Web design

August 2026 · 8 min read

ADA and accessibility for commercial real estate websites.

Most brokers meet this subject for the first time in a demand letter. That is an expensive way to learn it, and unnecessary, because getting a property site close to right is less work than arguing about it afterward. Here is what the standards require, where our industry's sites fail in ways specific to our business, and a pass you can run this week.

What the rules actually are

Three separate things get blurred together, and separating them makes the subject manageable. The first is the technical standard. WCAG, the Web Content Accessibility Guidelines, is published by the W3C, and Level AA is the conformance level everyone means when they say a site should be accessible. Version 2.1 is the one written into current federal regulation; version 2.2 became a W3C Recommendation in October 2023 and adds a few criteria on top, so building to 2.2 AA satisfies both. The guidelines are free at w3.org, and the plain-language companion, "How to Meet WCAG," is the version worth sending a designer.

The second is federal law. Title III of the ADA covers places of public accommodation and never names websites, which is why courts have split for twenty years. The Department of Justice is not ambiguous, though: its March 2022 "Guidance on Web Accessibility and the ADA" states that web accessibility is required of Title III businesses, without adopting a technical standard for them. Title II, covering state and local governments, does have a hard rule. The DOJ's final rule of April 24, 2024 adopts WCAG 2.1 Level AA for public entities, due April 24, 2026 for those serving 50,000 people or more and April 26, 2027 for smaller ones. If you market to public agency tenants or respond to city and district RFPs, the standard follows the counterparty.

The third is state law, and in California it is the part with teeth. The Unruh Civil Rights Act treats an ADA violation as an Unruh violation, and California Civil Code section 52 sets statutory damages at a minimum of four thousand dollars per offense plus attorney's fees. That structure is why website access claims are filed in volume here. I am a broker, not your lawyer, and none of this is legal advice. But an owner weighing whether this is worth an afternoon should know the exposure is statutory rather than theoretical.

As for how common failures are: WebAIM, the accessibility group at Utah State University, scans one million home pages a year and publishes the results as the WebAIM Million. In every edition since 2019 it has detected WCAG failures on more than nine of ten pages tested, with low-contrast text, missing alternative text, and unlabeled form inputs topping the list. Automated scanning catches only a fraction of the criteria, so the real number is higher. The useful part: a handful of problems account for most of it, so a focused pass gets you most of the way.

Where commercial real estate sites fail, specifically

Generic accessibility advice does not describe our sites well, because they are made of things other industries do not build. These are the failures we actually find:

• The interactive site plan. A center's plan is usually an image or an SVG with clickable suites, and the information inside it exists only as shapes. A screen reader announces nothing useful, and neither does Google. The fix is not to abandon the plan but to publish the same availability as real text beside it: suite, square footage, status.
• Text over hero photography. White type on a drone still is the house style of this entire industry, and it is where contrast fails most often. WCAG 2.1 AA asks for a 4.5 to 1 ratio on normal text and 3 to 1 on large text. A photograph is not a fixed background, so the fix is a scrim or a solid panel behind the type, not eyeballing it on a bright monitor.
• Autoplaying drone film. Moving content that plays automatically for more than five seconds needs a way to pause or stop it. A short muted loop is fine. A ninety second aerial that starts on its own with no controls is a failure, and a page speed problem too, which we covered in page speed for property websites.
• The inquiry form. Placeholder text is not a label. When the field says "Name" in gray and that text vanishes as soon as someone types, a screen reader user gets an unlabeled box. Visible labels, error messages in text rather than color alone, and a focus outline you did not delete in the stylesheet.
• Suite status by color alone. Green for available, gray for leased. Color cannot be the only carrier of meaning. Add the word.
• Alt text nobody wrote. Alt text says what a prospect would learn from seeing the image. "Storefront of the vacant corner suite facing Lincoln Ave" is useful. "IMG_4821" and "shopping center" are not.
• Map and tour embeds. You inherit whatever accessibility a third party embed has. Publish the address as selectable text beside the map, and never make a tour the only way to understand a layout.

The flyer is the part nobody checks

Here is the gap specific to commercial real estate. Our industry moves on PDFs. The flyer gets emailed, attached to portal listings, and printed for tours, and almost every leasing flyer in circulation is a flattened design export with no tag structure, no reading order, and no useful text layer. A screen reader opens it and finds a picture of a document.

A flyer that cannot be read aloud is not a small accessibility problem. It is the single most forwarded file in the entire campaign.

We will be straight about our own work here, because this is a real tension rather than a solved problem. The seven-page flyer we produced for the 5801 Lincoln listing, a 2,660 square foot corner suite in Buena Park taken from brief to live in three days, is flattened on purpose so it scrolls smoothly in a browser instead of stalling. Flattening is good for the reader in a Chrome tab and bad for the reader using assistive technology. Our answer is not to pretend the PDF is accessible. It is to make sure the listing page carries every fact the flyer does as real HTML text: suite facts, traffic counts with sources, demographics, contacts. Nobody should have to open a PDF to learn how big the space is or who to call. A genuinely accessible flyer is a tagged PDF with a defined reading order, produced deliberately, and worth asking for when a public agency is on the other side of the deal. Otherwise the web page is the accessible version of record. See our flyer design guide and the Lincoln case study.

What we do on our builds

We hand-write the HTML and CSS on every project, which is practical rather than philosophical: accessibility problems are mostly structural, and structure is what a page builder decides for you. Headings run in order and describe the section instead of being picked for their font size. Every interactive element is a real button or link, reachable by keyboard without extra code. Focus outlines stay. Alt text is written by whoever wrote the listing copy, because they know what the photo is meant to prove.

On the Marbella Plaza site, a 66,124 square foot grocery-anchored center, the availability table is the source of truth and the interactive site plan is the visual index of it. Both say the same thing, and one of them works without vision, a mouse, or JavaScript. That was a decision made for tenant reps skimming on a phone before it was ever an accessibility decision, which is usually how this goes. The Marbella case study covers the rest of the build. What we will not do is call a site certified compliant. There is no such certification, and conformance is a judgment about a specific site at a specific moment. What we can tell you is what was checked, by whom, and against which criteria.

About the overlay widgets

You have seen the pitch: one line of JavaScript, an icon in the corner, compliance handled. Practitioners have pushed back hard, most visibly through the Overlay Fact Sheet at overlayfactsheet.com, signed by hundreds of accessibility professionals, many of them screen reader users. Regulators noticed too: in January 2025 the Federal Trade Commission announced a settlement with overlay vendor accessiBe over claims about its product's ability to make sites WCAG compliant. A widget is a script layered over the markup, not a fix to it. The page underneath either has labeled fields and readable contrast or it does not.

A pass you can run this week

• Unplug the mouse. Tab through your busiest property page from the top. You should always be able to see where you are, and you should be able to reach and submit the inquiry form. This test finds more than any scanner.
• Run a free automated scan. WAVE from WebAIM and the axe DevTools extension flag contrast, missing alt text, and unlabeled inputs in seconds. They catch a minority of the criteria, so a clean report is a floor.
• Zoom to 200 percent. Text should reflow and stay readable without horizontal scrolling.
• Read one photo's alt text out loud. If it tells you nothing a prospect would want to know, rewrite it.
• Open your own flyer and try to select a sentence. If nothing selects, confirm everything in it exists on the page too.
• Turn on your phone's screen reader for two minutes. VoiceOver on iOS, TalkBack on Android. It is awkward the first time, and it will tell you more than a report will.

What to ask whoever builds it

Three questions produce useful answers. Which conformance level are you building to, and how will you check it. Who writes the alt text, and is it in the content scope or an afterthought at launch. When availability changes, does the accessible version of that information change with it, or only the graphic. There is a longer list of vendor questions in how to choose a commercial real estate web design firm, and you can see how we scope the work in our services.

The argument that gets owners to act is the legal one, and it is a real argument. The better one is quieter. A tenant rep with low vision, an owner reading a rent roll on a phone in the sun, a broker tabbing through a form because the trackpad is unreliable in a truck: accessible pages hold up under conditions you did not design for. That is most conditions.