Insights / Research, scanned October 9, 2026
SPECIAL DISTRICT websites and the ADA.
The Justice Department’s web accessibility rule gives special districts until April 26, 2028 to make their websites meet WCAG 2.1 Level AA. We scanned the homepages of 38 Orange County special districts and joint powers agencies to see where they stand.
38
agency homepages scanned
Orange County special districts and joint powers agencies
84%
fail at least one automated check
32 of 38 homepages
30%
of the PDFs we checked are untagged
18 of 61 documents
564
days until the special district deadline
April 26, 2028
The deadlines
TWO
deadlines.
From ADA.gov. The April 2026 interim final rule extended every compliance date by a year; the technical standard did not change.
April 26, 2027
Larger governments
Cities, counties, and other public entities serving 50,000 people or more.
April 26, 2028
Special districts
Special district governments, and public entities serving fewer than 50,000 people.
Findings
WHAT THE
scan found.
We scanned 38 homepages with axe-core on October 9, 2026.
- 01
32 of the 38 homepages (84%) fail at least one automated WCAG 2.1 check. The median homepage fails 2 kinds of check, on 6 page elements. 10 homepages have at least one failure that axe-core rates critical, such as an image with no text alternative or a button with no name.
- 02
The most common problem is low-contrast text, found on 14 homepages, followed by links with no readable name (13). Both are usually fixed once, in the site’s template.
- 03
18 of the 61 PDFs we checked are untagged, so screen readers cannot follow their structure. 5 have no text layer at all, which usually means a scanned page, and 20 do not declare a language.
- 04
11 agencies load an accessibility overlay (7 accessiBe, 3 UserWay, 1 AudioEye). 10 of those 11 homepages still fail at least one automated check with the overlay running.
- 05
Automated scans catch only part of what WCAG covers. Keyboard use, reading order, captions, and document structure need a person to check, so a homepage that passes every automated check is not necessarily accessible.
The most common failures
Number of homepages with each failure, of 38.
Before 2028
WHAT TO DO
first.
These six steps are in the order that usually saves the most work.
Ask for a scan- 01
Scan, then test by hand
Run an automated scan across the whole site, then check the key pages with a keyboard and a screen reader. Automated tools find only part of the problems.
- 02
Fix the template first
Contrast, link names, labels, and headings usually live in the theme, so one fix repairs every page that uses it.
- 03
Make new documents accessible
Agendas, packets, and notices posted from now on should be tagged PDFs or web pages. Older documents can stay as they are only if no one needs them to use a service.
- 04
Set up an archive
Content kept only for reference can be exempt if it was created before the deadline, sits in a separate archive area, and is not changed.
- 05
Publish a way to ask for help
Add an accessibility page that gives a contact for anyone who cannot use part of the site, and commit to responding.
- 06
Put it in the contract
Require WCAG 2.1 Level AA from your website, agenda, and payment vendors, and train the staff who post content.
What is exempt
FIVE
exceptions.
Summarized from ADA.gov. The exceptions do not remove an agency’s duty to provide effective communication or reasonable modifications when someone asks.
Archived content
Content created before the compliance date is exempt if it is kept only for reference, research, or recordkeeping, held in a special archive area, and left unchanged.
Older documents
PDFs, Word files, presentations, and spreadsheets posted before the compliance date are exempt, unless people use them now to apply for or access a service.
Third-party posts
Content posted by members of the public who are not working for the agency is exempt. Content the agency or its vendors post is covered.
Individual documents
Password-protected files about one person, property, or account, such as a bill, are exempt.
Older social media posts
Social media posts made before the compliance date are exempt.
For agencies
YOUR AGENCY’S
results.
Agencies in the review can ask for their own results: every failure on the homepage, the PDFs we checked, and the fixes that would clear the most problems. We run the same scan for agencies outside the review.
Ask for your resultsMethod
The agencies are the special districts in OC LAFCO’s directory, plus joint powers agencies, commissions, and the county law library with websites of their own, 41 in total. Each homepage was loaded in Chromium on October 9, 2026 and scanned with axe-core for WCAG 2.0 and 2.1 Level A and AA rules. 3 sites blocked automated visits and are left out, which leaves 38. PDFs are up to eight documents linked from each homepage; 61 from 27 homepages opened and were checked for tags, a text layer, and a declared language, and 7 that failed to download were left out. Overlay scripts were identified in each homepage’s source on October 10. We publish totals only; no agency is named.
Rule details: ADA.gov, Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps. This page is a summary, not legal advice.
When do special district websites have to meet the ADA rule?
By April 26, 2028. The Justice Department’s interim final rule of April 20, 2026 moved the date back a year for every group. Public entities serving 50,000 people or more have until April 26, 2027.
What standard does the rule use?
WCAG 2.1 Level AA, the Web Content Accessibility Guidelines published by the World Wide Web Consortium. It applies to the agency’s website and mobile apps, including content that vendors provide for it.
Does an accessibility overlay make a website compliant?
An overlay adds a toolbar on top of the page. In our scan, 10 of the 11 homepages with an overlay still failed at least one automated check with the overlay running, so the page itself still needs fixing.
Do old agendas and PDFs need to be fixed?
Documents posted before the compliance date are exempt unless people use them now to apply for or access a service. New agendas, packets, and forms posted after the date are covered.
Which agencies did you scan, and can we see our results?
We scanned the homepages of 38 Orange County agencies: the special districts in OC LAFCO’s directory, plus joint powers agencies, commissions, and the county law library with websites of their own. We do not publish results by agency. An agency can ask for its own results, and we can run the same scan for agencies outside the review.
What does fixing a website usually involve?
Most of the work is in the template: color contrast, link and button names, form labels, and heading structure. Documents are the second part, usually by moving recurring items such as agendas to tagged PDFs or web pages. We quote after looking at the site.
Contact Endcap
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project.
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Start a project or call or text Noah at (425) 233-0769