US Americans with Disabilities Act (ADA) - Title III Digital Accessibility
Evidence request list. 13 controls, 13 carrying auditor artefact guidance. Generated from the compliance knowledge graph on 12 September 2026. Published by The Art of Service.
Auxiliary Aids and Digital Content
Digital platforms of public accommodations must be accessible to individuals with disabilities.
- Accessibility statement published on website
- VPAT (Voluntary Product Accessibility Template) for procured products
- Auxiliary aids and services request handling procedure
- Assistive technology test results (screen readers, voice control)
- Captioning and transcripts missing for media
- No documented WCAG conformance level for primary digital channels
- Mobile apps excluded from accessibility programme scope
- Procurement does not require VPAT or equivalent
Compliance
Per DOJ ADA Title II Rule: compliance timeframes (24 months for state/local government >50k population) + exceptions including fundamental alteration and undue burden + record-keeping.
- ADA evidence for USADA-2
- WCAG + compliance timeline partial
DOJ Web Accessibility Guidance (WCAG 2.1 Level AA)
DOJ references WCAG 2.1 Level AA as the standard for digital accessibility compliance.
- VPAT (Voluntary Product Accessibility Template) for procured products
- Accessibility remediation backlog and tracking
- WCAG 2.1 AA conformance audit reports
- Auxiliary aids and services request handling procedure
- Procurement does not require VPAT or equivalent
- No documented WCAG conformance level for primary digital channels
- Mobile apps excluded from accessibility programme scope
- Captioning and transcripts missing for media
Web content must be presentable to users in ways they can perceive, including text alternatives.
- Accessibility statement published on website
- Auxiliary aids and services request handling procedure
- VPAT (Voluntary Product Accessibility Template) for procured products
- Assistive technology test results (screen readers, voice control)
- Forms and error messages not programmatically accessible
- Procurement does not require VPAT or equivalent
- No documented WCAG conformance level for primary digital channels
- Mobile apps excluded from accessibility programme scope
User interface components and navigation must be operable by all users including keyboard-only users.
- Assistive technology test results (screen readers, voice control)
- Auxiliary aids and services request handling procedure
- Accessibility statement published on website
- WCAG 2.1 AA conformance audit reports
- Forms and error messages not programmatically accessible
- Captioning and transcripts missing for media
- Mobile apps excluded from accessibility programme scope
- Procurement does not require VPAT or equivalent
Information and operation of the user interface must be understandable to all users.
- WCAG 2.1 AA conformance audit reports
- Assistive technology test results (screen readers, voice control)
- Accessibility remediation backlog and tracking
- Accessibility statement published on website
- Mobile apps excluded from accessibility programme scope
- Captioning and transcripts missing for media
- No documented WCAG conformance level for primary digital channels
- Procurement does not require VPAT or equivalent
Content must be robust enough to be reliably interpreted by assistive technologies.
- Assistive technology test results (screen readers, voice control)
- Accessibility remediation backlog and tracking
- Auxiliary aids and services request handling procedure
- WCAG 2.1 AA conformance audit reports
- Captioning and transcripts missing for media
- Procurement does not require VPAT or equivalent
- No documented WCAG conformance level for primary digital channels
- Mobile apps excluded from accessibility programme scope
Enforcement
Per ADA Title III: private right of action + DOJ enforcement + class actions + serial litigation risk.
- ADA evidence for USADA-4
- WCAG + compliance timeline partial
Enforcement and Penalties
Civil penalties up to 5,000 for first violation and 50,000 for subsequent violations.
- Written biometric consent forms
- Retention and destruction schedule
- Biometric data storage security controls
- Disclosure log and prohibition attestation
- Litigation and settlement file
- Written informed consent missing or generic
- Retention schedule exceeds statutory 3-year ceiling
- Disclosure to third parties not logged
- No publicly available biometric data policy
Individuals may bring civil actions for injunctive relief against Title III violations.
- Written biometric consent forms
- Retention and destruction schedule
- Biometric data storage security controls
- Disclosure log and prohibition attestation
- Litigation and settlement file
- Written informed consent missing or generic
- Retention schedule exceeds statutory 3-year ceiling
- Disclosure to third parties not logged
- No publicly available biometric data policy
Attorney General may bring civil actions and obtain monetary damages for pattern or practice violations.
- Written biometric consent forms
- Retention and destruction schedule
- Biometric data storage security controls
- Disclosure log and prohibition attestation
- Litigation and settlement file
- Written informed consent missing or generic
- Retention schedule exceeds statutory 3-year ceiling
- Disclosure to third parties not logged
- No publicly available biometric data policy
Procurement
Per ADA: accessible procurement + VPAT + documentation + training + maintain accessibility over time.
- ADA evidence for USADA-3
- WCAG + compliance timeline partial
Title III Communication
Per ADA Title III + DOJ 2024 Final Rule: effective communication including web + mobile accessibility. WCAG 2.1 Level AA conformance for state and local government per Title II + DOJ guidance for Title III.
- ADA evidence for USADA-1
- WCAG + compliance timeline partial
Assembled from the framework’s own control set, so this list is regenerated rather than written and stays current as the graph does.