Precedent
How this has played out for other organizations.
These are matters on the public record: settlement agreements, consent decrees, and a regulator's order. Each shows what an organization was required to do about a website, an app, or its documents, and each carries the citation to look it up.
They were chosen because every fact shown comes from the agreement or order itself. They are terms the parties accepted, not rulings after a trial. Where the record is silent, so is the page. A court clerk, a law library, or the agency named will have each one.
Public bodies
Two public universities, a city, a transit district, a state agency, and a county. Each was required to meet a named standard by a set date.
Aleeha Dudley and United States v. Miami University
Eighteen months, and $25,000
At issue: whether people with disabilities could use the university's technology and course materials on an equal basis.
Required: existing web content Miami created and published since January 2012 brought to WCAG 2.0 Level AA within eighteen months. For outside systems used for "critical or important transactions (e.g., websites used for campus housing, campus dining, registering for classes, paying bills, obtaining transcripts)," conformance or equally effective alternate access. Payments totaling $25,000 to individuals the United States named.
United States and the City and County of Denver, Colorado
Six months, vendors included
At issue: the accessibility of the city's websites and online services.
Required: within six months, websites and all online services, "including those websites or online services provided by third parties upon which Denver relies to provide services or content," to WCAG 2.0 Level AA. An independent consultant, approved by the United States, to evaluate them.
United States and Champaign-Urbana Mass Transit District
Nine months, and $100,000
At issue: the accessibility of the district's websites, web content, and mobile applications.
Required: all of them to WCAG 2.1 Level AA within nine months. An investment of "a minimum of one hundred thousand dollars ($100,000) over the term of the Agreement to improve its services for individuals with disabilities."
United States v. The Regents of the University of California
Nine months to three years, podcasts and YouTube included
At issue: the accessibility of the University of California, Berkeley's free public online content: its website, its online courses, and its audio and video.
Required: that content to WCAG 2.0 Level AA: online-course content and new audio and video within nine months, the website within eighteen, and existing audio and video within thirty-six. Channels the university controls on outside platforms, "such as Apple Podcasts and Spotify" and "such as YouTube," are included. An independent auditor, approved by the United States, "whose team includes individuals with disabilities who are experienced users of assistive technology."
United States and Service Oklahoma
Six months
At issue: a state agency's mobile ID app. A federal letter of findings (November 2023) concluded that "because of accessibility barriers, people with vision disabilities cannot use it."
Required: any mobile app the agency "creates, administers, or maintains" to WCAG 2.1 Level AA within six months. The agency decided to withdraw the app within thirty days.
United States and Smith County, Texas
Four months
At issue: the accessibility of the county's online election content.
Required: "all existing information on the County's Election Website and Election Online Content, including audio and video content," to WCAG 2.1 Level AA within four months, with the help of a Website Auditor. Reports to the United States within four months "and every six (6) months thereafter."
Businesses
For businesses and nonprofits, no regulation sets a web standard or a date. These records show what individual businesses have been required to do anyway.
National Federation of the Blind v. Target Corporation
$6,000,000, and three years of testing
At issue: whether shoppers who are blind could use Target.com. In 2006 the court held that the ADA covered the website to the extent it connected customers to the goods and services in Target's stores.
Required: "the payment by Defendant of $6,000,000 to the California Settlement Class." A website on which "blind guests using screen-reader software may acquire the same information and engage in the same transactions as are available to sighted guests with substantially equivalent ease of use." Testing by the National Federation of the Blind, including testing by people who are blind every year, for at least three years. Legal fees and costs, awarded separately: $3,738,864.96.
National Federation of the Blind v. HRB Digital LLC
$55,000, paid to the Department
At issue: whether people who are blind could use H&R Block's website and its online tax preparation.
Required: www.hrblock.com and "the Online Tax Preparation Product" to WCAG 2.0 Level AA by January 1, 2015, and the mobile apps by January 1, 2016. An independent consultant, "approved by all parties," evaluating the work every year. "A civil penalty of $55,000," and $22,500 to each of two people who brought the claim.
United States and Hy-Vee, Inc.
Ninety days, tested by users
At issue: a supermarket chain's COVID-19 vaccine registration website. A federal compliance review found it was not accessible to some people with disabilities, "including those who use screen reader software and those who have difficulty using a mouse to navigate the website."
Required: the registration website, the paths leading to it, and any vaccine content on the site to WCAG 2.1 Level AA within ninety days. An independent consultant, approved by the United States, within five days. Testing every thirty days by at least one person who uses a screen reader and one who cannot use a mouse.
United States and Rite Aid, Kroger, Meijer, and CVS
Thirty days, four more chains
At issue: the barrier Hy-Vee's agreement addressed, at four more pharmacy and grocery chains: online COVID-19 vaccine booking that people using screen reader software could not complete. At Kroger, "appointment selection buttons erroneously told screen reader users that available appointment times were unavailable." At CVS, a keyboard user "would need to press the Tab key hundreds, or potentially thousands, of times to move past one control."
Required: the booking websites to WCAG 2.1 Level AA within thirty days (Rite Aid, Kroger, and Meijer), or from the day the agreement took effect (CVS). Regular testing by people who are blind, people with low vision, and people with disabilities who have difficulty using a mouse. Critical problems found in testing fixed within ten days at Rite Aid, Kroger, and CVS.
Vendors
These do a different job. The matters above show what organizations were required to do. These show what happened when a vendor's own account of its work was tested.
State of California ex rel. Bryan Bashin v. Conduent Incorporated, et al.
$2,050,000
At issue: a claim that ReserveCalifornia.com, the reservations website built under a state contract for California's Department of Parks and Recreation, did not meet the contract's accessibility requirements. Brought under the California False Claims Act and the Unruh Civil Rights Act.
Required: "the total aggregate lump sum of Two Million Fifty Thousand Dollars ($2,050,000.00)," including up to $50,000 to fund "a comprehensive audit of the Website by Prime Access Consulting."
In the Matter of accessiBe Inc. and accessiBe Ltd.
$1,000,000, paid to the Commission
At issue: how the company described what its product could do for a website's conformance with WCAG.
Required: no representation that the product "can make any website compliant with WCAG," or that it "can ensure continued automatic compliance with WCAG over time as website content changes," unless the claim is non-misleading and supported by competent and reliable evidence. A payment: "Respondents must pay to the Commission $1,000,000."
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