To the members of the:
CITY COUNCIL Date~CA v cc✓
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Council Memorandum
April 16, 2026
To:
From:
Via:
Re:
Honorable Mayor Blackburn and Members of the City Council Faviola Medina, Director of Constituent & Clerk Services Amy Ventetuolo, Communication & Engagement Director
Cindie McMahon, City Attorney
Doug Kappel, Information Technology ~a~A9.tr
Sheila Cobian, Assistant City Manager ~
New Accessibility Laws in 2026 (Districts -All)
{city of
Carlsbad
Memo ID# 202601 7
This memorandum provides information related to the U.S. Department of Justice (DOJ} regulations issued under Title II of the Americans with Disabilities Act (ADA} related to digital accessibility.
Background
In April 2024, the DOJ finalized a rule clarifying how Title II of the ADA applies to digital services provided by state and local governments. Effective April 24, 2026, these new regulations impose mandatory accessibility requirements for websites, mobile applications, and other digital content of state and local governments to ensure that their digital services are accessible to individuals with disabilities.
It is the responsibility of the city that members of our community who rely on screen readers, captions, or keyboard navigation have access to content available on the city's digital platforms.
Discussion
The DOJ rule mandates compliance with Web Content Accessibility Guidelines (WCAG) 2.1, Level AA. This standard requires that digital content be:
• Perceivable: information and user interface elements must be presented in ways users can perceive such as alternative text, or alt text, descriptions for images, captions for videos
• Operable: functions must be available from touchscreen, keyboard, or assistive technology not just reliance on mouse-only interaction
• Understandable: must have a clear, predictable structure and readable text • Robust: must be compatible with different assistive technologies, such as screen readers and magnifiers, across platforms and updates
Policy & Leadership
City Manager Department
1200 Carlsbad Village Drive I Carlsbad, CA 92008 I 442-339-5989 t
Council Memo -New Accessibility Laws in 2026 (Districts -All} April 16, 2026
WCAG 2.1 Level AA includes requirements such as:
• Text alternatives for images (alt text)
• Captioning for multimedia
• Keyboard navigability
• Sufficient color contrast
• Accessible forms and structure
These criteria are designed to ensure usability for individuals with visual, auditory, cognitive, and physical disabilities.
The rule allows limited exceptions, including:
• Archived web content maintained solely for reference
• Certain preexisting content created before the compliance date • Third-party content not controlled by the city
However, if a resident requests access to inaccessible content, the city must provide an accessible alternative in a timely manner.
To meet the April 2026 deadline and maintain ongoing compliance, staff has conducted a comprehensive audit of all city websites, applications and documents and identified non-compliant content.
City Website, Mobile Apps and Third-Party Platforms
The city is working with a third-party accessibility consultant to complete an accessibility audit of city's websites. This audit includes both automated testing tools and a detailed manual review performed by consultants trained in the use of assistive technologies. Upon completion, the city will receive a comprehensive report outlining all identified WCAG compliance issues for each site.
City staff and the city's web hosting vendors will use this report to remediate any findings.
After all corrections are made, the consultant will conduct post-remediation validation testing to verify that the identified issues have been resolved. Once compliance is confirmed, the consultant will provide the city with a formal accessibility compliance report.
In addition to the city's websites, the city also has agreements with over 50 vendors that provide on line services. These services range from the city's utility billing portal to the online research tools and databases provided through the city libraries. City staff are sending each of these vendors notices requesting the status of their accessibility compliance efforts and, if available, requesting the vendor provide a copy of their Voluntary Product Accessibility Template document that explains how their solutions conform to key accessibility standards. As agreements with these vendors come up for renewal, or new agreements are executed with new
Council Memo -New Accessibility Laws in 2026 (Districts -All) April 16, 2026
on line services vendors, city staff are ensuring these agreements contain language that requires their solution comply with the DOJ rule. As part of the fiscal year 2026-27 SDTIP Budget, staff will be requesting $100,000 to work with the city's accessibility consultant to conduct validation testing of these third-party services to confirm accessibility.
Public Meetings
For the public, the rule requires that all digital aspects of City Council meetings be accessible, including:
• Agendas, staff reports, memos and meeting minutes posted on line must be screen-reader compatible
• Any public meeting presentations must be ADA compliant as they become a part of the permanent record
• Live and recorded video must include accurate captions • Meeting portals and livestream platforms must support keyboard navigation and assistive technologies
• Public participation tools (e.g., virtual comment platforms) must be accessible The April 28, 2026, City Council Meeting will be the first meeting where these changes will first be noticeable.
Social Media
The city is required to make all digital content, including social media content, accessible to people with disabilities. Social media content must meet compliance with Web Content Accessibility Guidelines (WCAG) 2.1, Level AA. This standard requires social media content compliance, such as:
• Text alternatives for images (alt text)
• Captions or transcripts for all video content
• Sufficient color contrast and to ensure information is not conveyed through color alone • Use of plain language and CamelCase hashtags
• Use of descriptive link text
Next Steps
To comply with these new requirements, staff has updated all public meeting templates to meet accessibility requirements and will be distributed citywide by the implementation deadline of April 24, 2026. Training for all staff responsible for creation of any city documents, website content and social media content will be provided.
Council Memo -New Accessibility Laws in 2026 (Districts -All} April 16, 2026
cc: Geoff Patnoe, City Manager
Cindie McMahon, City Attorney
Jeff Murphy, Deputy City Manager, Community Services
Laura Rocha, Deputy City Manager, Administrative Services Paz Gomez, Deputy City Manager, Public Works
Christie Calderwood, Police Chief
Michael Calderwood, Fire Chief
Sherry Freisinger, City Clerk
Leadership Team
All Board and Commission Members