AccessLumens Research · July 2026
The State of US Local Government Accessibility 2026
The ADA Title II deadline passed on April 24, 2026. 42% of city sites still have a critical accessibility barrier.
Under the Department of Justice’s 2024 ADA Title II rule, state and local governments serving 50,000 or more residents had until April 24, 2026 to make their web content conform to WCAG 2.1 Level AA. We scanned 221 of the largest US city governments after that deadline — homepage and a resident service page each — to ask a simple question: did they make it?
42%
Still have a critical barrier
of 158 scored cities
45%
Fail WCAG 4.1.2
most-litigated criterion
23%
Blocked automated audit
aggressive bot-walls
93
Average score
out of 100
The nuance that matters: city sites are not catastrophically broken. The average score across the 158 scored cities was 93 out of 100. But 42% still carried at least one critical barrier after the compliance deadline — a control a resident cannot operate: a button a screen reader announces as nothing, a menu a keyboard user can never reach, a link with no discernible purpose. A good score and a locked-out resident are not mutually exclusive.
And unlike a retailer, a city is not optional. If its permit form, tax portal, or council page is unusable with assistive technology, there is no competitor to switch to — and, post-deadline, there is a legal obligation it is now missing.
“A city site can score 93/100 and still lock a resident out of paying a water bill.”
Key findings
1. Your city’s CMS vendor predicts its accessibility risk — by a factor of 3.
In our sample, cities running CivicPlus (n=32) had a critical barrier 72% of the time — 3× the rate of cities on Granicus / Vision / OpenCities (n=37, 24%). Same public officials, same budgets, same legal obligation — yet the platform underneath is one of the strongest signals of whether residents get an accessible experience. This is an observed association across the cities we scanned, not a controlled comparison; a vendor’s customers may differ in other ways.
2. Nearly half of city sites fail the criterion most cited in ADA lawsuits.
45% of cities had failures under WCAG 4.1.2 (Name, Role, Value) — the requirement that interactive elements announce what they are and what they do to assistive technology. It is the single most common thread in US digital-accessibility complaints.
3. Almost a quarter of city sites could not be audited at all.
23% of the sites we attempted (51 of 221) sat behind bot protection aggressive enough to block an automated accessibility scan running a real browser. That is a finding in itself: the same walls that stop a scanner can interfere with monitoring tools, and over-aggressive challenges can themselves create barriers for users of assistive technology.
4. The biggest cities do best — but no size tier is clean.
Cities over one million residents had the lowest critical-barrier rate (13%), while mid-size cities of 100,000–250,000 fared worst (44%) — often the tier with the least in-house accessibility staffing. Every tier still left residents facing critical barriers.
5. Compliance is achievable — 11 cities proved it.
11 of the scored cities posted a perfect 100 across every page we tested, and 58% had no critical barrier at all. A conformant city site is a normal, reachable outcome — not a moonshot.
The platform gap: accessibility by CMS vendor
A handful of vendors power most US municipal websites. We fingerprinted each city’s platform and compared them. The spread is stark — and it is the clearest lever a city has: the platform you buy sets your accessibility floor.
Critical-barrier rate by CMS vendor
Share of cities on each platform with at least one critical barrier. Lower is better.
| CMS vendor | Cities | Avg score | % with critical | Issue types/city |
|---|---|---|---|---|
| Granicus / Vision / OpenCities | 37 | 96 | 24% | 1.1 |
| WordPress | 8 | 94 | 38% | 1.8 |
| Drupal | 20 | 94 | 45% | 1.6 |
| Municode | 17 | 93 | 47% | 2.3 |
| CivicPlus | 32 | 90 | 72% | 3.2 |
If you procure or manage a government site, this is the most actionable row in the study: platform choice and template configuration move the floor for every page you publish. Vendors with small samples (fewer than eight cities) are omitted from this table to keep the comparison fair.
The lawsuit-relevant picture
We mapped every finding to the five WCAG success criteria most frequently cited in US digital accessibility litigation:
Failures by lawsuit-relevant success criterion
Share of cities with at least one failure under each criterion.
| Success criterion | Cities affected |
|---|---|
| 4.1.2Name, Role, Value | 45% |
| 1.4.3Contrast (Minimum) | 28% |
| 1.1.1Non-text Content (alt text) | 22% |
| 2.4.4Link Purpose (In Context) | 13% |
| 2.1.1Keyboard | 11% |
ADA Title II mandates WCAG 2.1 Level AA. Because our engine tests against WCAG 2.2 AA — a superset — every city that fails here also fails the 2.1 AA bar the deadline set. Each row is unfinished compliance work.
Where barriers concentrate: by page type
Homepages carried more critical barriers than the resident service pages behind them — the opposite of what many teams assume.
Share of pages with a critical issue
| Page type | Pages | Avg score | % with critical |
|---|---|---|---|
| Homepage | 157 | 93 | 34% |
| Service / payments page | 119 | 94 | 25% |
By population tier
Larger cities fared slightly better — but every tier left residents facing critical barriers.
| Population | Cities | Avg score | % critical | Most common failure |
|---|---|---|---|---|
| 100,000 – 250,000 | 98 | 93 | 44% | Color contrast |
| 250,000 – 500,000 | 30 | 93 | 43% | Color contrast |
| 500,000 – 1M | 22 | 94 | 41% | Missing image alt text |
| 1M+ | 8 | 95 | 13% | ARIA hidden focusable elements |
The most common failures
Share of cities where each issue appeared at least once.
| Issue | Severity | Cities |
|---|---|---|
| Elements must meet minimum color contrast ratio thresholdsColor & Visual Accessibility | Serious | 28% |
| Elements must only use permitted ARIA attributesStructure & Semantics | Serious | 17% |
| Links must have discernible textNavigation | Critical | 13% |
| Certain ARIA roles must contain particular childrenStructure & Semantics | Critical | 13% |
| Images must have alternative textImages & Media | Moderate | 13% |
| <li> elements must be contained in a <ul> or <ol>Structure & Semantics | Serious | 10% |
| Certain ARIA roles must be contained by particular parentsStructure & Semantics | Critical | 9% |
| Interactive element not reachable by keyboardInteractive Controls | Serious | 9% |
What this means if you run a city website
- The deadline has passed — audit now. For entities serving 50,000+, the WCAG 2.1 AA obligation is already in effect. A score in the 90s is not evidence of conformance; 34% of homepages we scanned scored well and still had a critical barrier.
- Start with your platform. If your CMS is in the higher-risk group, much of the failure surface is inherited from templates and components you did not write — and can often be fixed once, at the platform or theme level, rather than page by page.
- Test the transaction pages residents actually need. Paying a bill, pulling a permit, contacting a department — those are the pages where a barrier stops a resident from completing something they are required to do through the city.
- Automated scanning is the floor, not the ceiling. This study uses automated and scripted keyboard analysis, which catches a substantial but partial subset of WCAG. Issues needing human judgment — meaningful alt text, logical reading order, plain-language content — sit on top of these numbers. The true barrier count is higher than reported here.
Check your city or agency site against the Title II bar
Run the same WCAG 2.2 + keyboard scan we used for this benchmark — free, no signup — and see your score, your critical barriers, and exactly what to fix first.
Scan your site freeMethodology
We selected the largest US city governments by population and attempted 221 of them; our sample covers cities of roughly 100,000+ residents, the upper portion of the 50,000+ cohort covered by the April 24, 2026 ADA Title II web deadline. Each city was scanned on up to two pages — its homepage and one resident service-flow page (online payments, permits, or contact) — using the AccessLumens scanning engine (SWBS-1.3 scoring) with identical configuration for every page of every city, including scripted keyboard testing (focus traps, focus visibility, reachability, skip links). 51 cities (23%) could not be scanned because bot-protection challenges blocked a real headless browser; those are reported as a finding but excluded from the scored statistics, leaving 158 scored cities. We enforced strict robots.txt compliance — pages a site disallows were not scanned. CMS vendors were fingerprinted from page markup and response headers; vendors with fewer than eight cities are excluded from the vendor comparison. ADA Title II requires WCAG 2.1 Level AA; our engine tests WCAG 2.2 AA, a superset, so a city failing here also fails 2.1 AA. Headline failure statistics count automatically detectable WCAG violations; best-practice advisories and manual-review items are excluded. A city’s score is the mean of its scanned page scores. Individual cities are not named — the purpose of this study is to describe the state of the sector, not to single out governments. Scores use our SWBS model; this is a diagnostic snapshot, not a legal conformance determination (see our disclaimer).