City of Chandler Vendors and Contractors of Web Content and Mobile Apps
On April 24, 2024, the DOJ published the final rule updating its regulations for Title II of the Americans with Disabilities Act (applicable to state and local governments) ensuring that all web content and mobile applications, regardless of creation date unless specifically exempted, are accessible and usable by individuals with disabilities. The DOJ Rule requires that the City of Chandler (“city”), including its vendors and contractors, must, at a minimum, meet all success criteria and conformance requirements of the Web Content Accessibility Guidelines (WCAG) Version 2.1, Level AA. This includes all websites, software, and other information and communication technology (ICT) created, provided, managed, or maintained for the city by vendors and contractors.
The Basics
- The city has requested that all vendors and contractors meet accessibility technical requirements by no later than October 24, 2025, with extensions granted for good cause or reasonable necessity. This means that all web content and mobile applications delivered to or by the city must conform to the Level AA success criteria and conformance requirements of WCAG Version 2.1 in accordance with the DOJ Rule to allow the city to be fully compliant by April 24, 2026. The terms “web content” and “mobile applications” are defined in the Rule.
- The DOJ Rule includes limited exceptions for web content and mobile application compliance with WCAG Version 2.1. The following is more fully described in the DOJ Rule available at 28 CFR Part 35:
- Archived web content;
- Preexisting conventional electronic documents unless those documents are used to apply for, gain access to, or participate in a public entity’s services, programs, or activities;
- Content posted by a third party;
- Individualized, password-protected or otherwise secured conventional electronic documents; and
- Preexisting social media posts
- Every City of Chandler vendor and contractor subject to this notice must conduct testing and provide an Accessibility Conformance Report (ACR) to the city by completing a Voluntary Product Accessibility Template (VPAT).
- Vendors and contractors may select a software, application or industry expert to produce this report. Testing should be done using both automated tools and manual testing methods, ensuring compliance is achievable for all user groups, including those with assistive technologies.
- Please submit your ACR via email to the ADA Coordinator by April 25, 2025.
- Non-compliance may result in corrective action, which could include renegotiation of contracts or removal of services if vendors are unable to meet the required accessibility standards.
Resources
- W3C Accessibility Standards Overview
- Evaluating Web Accessibility Overview
- How to meet WCAG (quick reference)
- ADA Rule from the Department of Justice
- State and Local Governments: First Steps for Compliance
- Free VPAT template from the Information Technology Industry Council (see form “VPAT 2.5 WCAG” dated November 1, 2023)
Vendor Responsibilities
All third-party vendors engaged by the City of Chandler must ensure that all web content, applications, and digital assets they produce or maintain meet or exceed the following accessibility standards.
Vendors must ensure that all web pages, content, and applications conform to WCAG 2.1 Level AA standards.
The guidelines should be applied to all forms of digital content including but not limited to websites, mobile apps, documents (PDFs, Word, Excel), and multimedia elements (videos, images, audio).
Vendors are required to perform accessibility audits of their products and services to ensure compliance with WCAG 2.1 guidelines at Level AA before any deliverables are presented to the City of Chandler.
- Testing should be done using both automated tools and manual testing methods, ensuring compliance is achievable for all user groups, including those with assistive technologies.
- Vendors must provide a detailed accessibility report that outlines compliance with specific WCAG criteria.
Vendors must provide an Accessibility Conformance Report (ACR) for all deliverables, confirming adherence to WCAG 2.1 Level AA standards by completing a Voluntary Product Accessibility Template (VPAT). The Information Technology Industry Council offers a free VPAT template (see form “VPAT 2.5 WCAG” dated November 1, 2023). The report should include:
- A listing of all pages or assets evaluated.
- Details of WCAG criteria met or failed.
- Any potential known issues or exceptions and proposed solutions or mitigation strategies.
In the event of identified accessibility issues, vendors are asked to promptly resolve them and provide updates to the City of Chandler on the remediation efforts and timelines.
Vendors must make necessary adjustments to comply with WCAG 2.1 Level AA standards, ensuring that all elements are fully accessible and functional for individuals with disabilities.
Vendors must provide ongoing support for accessibility compliance, ensuring that any future updates, modifications, or new content also meet WCAG 2.1 standards at Levels AA.
Vendors are expected to regularly review their digital products to ensure continuous compliance, including monitoring changes to web content, functionality, and design.
Vendors must provide their teams with training and resources necessary to understand and implement WCAG 2.1 guidelines, including training on accessibility testing and accessible design principles.
Vendors must maintain clear documentation outlining the steps taken to achieve accessibility compliance and be able to provide this documentation upon request to the City of Chandler or any relevant stakeholders.
Regular communication must be maintained to ensure any changes in accessibility requirements, technology, or tools are addressed promptly.
In some cases, certain content or functionality may not be fully compliant due to technological limitations, legacy systems, or specific business requirements. In such cases, vendors must provide a justification for non-compliance and outline a plan for remediation.
Exceptions must be documented and reviewed by the City of Chandler’s Accessibility Team to ensure that the overall accessibility goals are not compromised.
The City of Chandler reserves the right to conduct periodic accessibility audits and reviews of all third-party digital assets.
Non-compliance may result in corrective action, which could include renegotiation of contracts or removal of services if vendors are unable to meet the required accessibility standards.
Conclusion
By ensuring compliance with WCAG 2.1 Level AA, the City of Chandler is dedicated to providing a digital environment that is accessible, inclusive, and usable by all members of the community. Vendors are expected to align their practices with these accessibility guidelines to support the City’s commitment to equal access for all individuals.
For further inquiries or assistance regarding accessibility standards, please contact the City of Chandler’s Accessibility Coordinator.
This information serves as a guideline for third-party vendors working with the City of Chandler to ensure that all digital content complies with the WCAG 2.1 standards, fostering an accessible online experience for all users.