Website accessibility checklist for small businesses (ADA and WCAG 2.1 AA)

It's the accessibility part of the review we run in every free audit, written so you can do it yourself in an afternoon without touching code. Each check says how to test it with free tools. What you tick is saved in this browser.

What the ADA risk really is for a private business

Title III of the ADA requires businesses open to the public (stores, restaurants, clinics, contractors, offices) to offer people with disabilities “full and equal enjoyment” of what they sell. In its 2022 guidance, the Justice Department says those requirements apply to what you offer online too. It also says there is no regulation with detailed technical standards for businesses: you have flexibility in how you comply, and it points to WCAG as helpful guidance.

In practice, the risk looks like this:

• A demand letter: a law firm writes on behalf of a user, lists barriers on your site and proposes a settlement. Many claims start this way, before any lawsuit is filed.
• A federal lawsuit: under Title III, a private plaintiff can get a court order to fix the site and attorney's fees, but not money damages.
• State law: some states add damages. In California, the Unruh Civil Rights Act treats an ADA violation as a violation of state law, and that one does allow money damages.
• Lost customers: the most certain cost. A form a screen reader can't fill out or a menu that doesn't open without a mouse means someone who wanted to buy goes elsewhere.

The 2024 rule: for governments, not for your business

In April 2024 the Justice Department published a rule under Title II of the ADA that, for the first time, sets a technical standard: WCAG 2.1 Level AA for the websites and mobile apps of state and local governments. In April 2026 it pushed the compliance dates back one year. It doesn't apply to private businesses in general, with one exception worth knowing: if you provide web content or an app to the public on behalf of a city or county (a parking payment app, say), the government has to make sure it complies.

Selling to Europe: the European Accessibility Act

Only relevant if you sell online to consumers in the European Union. Since June 28, 2025, the EU directive on accessibility requirements covers, among other things, e-commerce services: buying products or services from a website or app. Microenterprises providing services (fewer than 10 people and no more than EUR 2 million in annual turnover or balance sheet) are exempt. Each country enforces it through its own law, so if Europe is a real market for you, check the rules of the countries you sell to.

Why an overlay widget doesn't fix it

Overlays are the little accessibility icon that some vendors promise will make your site compliant with one line of code. They don't change your HTML: images without a description, unlabeled forms and menus that can't be used with a keyboard are still there underneath. In 2025 the Federal Trade Commission ordered one of the best known vendors to pay $1 million for claiming, without evidence, that its AI tool could make any website WCAG compliant. And the W3C itself warns that automated tools can't determine whether a site is accessible: they can only help a person check it.

The free tools you need

• WAVE (wave.webaim.org): paste your URL and it marks errors on the page itself. Errors and contrast warnings first.
• Lighthouse, built into Chrome: right-click, Inspect, Lighthouse tab, Accessibility. A score under 90 means there's obvious work to do; 100 doesn't mean the site is accessible.
• WebAIM's contrast checker: enter the text color and the background color and it tells you whether they pass.
• Your keyboard: the Tab key moves forward, Shift+Tab goes back, Enter activates. It's the most revealing test of all.
• Your phone: to check zoom and that nothing is cut off on a small screen.

Test the home page, a service page, the contact form and, if you sell online, the checkout. Those are the pages where a barrier costs you a customer.

1. Images and color

2. Headings, links and buttons

3. Forms and error messages

4. Keyboard and focus

Put the mouse aside and go through the page with Tab only. Many people with motor disabilities or who use a screen reader browse this way.

5. Video, PDFs and mobile

What to do with what you find

1. Start with what blocks a purchase or a contact: the form, the phone button, the menu and the checkout. A slightly low contrast on the blog can wait a week.
2. Fix it in the template, not page by page: menu, footer and form usually live in one place, and one fix covers the whole site.
3. Publish an accessibility statement: what standard you aim for (WCAG 2.1 AA) and a phone and email to contact you if something doesn't work.
4. Repeat the review when you redesign, add a booking tool or a new form, and once a quarter as part of maintenance.

David Abellán

Co-founder · Engineering

Co-founder of Intervolutions. Architecture, code and infrastructure since 2010, with projects delivered in seven countries.