Everyone agrees it matters. Nobody agrees on step one.
Title II conversations stall in the same place. IT wants an audit. Marketing wants the redesign to fix it. Legal wants a date. A dean wants to know if their department site is in scope. Meanwhile, nothing ships.
The fastest way out is to answer a few factual questions first. The answers point to one of four starting moves, and they make the first conversation with any vendor shorter and more useful.
The six questions
1. Are you a public entity under Title II?
State and local governments and their instrumentalities are covered, including public colleges and universities. Private institutions fall under other laws. If you are not sure, ask counsel before anything else.
2. Is your entity’s total population 50,000 or more?
On April 20, 2026, the Department of Justice extended the Title II web and mobile app compliance dates. State and local government entities with a total population of 50,000 or more now have until April 26, 2027. Entities under 50,000, and every special district government, now have until April 26, 2028. The technical standard did not change: WCAG 2.1 Level AA. Source: the DOJ interim final rule extending the Title II compliance dates (91 FR 20902).
3. How many sites do you actually run?
Not how many you built. How many exist on your domains. If the honest answer is “we are not sure,” that is your answer to where to start.
4. Who owns them?
Central web team, departments, vendors, student groups, or nobody. Ownership decides who fixes what.
5. When was your last real audit?
A manual review against WCAG 2.1 AA, not an automated score. If it was before your last redesign, it no longer describes your site.
6. Do you publish an accessibility statement with a working feedback channel?
It is a small thing that shows intent and gives people a way to report barriers.
What the answers point to
Start with inventory
If you cannot answer question 3 or 4, start there. Remediation plans built on a partial list miss the sites that carry the most risk. For large, spread-out estates, KWALL implements Accorbis to map every site on the domain; see how KWALL implements Accorbis.
Start with an audit
If you know your sites but your last manual review is old or never happened, an audit and prioritized remediation plan comes first.
Start with a remediation sprint
If you have a recent audit and a known list of template issues, go straight to fixing components on your highest-traffic journeys.
Start an ongoing program
If the big fixes are done, the risk now is drift: new content, new sites, new vendors. That is what the KWALL Accessibility & Compliance program is for.
A note on honesty
None of these starting points is a guarantee of compliance, and no vendor should promise one. What they give you is a defensible plan with dates, owners, and evidence of progress.
Two hypothetical answers, two different starts
A mid-sized city
Imagine a city above 50,000 residents. It knows its main site well and had a manual audit last year, but parks, library, and police each run separate sites, and nobody can say who owns two of them. Its answers point to inventory and ownership first, then an audit of the department sites, with the main site moving straight into a remediation sprint.
A small special district
Now imagine a water district with one site, built by a vendor, and no audit on record. It is on the April 26, 2028 date. Its answers point to an audit first, a short remediation plan, and an accessibility statement with a working contact. It does not need an inventory platform.
Same six questions, very different first steps. That is the point of asking them.
Turn the answers into a one-page brief
Write the answers down before you talk to anyone. A one-page brief should include:
- Your entity type and which date counsel says applies.
- Your best site count, and how confident you are in it.
- Known owners and known gaps.
- The date and scope of your last manual audit.
- Whether you publish an accessibility statement, and where.
- Your budget timing: when the next cycle is decided.
This brief makes internal approvals faster and lets any vendor give you a useful answer in the first conversation.
Frequently asked questions
Can we do inventory and audit at the same time?
Yes, if you audit the sites you already know are high-traffic while discovery finds the rest.
Does a private university need to worry about Title II?
Title II applies to public entities. Private institutions face accessibility obligations under other laws, including Title III and Section 504 where federal funds are involved. Ask counsel.
Which comes first, the redesign or remediation?
Remediation on the sites you run today. A redesign can be built accessible, but it should not hold up fixes to live pages.
Is this a self-assessment we can do internally?
Yes. These questions need no vendor. Bring the answers to any partner you talk to.
What if we cannot answer most of the questions?
That is a useful answer. It means inventory and ownership come first, before any spending on fixes.
How often should we revisit these questions?
Every quarter until your compliance date, and at least yearly after it. Estates change, and so do the answers.
Next step
Have your six answers? Tell us what you are working on, and include them in the message.
