A licensee with a visual impairment tries to renew her credentials online. The form fields lack labels. Her screen reader cannot interpret the page. She calls your office for help, joins a queue and waits.
This scenario plays out across state regulatory agencies every day and it sits at the center of NASCIO’s sixth priority for state CIOs in 2026: accessibility. For regulatory agencies, digital accessibility compliance means more than a compliant website. NASCIO’s definition covers every service, communication and tool your agency puts in front of the public, with procurement decisions and DOJ compliance built in from the start. If a constituent interacts with your office digitally, accessibility standards apply.
This article continues a 10-part series examining NASCIO’s top priorities for state regulatory agencies in 2026. Each installment explores how pairing advanced technology platforms with disciplined operational practices helps agencies meet elevated expectations, stretch limited resources and deliver better outcomes for the public they serve.
The DOJ Rule: Where Things Stand
In April 2024, the Department of Justice finalized a rule under Title II of the Americans with Disabilities Act requiring state and local governments to make their websites and mobile applications compliant with Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. While federal agencies have long operated under Section 508, this DOJ rule gave state and local government agencies a parallel mandate and a clear technical benchmark:
- Online content navigable by keyboard
- Compatible with screen readers
- Functional on mobile devices regardless of orientation
- Accessible to users with cognitive and visual disabilities
State and local governments serving populations above 50,000 faced an original compliance deadline of April 24, 2026. Then, just four days before that deadline, the DOJ issued an interim final rule pushing the deadline to April 26, 2027 for larger entities and April 26, 2028 for smaller ones. The administration cited overestimated compliance capacity as the rationale. The delay arrived without the required notice-and-comment period, drawing an immediate legal challenge.
On May 21, 2026, the National Federation of the Blind filed a federal lawsuit against the DOJ and the Department of Health and Human Services, arguing that the last-minute extensions violated the Administrative Procedure Act and failed to adequately weigh the harm to people with disabilities. The complaint describes real members who cannot complete unemployment applications, register businesses, access telehealth services or pay medical bills because government websites remain inaccessible. The lawsuit asks the court to restore the original deadlines.
The legal uncertainty cuts both ways for regulatory agencies. The extended deadline reduces near-term enforcement exposure, but it does not eliminate liability. User complaints, civil rights investigations and reputational damage do not pause for a court calendar. Agencies that continue working toward compliance now stand on stronger ground regardless of how the litigation resolves.
What WCAG 2.1 Actually Requires of Your Agency
WCAG 2.1 Level AA is not an abstract standard. It produces specific, testable requirements that your web team, software vendors and procurement staff evaluate. For a regulatory agency, the most operationally significant requirements break down into four categories.
- Mobile accessibility: Your licensing portal, inspection reports and renewal forms must function correctly on any device, regardless of screen orientation. A licensee using a mobile device needs the same experience as someone using a desktop.
- Keyboard navigation: Every function your website performs must work without a mouse. Users with motor disabilities or other limitations navigate by using a keyboard.
- Vision accessibility: PDFs, images and documents require alternative text. Font sizes must meet minimum thresholds. Color contrast ratios must meet standards that make content readable for users with low vision.
- Cognitive accessibility: Forms and instructional content must support users who rely on text-to-speech software. Error messages must clearly explain what went wrong and how to fix it.
Franklin County, Ohio’s Clerk of Courts built accessibility into its style guides to address exactly these categories systematically. Rather than auditing for compliance after the fact, the team embedded standards into the design process from the start. That approach holds a useful lesson for regulatory agencies: accessibility catches made late cost significantly more than standards applied early.
Accessibility Belongs in Procurement, Not Just Design
NASCIO’s definition of accessibility includes the procurement process, which matters for regulatory agencies that rely on third-party regulatory agency software for licensing, case management and public-facing portals. When your agency acquires a new regulatory platform, every accessibility gap in that platform becomes your agency’s compliance problem.
Building accessibility requirements into your procurement checklist shifts the burden appropriately and protects your agency downstream. When evaluating vendors, your team should ask:
- Does the platform meet WCAG 2.1 Level AA today, and does the vendor maintain a Voluntary Product Accessibility Template (VPAT)?
- How does the vendor track and respond to accessibility issues identified after deployment?
- Does the platform support keyboard navigation, screen reader compatibility and mobile responsiveness across all constituent-facing features?
- Will the vendor update the platform proactively when accessibility standards evolve, before your agency needs to request changes?
GL Solutions CEO Bill Moseley describes the vendor posture your agency should expect:
“GL Solutions takes a compliance-first approach when it comes to cybersecurity and website accessibility. We watch for changing requirements and embed them into the core of our SaaS offering before agencies even know a change is required.”
That standard, proactive compliance built into the product rather than retrofitted after the fact, belongs at the center of your software vendor evaluation criteria.
GenAI as an Accessibility Tool: Opportunity and Caution
NASCIO’s 2024 report, Revolutionizing Assistance: How States Can Improve Generative AI’s Role in Disability Empowerment, identifies real opportunities for AI to extend accessibility beyond what static WCAG compliance delivers.
Practical applications for regulatory agencies to deploy now include:
- Text-to-speech conversion
- Real-time transcription
- Plain-language summaries
- AI-powered chatbots
That last tool does double duty. An AI chatbot that reads form fields aloud and answers questions in plain language extends accessibility far beyond a static, WCAG-compliant page, and it serves all users more effectively, including staff, making it an efficiency investment that also advances compliance.
NASCIO also identifies risks your agency needs to manage:
- AI tools trained on non-representative datasets sometimes produce outputs that fail users with disabilities.
- Without inclusive training data, even well-designed tools exclude the people they strive to serve.
- Vendors vary widely in how transparently they document model development and limitations.
The report urges licensing and permitting agencies to test AI tools with stakeholders with disabilities before deployment and treat AI as a first-draft tool that requires human oversight. The decision framework for deploying AI in a government context applies here directly: does this tool make a specific task better for a specific user group, and does your agency have the governance structure to monitor and correct it?
What Your Agency Should Do Now
The delayed enforcement deadline gives state regulatory agencies more time to reach compliance, but it does not eliminate the work or the risk. Agencies that treat the extension as permission to pause leave themselves exposed when the next deadline arrives, when a user complaint surfaces, or when the court rules in the NFB’s favor and original deadlines snap back into effect.
The practical path forward looks like this:
- Conduct an accessibility audit of your public-facing digital properties. Identify which pages, forms and documents fail WCAG 2.1 Level AA criteria. Free tools like WAVE and the axe browser extension give your web team a starting point. Prioritize your highest-traffic constituent-facing digital services: license applications, renewals, status checks and complaint submissions.
- Add accessibility criteria to your vendor evaluation process. Request VPATs from current and prospective software vendors. Make WCAG 2.1 Level AA compliance a contractual requirement, not a preference. Ask vendors how they handle accessibility updates when standards evolve.
- Build accessibility into your style guide and content workflow. Every document, PDF, form and webpage your agency publishes needs to meet accessibility standards at creation, not remediation. Train staff who produce digital content on alt text, heading structure, color contrast and plain-language writing.
- Evaluate GenAI tools with disability-community stakeholders before deployment. If your agency plans to deploy AI chatbots, automated document processing or any AI-assisted constituent service, test those tools with users with disabilities. Identify failure modes before they affect real constituents.
- Document your progress. Regulators who demonstrate good-faith, documented remediation efforts stand on stronger ground in the event of a user complaint or compliance review. Your accessibility roadmap, audit results and vendor correspondence all contribute to that record.
Accessibility and Modernization Point in the Same Direction
Regulatory agencies sometimes frame accessibility as a compliance burden separate from modernization. But an online licensing portal that works for users with disabilities also works better for everyone. Mobile-responsive forms serve a licensee using a phone on a job site the same way they serve a user with a visual impairment. Clear error messages help a first-time applicant the same way they help someone using assistive technology. Plain-language content reduces call volume across your constituent base.
Accessibility improvements compound. Each remediation your agency makes produces a more usable digital service for everyone, reduces staff time spent fielding avoidable phone and email inquiries and moves your regulatory agency closer to the compliance standard the law requires.
Build Accessibility into Your Regulatory Platform with GL Solutions
GL Solutions takes a compliance-first approach to accessibility, embedding WCAG standards into GL Suite before agencies need to ask. Our platform gives state regulatory agencies accessible, mobile-responsive licensing and permitting tools that serve every constituent. Our team monitors evolving requirements so your agency stays ahead of the compliance curve. Contact us to learn more about modernizing your regulatory operations with accessibility built in from the start.
Renee Moseley joined GL Solutions in 2016 with an educational and professional background in research and writing, along with software documentation. At GL Solutions she produces informative content to help regulatory agencies stay current on news and information that supports their success.
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