· Compliance · 3 min read
ADA Title II: Audio Description Compliance Checklist
The ADA Title II digital accessibility deadline hits April 2026. Here is a practical compliance checklist for public entities that need to add audio description to their video content.
On April 24, 2026, new ADA Title II regulations take effect, requiring state and local government entities to make their web content and mobile applications conform to WCAG 2.1 Level AA. This includes a requirement that has caught many organizations off guard: audio description for pre-recorded video content.
What Changed?
In April 2024, the Department of Justice published a final rule under Title II of the Americans with Disabilities Act requiring digital accessibility for state and local government entities. The rule establishes WCAG 2.1 Level AA as the technical standard.
WCAG 2.1 Success Criterion 1.2.5 requires audio description for all pre-recorded video content. This means every informational, educational, or promotional video published by a covered entity must include AD.
Who Is Covered?
Entities with 50,000+ population: Must comply by April 24, 2026.
Entities with populations under 50,000: Must comply by April 26, 2027.
This includes:
- State government agencies
- County and city governments
- Public universities and community colleges
- Public school districts
- Public libraries and museums
- Public transit agencies
- Public hospitals and health departments
Your Audio Description Compliance Checklist
Phase 1: Assessment (Now)
- Inventory all video content on your websites, apps, and social media
- Identify which videos lack audio description
- Categorize by priority: high-traffic content, legally required content, public-facing content
- Estimate total minutes of video requiring AD
- Review your budget for accessibility improvements
Phase 2: Planning (Immediately)
- Select an AD solution: Evaluate manual vs. AI-powered approaches based on your volume
- Set a production timeline: Work backward from your April 2026 deadline
- Assign responsibility: Designate an accessibility coordinator
- Establish quality standards: Define what “good” audio description means for your content
- Plan for ongoing compliance: New content needs AD at time of publication
Phase 3: Production (ASAP)
- Begin AD production for highest-priority content
- Implement a workflow for adding AD to new content before publication
- Test with assistive technologies: Verify AD plays correctly with screen readers and media players
- Train content creators: Ensure staff understand AD requirements for new videos
Phase 4: Verification (Before April 2026)
- Conduct an accessibility audit of all video content
- Document compliance: Maintain records of AD coverage and quality
- Publish an accessibility statement on your website
- Establish a feedback mechanism: Allow users to report accessibility issues
Understanding WCAG 2.1 Audio Description Requirements
Success Criterion 1.2.5 (Audio Description — Pre-recorded): Audio description is provided for all pre-recorded video content in synchronized media.
Key points:
- AD must describe important visual information not available from the audio track alone
- AD is inserted during natural pauses in the dialogue
- If pauses are insufficient, extended audio description (which pauses the video) may be needed
- Live video content has different requirements (SC 1.2.7)
The Scale Challenge
Many public entities have hundreds or thousands of videos across their digital properties. At traditional AD rates of $15–50 per finished minute with weeks of turnaround, achieving full compliance before the deadline is mathematically challenging.
Example: A state university with 2,000 videos averaging 10 minutes each = 20,000 minutes of content. At $25/minute for manual AD, that is $500,000 and months of production time.
AI-powered audio description changes this equation:
- Process thousands of minutes per day
- Reduce costs by 80–90%
- Generate AD in multiple languages for diverse communities
- Maintain consistent quality at scale
Penalties for Non-Compliance
Under ADA Title II:
- First violation: Up to $75,000 in civil penalties
- Subsequent violations: Up to $150,000 per violation
- Lawsuits: Private right of action allows individuals to sue
- Complaints: Filed with the Department of Justice, which can investigate and pursue enforcement
Web accessibility lawsuits exceeded 5,100 in 2025 — a 20% increase year over year. Video accessibility is increasingly a target.
Start Now
The April 2026 deadline is approaching fast. Organizations that start now have time to implement a systematic approach. Those that wait will face rushed timelines, higher costs, and greater compliance risk.