WCAG 2.1 Level AA: What You Need to Know About the New ADA Requirements for 2026

While information rich, the official W3 Web Content Accessibility Guidelines is exhaustive and technical, while also containing abundant information to wade through about medias beyond website content. Putting it plainly, these guidelines can be overwhelming, even for the savviest website content producers. Let’s break the requirements down to the most crucial pieces to follow, and how Foxbright will continue to support our partners during this transition and into the future. 

What You Need to Know

Many organizations are starting to plan for the upcoming federal ADA website accessibility deadlines. This federal government resource page provides information about the changes and requirements and serves as a primer for communication specialists with minimal-to-advanced experience with ADA standards by highlighting key requirements, what to prioritize, and suggestions on how to proceed as an organization. The W3 ‘What’s New in WCAG 2.1’ post is a more targeted resource to help understand specific changes from WCAG 2.0 to 2.1. 

Under the Department of Justice’s updated Title II rules, public entities are required to meet WCAG 2.1 AA standards by:

• April 2026 for larger entities
• April 2027 for smaller entities

Notable Changes to Requirements

WCAG 2.0 built the foundation for modern web compliance standards with a focus on primary websites. 2.1 is less about new requirements, and more about expanding existing 2.0 standards to other mediums like website mobile UI, social media, emails and physical displays. In essence, most requirements relating to website-based communications are relatively unchanged, but now also apply to the mobile/responsive presentation of websites. For specialists managing communication methods beyond the website, incorporating best practices that existed for website-based content into other mediums will be a good start to ensure all resources are compliant. We recommend reviewing the resources linked above for specifics regarding other channels of communication. 

Highlights Include:

• Ensure social media content (and other communications) adhere to ADA standards.
• Review captioning and transcript requirements for mixed media like video or podcasts. 
• The ADA.gov guidelines overview highlights exceptions to requirements eg some files that existed prior to requirements and that serve for archival purposes (rather than current policy) may not require remediation. 
  • Similarly, items like social media posts created prior to requirements do not need to be updated retroactively.
  • There are guidelines on what 3^rd party content being shared has compliance requirements or not. 

Foxbright’s System and WCAG 2.1

• Standards Now Applied to Mobile UI – Foxbright’s platform has been mobile responsive for years and thus adheres to 2.1 requirements for content reflow and orientation.  
• Reporting Protocol – Foxbright’s ADA reporting service was upgraded to 2.1 standards early 2025. Any issues relating to new standards have already been included in the reports. No surprises expected when the requirements become official!
• System Changes – The Foxbright CMS has generally adhered to 2.1 requirements for years. We have identified and resolved a few minor changes within our code to accommodate nominally more stringent requirements in areas relating to screen-reader labels, calendar grids, and tab-based content areas. 
• Content Requirement – 2.1 has introduced a requirement for distinct pages with the same menu name even when not displayed together. Multiple pages with the same name were acceptable for 2.0 standards when these items were not displayed together on a given page, such as a sub-sited area of a website. 2.1 now extends to the navigation displayed with the mobile UI, which by design, defaults to include access to all pages within a website. Practical options:
  • Update Menu Names – Foxbright’s CMS makes it easy to change page menu names within page settings. If multiple pages have the same menu name, they should be updated to be unique to adhere to this requirement. 
  • Hide Pages from Menus – Most designs support a dedicated mobile subpage menu to allow navigating to subpages once the landing page is visited. It may be desired to hide certain pages from the main mobile navigation slide out to satisfy the requirement of not including same-name pages within the main navigation. These items would then be available to visitors once they visit the parent/landing page for these items via the mobile subpage menu. Please contact [email protected] with questions or to determine if this option is applicable. Some design adjustments may be required if the subpage menu was not previously used. 
  • Combine Resources – If multiple areas of a website have a page with the same name, eg 'Calendars', it may be appropriate to link all same-name pages to a single shared destination. Using the Calendars example, all organizational calendars could be displayed on a single unified page instead of multiple 'Calendars' pages displaying distinct calendars. 
    
    Note: Only some websites will encounter this issue, namely larger websites with sub-sited navigation where departments, buildings, or other organizational units may have a subpage with the same name as another area on the site. Page redirects with the same name that link to the same destination do not apply to the requirement. 

Additional Services

Foxbright’s ADA compliance services go beyond launch. We offer:

• Comprehensive website audits to benchmark where you are and what needs attention. 
• Remediation and cleanup support for any accessibility issue that crop up.
• Ongoing monitoring and reports to keep your site compliant as content grows and changes over time. Reports include scans of unlimited webpages or files hosted and linked to within the site.
• Training for your team so web editors understand how to create and maintain accessible content.

That means not only do you have a compliant site from day one, but you also have a system and a partner that helps maintain compliance long into the future without surprises.

Resources

• MSU Accessible Content Tutorials - One of the best collections of accessibility tutorials we know of. Explains creating accessible content across various file types and medias. 
• OCR Video Series - In-depth collection of videos covering ADA topics and best practices, produced by the Office of Civil Rights. 
• W3.org
• ADA.gov 
• WebAIM Tutorials
• WAVE Accessibility Checker - free compliance scanning tool for those without other reporting solutions. Only scans 1 page at a time. 

Our Commitment 

It’s understandable to be nervous about changes to legal requirements and deadlines. Rest assured that when you partner with Foxbright, you have decades of experience with ADA compliance and broader web practices behind you and your organization. We constantly monitor compliance requirements and react immediately if technical system changes are required. We have worked directly with Office of Civil Rights (OCR) agents for years, both to adhere to their recommendations, and to support our partners that have been cited to assure a speedy resolution. This commitment ensures our partner’s success and a peace-of-mind that we will back-up your team in the increasingly rare event of a citation. Historically, the Foxbright CMS has met or exceeded ADA guidelines and we are committed to proactively respond to future changes, ensuring requirements are met well ahead of deadlines.