Between October 18 and 23, I reviewed the homepages of the main government websites for 35 Title II localities in Virginia with over 50,000 residents. Every website homepage had at least two significant accessibility failures. Across the whole group, there was an average of 5 failures per site.

The timing of this review is significant because it is 6 months after these sites were required to comply with the Virginia Information Technology Access Act (VITAA) and 6 months before the recently extended deadline to comply with federal regulations for digital accessibility. The findings show that most localities are not prepared to comply with either. This review is a follow-up to the same review I did in April 2026.

10 Key Accessibility Barriers Found

All of these barriers represent non-conformance with the Website Content Accessibility Guidelines (WCAG) version 2.0. Each failure can be found with automated testing tools or a minimal amount of manual testing. Only 10 accessibility barriers were checked for. It’s possible that additional barriers might be found with more extensive testing.

Landmarks

91% are missing HTML landmarks, are using landmarks incorrectly, or have landmarks that are not labeled properly. HTML landmarks identify key portions of the page (i.e., banner, main, navigation). Over 30% of screen reader users use landmarks as a way to quickly move throughout the page

Headings

80%have incorrect HTML heading order or incorrect HTML heading usage. This is significant because the recent Screen Reader Survey by WebAIM shows that 76% of respondents prefer to use headings as their way of navigating a page.

Links

86% have links with ambiguous or unclear purpose. These could be links that have text like “Learn More” or they could be linked images that do not have a clear text alternative. Ambiguous and unclear links make it harder for screen reader users and voice command users to interact with the content.

Image Alt Text

74% have missing image alt text, bad alt text, or alt text that is used incorrectly based on the purpose of the image. Alt text provides additional information to screen reader users about the contents of an image.

Not Keyboard Operable

57% have instances where a keyboard-only user would encounter significant challenges trying to use the main navigation or search form. This is a concerning increase since the last review.

Color Contrast

29% have low color contrast issues. This shows a significant improvement since the April 2026 review. Most instances of low color contrast were on minor elements that would not significantly hinder a person’s ability to interact with the site or perform important functions.

PDFs

40% have PDFs that are not properly tagged for accessibility.

Missing Transcripts

14% have videos on the homepage. All of those are missing transcripts.

Bypass Link

14% are missing a Skip to Content link. This can create a significant challenge for keyboard-only users who would need to navigate through every link in the page header (often containing elaborate mega-menus) before they can reach the main content.

Forms

11% have forms that are missing labels or correctly marked required fields.

Additional Findings

CivicPlus continues to power 60% of these sites. The remaining sites are powered by Drupal (11%), Granicus (17%), WordPress (6%), and other platforms (6%)
51% of sites have accessibility overlays. This is a 9% decrease since the last review. All of the sites with overlays contain accessibility issues detailed in the Key Findings. Overlays cannot fix complex accessibility issues and will not put these sites in compliance with state and federal requirements.
Over 70% of the sites reference conformance with a specific version of WCAG in their accessibility statement. However, not one homepage in this review fully conforms with WCAG. By April 26, 2027, all of these sites are required to conform with WCAG 2.1 AA across all of their digital content.
Only 20% of the sites have a specifically named digital accessibility coordinator in accordance with VITAA. Many of the accessibility statements contain a “contact us” link that directs users to a staff directory. Users must determine for themselves who is the best person to contact to report an accessibility barrier and request support.

Recommendations for Title II Entities for the Next 6 Months

Given the extent of the issues that still exist on these sites, it is unlikely that they will be able to meet the deadline to fully conform with WCAG 2.1AA by April 26, 2027. Localities need to focus their efforts on where they can have the most impact.

Fix issues that exist with global page templates (i.e., missing Skip to Content links, landmark issues), the global header and footer, and other component templates that are used multiple times across the site.
To comply with VITAA, name a digital accessibility coordinator and include their contact information in the accessibility statement. This way, when users encounter barriers, they can easily contact the right person for assistance. Make sure the accessibility statement is easy to find.
Start collecting Accessibility Conformance Reports (ACRs) from vendors that you use for information technology products and software-as-a-service (SAAS) tools. These reports should be created using the Voluntary Product Accessibility Template(VPAT) for WCAG 2.1 AA. Collecting these reports is required to comply with VITAA.
For any staff who create documents or content for the website and social media, make sure they are trained on accessibility best practices and what is required to comply with accessibility regulations going forward.
Achieving and maintaining digital accessibility will require continual effort. Make a detailed plan to address accessibility barriers that won’t be resolved before the April 2027 deadline. Have a plan for how new content will be reviewed and how all digital platforms will be reviewed periodically to maintain accessibility. Name the person who is accountable for making sure these plans are implemented and require regular status updates.

Testing Methodology

I used a combination of automated and manual testing methods on each homepage.

I used the ARCToolkit Chrome extension to look for missing image alt text, insufficient color contrast, and form label issues.
I tested with a keyboard alone to check for a bypass link, focus indicators, and keyboard-operable navigation menus.
I conducted a manual visual inspection to look for ambiguous links, check the quality of image alt text and to see if videos, if present, had captions and transcript.
I used the HeadingsMap Chrome extension to check for incorrect heading order and incorrect or missing landmarks.
I manually reviewed one PDF from each site for accessibility. PDFs related to current programs or services so they are not subject to exceptions for archive content.

Limitations

The following were not tested:

Other than specified PDFs, only the homepage was tested.
Sites other than the primary government site were not tested. However, sites for police and fire departments, schools, parks and recreation, tourism, economic development, special events, boards and commissions are all required to meet the new guidelines.

Final Thoughts

The localities included in this review are past due to comply with VITAA and were recently granted additional time to meet federal regulations. However, likely due to limited budget, staff time constraints and competing priorities, the additional time does not seem like it will be enough. This review only included localities with more than 50,000 residents. Smaller localities have 6 more months to comply with VITAA and 18 more months to comply with federal regulations. It remains to be seen if they will be able to meet those deadlines.

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AI Disclosure: The feature image was generated by AI. The text was written and approved by the author. AI was used for proofreading to identify grammatical errors.