WCAG 2.1 AA Legal Baseline Audit for templates

Six lines in this county permits template fail WCAG 2.1 AA - US county and city web teams, due 26 April 2027.

  1: 3.1.1 Language of Page (A) - <html> has no lang attribute, so the screen reader guesses the voice.
  2: 1.4.4 Resize Text (AA) - user-scalable=no blocks pinch zoom. This is an AA failure, not a preference.
  4: 1.1.1 Non-text Content (A) - <img> has no alt. Use alt="" only when the image is decorative.
  5: 1.3.5 Identify Input Purpose (AA) - no autocomplete token. This criterion is NEW in WCAG 2.1, so WCAG 2.0-era checkers never report it.
  6: 2.1.1 Keyboard (A) - a click handler on a <div>/<span> cannot be reached by Tab.
  7: 4.1.2 Name, Role, Value (A) - <iframe> has no title. The frame list announces it as "frame".
—— 6 ——

The whole file it read - nine lines, unedited:

<html>
<head><meta name="viewport" content="user-scalable=no"></head>
<body>
  <img src="/img/county-seal.png">
  <input type="email" id="em" name="email">
  <div onclick="payBill()">Pay a bill</div>
  <iframe src="https://maps.example/embed"></iframe>
</body>
</html>

No page was rendered; every finding came out of the source.

The version nobody checks

Ask an assistant which standard applies and it answers WCAG 2.2, because that is the current W3C recommendation. That is the wrong answer for a legal baseline. 28 CFR 35.200(b) names WCAG 2.1 Level AA, and in the EU the presumed-conformance standard behind the European Accessibility Act, EN 301 549 V3.2.1, names WCAG 2.1 Level AA as well. Version 4.1.1 of EN 301 549 will move to WCAG 2.2, but it is not the harmonised standard yet.

A team following the assistant chases 2.2-only criteria that carry no obligation and walks straight past line 5 above: 1.3.5 Identify Input Purpose, an AA criterion that is new in WCAG 2.1, which every 2.0-era checker in the toolchain silently ignores.

The dates moved, and the moved dates are the ones that bind

On 20 April 2026 the Department of Justice issued an interim final rule extending the Title II compliance dates by one year. Public entities serving 50,000 or more people now have until 26 April 2027. Entities under 50,000, and all special district governments, have until 26 April 2028. The technical standard did not move: it is still WCAG 2.1 Level AA. Articles written before April 2026, and the models trained on them, still give the old dates.

Why the checker on your laptop cannot see this

Browser extensions and page scanners test a rendered page. A county site is hundreds of Twig, Blade, ERB and Razor templates, most of which never render outside a request with real data. The 6 failures above live in the markup, one line each, and they are readable there long before anyone can load the page.

So the audit belongs in the editor. This one reads markup as source: 24 checks covering 13 success criteria, each finding labelled with its WCAG 2.1 criterion number and level, on HTML, JSX, Vue, Twig, Blade, ERB and Razor alike.

Mechanical means mechanical. A positive tabindex becomes tabindex="0". A zoom lock becomes a cap that reaches 200%. Anything needing human judgement - what the alt text on line 4 should say, what the frame on line 7 is for - is listed and left alone, because a tool that invents alt text produces a page that passes a checker and still fails a person.

Free, and what a licence adds

Auditing the file you have open is free and complete: every one of the 24 checks, real line numbers, criterion numbers, nothing withheld. A licence adds scale rather than answers - every template in the repository in one pass, the findings exported as CSV, JSON or HTML for procurement and counsel, mechanical fixes applied in place, and a re-audit on every save. That is $29 once. An audit firm bills $100-$250 a page for the same reading.

Run it against one template you already shipped. If it finds nothing, you have your answer for free.