the ADA was enacted in 1990.

The Lawsuit Numbers Are Staggering

Let's look at the data:

• 2023: 4,605 ADA website accessibility lawsuits filed
• 2024: 4,800+ lawsuits filed (estimated, final numbers still being compiled)
• 2025: On pace to exceed 5,000 lawsuits
• Average settlement for small businesses: $5,000–$25,000
• Average legal defense cost (if you fight): $10,000–$50,000+

The plaintiffs targeting small businesses aren't random. They use automated scanning tools to identify websites with obvious WCAG violations, then send demand letters at scale. It's a volume business for the law firms involved.

The most targeted industries:

• E-commerce and retail
• Restaurants and food service
• Healthcare and dental practices
• Real estate
• Professional services (lawyers, accountants, consultants)
• Nonprofits (yes, nonprofits)

If your business has a public-facing website in any of these sectors, you're in the crosshairs.

How to Run a Website Accessibility Audit

Step 1: Automated Scan

Start with an automated accessibility scan. This catches the low-hanging fruit — missing alt text, contrast failures, broken ARIA labels, and form labeling issues.

Our free Website Intelligence Report runs a comprehensive scan in about 30 seconds. It checks your site against WCAG 2.2 criteria and gives you a prioritized list of issues with severity ratings.

An automated scan is not a complete audit, but it's the essential first step. It tells you where you stand and what needs immediate attention.

Step 2: Manual Testing

After your automated scan, you need manual testing for issues that tools can't detect:

Keyboard navigation test:

• Can you reach every interactive element using only Tab, Enter, and Arrow keys?
• Is there a visible focus indicator on every focused element?
• Can you escape from modals and dropdown menus?
• Does the tab order follow a logical reading sequence?

Screen reader test:

• Do all images have meaningful alt text (not just "image.jpg")?
• Are form fields properly labeled?
• Do headings create a logical document outline?
• Are dynamic content changes announced?

Cognitive accessibility:

• Is the language clear and readable?
• Are instructions explicit (not just "click here")?
• Do error messages explain what went wrong and how to fix it?
• Is content organized with clear visual hierarchy?

Step 3: Prioritize Fixes

Not all accessibility issues carry equal legal risk. Prioritize based on impact:

Critical (fix immediately):

• Missing alt text on images
• Forms without labels
• No keyboard navigation
• Insufficient color contrast (below 4.5:1 ratio)
• Missing skip navigation links
• Auto-playing audio or video

High (fix within 30 days):

• Broken heading hierarchy
• Missing ARIA landmarks
• Links that don't describe their destination
• Missing focus indicators
• Inaccessible PDF documents

Medium (fix within 90 days):

• Missing captions on videos
• Complex data tables without proper markup
• Inconsistent navigation patterns
• Missing language attributes

Step 4: Implement Fixes

The technical fixes range from simple HTML changes to architectural updates:

Quick wins (under 1 hour each):

- Add alt attributes to all images
- Add labels to all form inputs
- Fix color contrast ratios
- Add a skip navigation link
- Set the page language attribute

Medium effort (1-4 hours each):

- Fix heading hierarchy across all pages
- Add ARIA landmarks (main, nav, footer, etc.)
- Make all interactive elements keyboard accessible
- Add focus visible styles
- Fix form validation to be accessible

Significant effort (1-2 days each):

- Rebuild navigation to be fully keyboard accessible
- Add captions to all video content
- Make complex widgets (carousels, tabs) ARIA-compliant
- Convert inaccessible PDFs to accessible format
- Implement accessible modal/dialog patterns

Step 5: Ongoing Monitoring

Accessibility isn't a one-time project. Every content update, new page, or design change can introduce new issues. You need continuous monitoring.

Set up automated weekly scans that alert you to new violations before they become lawsuit material. This is exactly what our automated accessibility monitoring does — continuous scanning, instant alerts, and compliance documentation.

Common Mistakes That Get Businesses Sued

Relying on Accessibility Overlays

Those widgets that promise "one-click ADA compliance" with a toolbar overlay? They don't work. Multiple courts have ruled that overlay widgets do not constitute compliance. The National Federation of the Blind has publicly opposed them. And plaintiffs specifically target sites using overlays because they know the underlying code is still broken.

Assuming a "Clean" Template Is Accessible

WordPress themes, Shopify templates, and website builders often market themselves as "accessible." Most aren't. They may pass basic automated checks while failing miserably on manual testing. A template is a starting point, not a compliance guarantee.

Ignoring Third-Party Content

Your website's accessibility obligations extend to embedded content — third-party booking widgets, chatbots, social media feeds, and payment forms. If it's on your site, it needs to be accessible.

Treating Accessibility as a One-Time Fix

You fixed your alt text last year. Great. But you've added 47 new images since then, and 31 of them have no alt text. Accessibility requires process change, not just code change.

What a Lawsuit Actually Costs

Let's break down the real cost of an ADA website accessibility lawsuit for a small business:

Cost Category	Range
Demand letter settlement	$5,000 – $25,000
Legal defense (if you fight)	$10,000 – $50,000+
Website remediation (emergency)	$3,000 – $15,000
Lost business during proceedings	Varies
Insurance premium increase	10-25%
Total potential exposure	$18,000 – $90,000+

Compare that to the cost of proactive compliance:

Prevention	Cost
Professional accessibility audit	$500 – $2,000
Remediation (planned, not emergency)	$1,000 – $5,000
Ongoing monitoring	$100 – $500/month
Total annual cost	$2,700 – $11,000

The math is clear. Prevention costs a fraction of remediation under legal pressure.

Your Action Plan Before April 2026

Here's exactly what to do, in order:

1. Run a free accessibility scan today. Use our Website Intelligence Report to see where you stand. It takes 30 seconds and requires no signup.

2. Fix critical issues within 2 weeks. Missing alt text, form labels, keyboard navigation, and contrast failures. These are the violations that appear most often in lawsuits.

3. Schedule a comprehensive audit within 30 days. Get a manual review by accessibility experts who test with actual assistive technology.

4. Set up continuous monitoring. New content means new potential violations. Automated monitoring catches problems before attorneys do.

5. Document everything. Keep records of your audits, fixes, and accessibility policy. Courts consider good-faith compliance efforts.

6. Publish an accessibility statement. A public commitment to accessibility on your website demonstrates good faith.

The Bottom Line

The April 24, 2026 deadline isn't just for government websites. It's the date that cements WCAG compliance as the undeniable legal standard for everyone. Plaintiff attorneys know this. They're already preparing their 2026 campaign.

You have two options: spend a reasonable amount now on proactive compliance, or spend 5-10x more later when a demand letter arrives.

The audit takes 30 seconds. The lawsuit takes 6-12 months.

Run your free website accessibility audit now →

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CT Solutions provides automated accessibility auditing, monitoring, and remediation. Our Accessibility Shield service continuously scans your site, alerts you to new issues, and generates compliance documentation — giving you protection and peace of mind.