● The short answer
According to the US Department of Justice, yes: the ADA's requirements apply to the goods and services public accommodations offer, including on the web. But there is no detailed DOJ regulation setting a technical standard for private business websites, so businesses have flexibility in how they comply. In practice, WCAG 2.1 or 2.2 Level AA is the benchmark most courts and settlements use.
Key takeaways
- The DOJ says the ADA applies to goods and services businesses offer on the web.
- There is no detailed DOJ technical regulation for private business websites.
- WCAG AA is the practical benchmark used in courts and settlements.
What the DOJ says
Title III of the ADA covers "public accommodations": businesses open to the public, such as retailers, restaurants, hotels, banks, medical offices, gyms, museums and many service providers. The DOJ's web guidance on ADA.gov says the department has "consistently taken the position that the ADA's requirements apply to all the goods, services, privileges, or activities offered by public accommodations, including those offered on the web."
The same guidance also says the DOJ "does not have a regulation setting out detailed standards," and that businesses have flexibility in how they comply. It points to existing technical standards, WCAG and the federal Section 508 standards, as helpful guidance.
Two clarifications as of late 2026:
- In 2025 the DOJ withdrew a set of older ADA Title III guidance documents. The 2022 web accessibility guidance was not among them, and withdrawing guidance does not change the statute.
- The DOJ's 2024 rule with a specific WCAG 2.1 AA requirement applies to state and local governments under Title II, not to private businesses. See the Title II web rule.
The how is where we come in.
What we walk through with you, for your business:
- Why this is still a real risk
- A sensible compliance path for a business
- Our take
Every business is different, so the plan is too. Tell us where you want to show up and we will show you what it takes.
Talk to usMore questions
Does the ADA apply to online-only businesses?
Courts have disagreed on whether businesses with no physical location are covered by Title III, and the law varies by federal circuit. The DOJ's position is that the ADA applies to goods and services offered on the web. Given the uncertainty, online-only businesses should still aim for WCAG AA and consult counsel about their specific risk.
What should I do if I get an ADA website demand letter?
Do not ignore it, and do not respond without legal advice. Contact an attorney experienced in ADA web claims, preserve a record of your site as it was, and get an independent audit. Starting real remediation promptly helps both the people affected and your position.
Sources
- ADA.gov: Guidance on Web Accessibility and the ADA
- ADA.gov: Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments
- Lexblog: DOJ Withdraws 11 Pieces of Americans with Disabilities Act Title III Guidance
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