King County IT says DOJ rule will require WCAG AA compliance by April 24; staff outlines archive rules, tools and next steps

Adam Teder, an applications staffer in King County’s IT department, told the Committee of the Whole that the U.S. Department of Justice issued a final rule under Title II of the Americans with Disabilities Act requiring state and local government websites and mobile applications to meet Web Content Accessibility Guidelines at the AA level and that King County plans to be prepared by April 24.

"The Department of Justice has asked us to be prepared by April 24 to have all of our public facing websites be to a double a level standard," Teder said, outlining the rule and the county’s initial steps to comply.

Why it matters: The change would affect how the county publishes agendas, minutes, PDFs, social media posts and other public content. Teder and Charles Lasker, also in IT, said automated scanning tools (SilkTide and Site Improve) will help identify problems but cannot replace human review for complex or scanned documents.

IT reported the county has more than 15,000 PDFs on the public site related to agendas and minutes and suggested using registrar platforms such as Granicus or Legistar as the primary public source for agenda packets while keeping fuller materials available on request. "We currently post the minutes and agendas onto a registrar product, but we also put it onto our existing King County website," Teder said, adding that shortening public packets could reduce accessibility burden while preserving full records for board members or for FOIA requests.

On archival treatment, IT explained that documents created before the April 24 deadline may be marked as archived and could be exempted from full AA remediation so long as they are not edited after that date; if an archived file is changed, it must meet the new standard. Lasker said agencies have the discretion to decide what to keep and what to archive but that requests to make specific archived items accessible can be handled case‑by‑case.

The presentation addressed common trouble spots: scanned vendor attachments, long RFP responses and images containing embedded text. Lasker warned that scanned attachments often require optical character recognition (OCR) and manual proofreading because automated fixes are not 100% reliable. IT said it is working with vendors, including Adobe, on batch tools to assist conversion but emphasized staff verification remains necessary.

Images and social media: IT urged more descriptive captions and alt text for images and discouraged embedding substantial text inside flat images. The department said the rule applies to public‑facing communications posted by county accounts, including social platforms that representatives use for official business. "On any social media platform ... it will have to follow these same guidelines," Teder said when asked about Facebook and other sites.

Legal risk and liability: Teder warned that noncompliance with WCAG 2.1 under Title II can be treated as an ADA violation, potentially resulting in DOJ enforcement or private suits; the presentation cited possible remedies including injunctive relief, attorney fees and fines, which the slide noted could be up to $75,000 for an initial violation and $150,000 for subsequent violations. Stephen Ford of the state’s attorney’s office said enforcement is likely to be complaint driven and that how courts will apply the rule remains uncertain. "How this would play out ... is hard to foresee given that this would primarily be complaint driven," Ford said.

Elected officials’ personal accounts and courts: Committee members asked whether an independently elected official’s personal social posts could create county liability. Counsel said the rule applies to public entities as defined by DOJ and recommended further review; the office offered to evaluate proposed procedural changes such as a members‑only portal to provide full packet materials without publishing them publicly.

Next steps: IT said it is drafting an ADA accessibility statement for placement in site footers and building a Laserfiche web form to allow members of the public to report accessibility problems; staff hopes to present the statement as a resolution to the board through the February administrative committee with possible action in March. IT also offered to show before‑and‑after examples at an upcoming meeting to illustrate how pages will change.

The committee did not take votes because there was not an in‑person quorum; members agreed to additional briefings and administrative follow‑up on the proposed resolution and technical solutions.