ADA & Accessibility — What the Law Requires

The Americans with Disabilities Act (ADA) is the landmark civil rights law that prohibits discrimination against people with disabilities across virtually every area of public life. For blind and visually impaired Missourians, the ADA is one of the most powerful tools available — covering employment, public services, businesses, telecommunications, and increasingly, digital spaces.

This guide explains what each ADA title requires, how web accessibility law is evolving, how to navigate the reasonable accommodation process, and where to file a complaint in Missouri.

Last reviewed: March 2026 — includes DOJ April 2024 Web Accessibility Final Rule  |  Know Your Rights overview →

What Is the ADA?

Signed into law on July 26, 1990, the Americans with Disabilities Act is a comprehensive civil rights statute that prohibits discrimination against people with disabilities. The ADA defines disability broadly: a person with a physical or mental impairment that substantially limits one or more major life activities is protected — and visual impairment, including legal blindness and low vision, clearly qualifies.

The ADA was amended in 2008 (the ADA Amendments Act) to expand the definition of disability and overturn Supreme Court decisions that had narrowed the law's reach. As a result, the vast majority of blind and visually impaired people are unambiguously covered.

Who Enforces the ADA?

Title I (Employment)

Equal Employment Opportunity Commission (EEOC)

Titles II & III

U.S. Department of Justice, Civil Rights Division

Title IV (Telecommunications)

Federal Communications Commission (FCC)

Missouri State Law

Missouri Commission on Human Rights (MCHR)

The Five Titles of the ADA

The ADA is divided into five titles, each addressing a different area of public life.

Title I

Employment

Employers with 15+ employees

ADA Title I prohibits discrimination in all aspects of employment — hiring, pay, benefits, training, promotion, and termination. Employers must provide reasonable accommodations to qualified individuals with disabilities unless it would cause undue hardship.

Common Accommodations for Blind Employees

Screen reading software (JAWS, NVDA, VoiceOver)
Refreshable Braille display
Accessible document formats (Braille, large print, audio)
Modified workstation lighting and glare reduction
Assigned accessible parking
Audio description for video training content
Accessible company intranet and software
Restructured non-essential job duties

Pre-Employment Rules

  • Employers cannot ask about disability before making a conditional offer
  • Medical exams allowed only after conditional offer, and only if required of all candidates in the role
  • Cannot withdraw offer solely because of blindness if you can perform essential functions with accommodation

File complaints with the EEOC:

(800) 669-9040 — 300-day deadline in Missouri
Title II

State & Local Government

All government entities, regardless of federal funding

Title II requires that all programs, services, and activities of state and local government be accessible to people with disabilities. This includes not just buildings but communications, websites, documents, and how services are delivered.

Missouri Government Accessibility Obligations

  • Government websites and mobile apps — must meet WCAG 2.1 AA by April 2026 (DOJ Final Rule)
  • Voting — accessible polling places and audio ballot machines
  • Courts — accessible proceedings and accessible legal documents
  • State VR programs — services in accessible formats
  • Public meetings — agendas and materials in accessible format on request
  • Written notices — large print, audio, or electronic format upon request

New in 2024–2026

The DOJ issued a final rule in April 2024 requiring all state and local government websites to meet WCAG 2.1 Level AA. This is the first time a specific accessibility standard has been codified in ADA regulation.

Compliance deadlines:

  • April 24, 2026 — populations ≥ 50,000
  • April 26, 2027 — smaller jurisdictions
Title III

Public Accommodations

Private businesses open to the public

ADA Title III covers privately owned businesses and facilities open to the public, including restaurants, hotels, theaters, retail stores, professional offices, gyms, and healthcare facilities. Covered entities must not discriminate against blind customers and must provide auxiliary aids and services to ensure effective communication.

Auxiliary Aids & Services for Blind Customers

  • Accessible menus (large print, audio, electronic, or staff reader)
  • Accessible contracts and written materials in alternative formats
  • Accessible ATMs and self-service kiosks (speech output, accessible controls)
  • Screen-reader-accessible websites and digital interfaces
Title III does not require fundamental alteration of the nature of services. However, if a specific modification creates undue hardship, an alternative accessible method must be offered.

Filing Title III Complaints

Unlike Title I, you do not need to exhaust an administrative process before going to court. Options include:

  • File a complaint with the DOJ Civil Rights Division
  • File directly in federal or state court (no prior complaint required)

Damages, injunctive relief, and attorney's fees may be available in private lawsuits. The DOJ may also file pattern-or-practice suits.

Title IV

Telecommunications

Requires telephone and television services to be accessible. Key provisions for blind viewers:

  • Audio description (video description) — required on major broadcast and cable channels during designated programming
  • Video programming must include audio description that narrates key visual content
  • The FCC enforces video programming accessibility requirements
Title V

Miscellaneous Provisions

Title V includes critical protections that apply across all other titles:

  • Anti-retaliation — you cannot be penalized for asserting ADA rights, filing a complaint, or assisting someone else in exercising their rights
  • Non-diminishment — the ADA does not override greater protections in state law (so Missouri can provide stronger protections)
  • Covers individuals associated with people with disabilities

Web Accessibility & the ADA

DOJ Final Rule — April 2024

Government Websites Must Meet WCAG 2.1 AA

The U.S. Department of Justice issued a final rule under ADA Title II in April 2024, codifying WCAG 2.1 Level AA as the required standard for all state and local government websites and mobile applications. This is the first time a specific technical standard has been written into ADA regulation.

April 24, 2026

Populations ≥ 50,000

April 26, 2027

Smaller jurisdictions

Non-compliant government websites are subject to DOJ enforcement and private litigation under the ADA.

Private Business Websites (Title III)

While no equivalent final rule has been issued for Title III, federal courts across the country have increasingly ruled that private business websites are places of public accommodation covered by the ADA. Businesses that fail to maintain accessible websites face a growing volume of litigation and enforcement pressure.

Industry best practice — and the standard used by MCB — is WCAG 2.2 Level AA (published October 2023), which builds upon WCAG 2.1 with additional criteria especially relevant to blind and low-vision users.

Key WCAG Requirements That Matter Most for Blind Users

Alt Text

All meaningful images must have descriptive alternative text. Decorative images use empty alt attributes.

Keyboard Operability

All interactive elements — buttons, links, forms — must be fully operable by keyboard alone, with no mouse required.

Semantic HTML & ARIA

Proper headings, landmark regions, and ARIA attributes ensure screen readers can navigate and understand page structure.

Color Contrast

Normal text must achieve a 4.5:1 contrast ratio; large text 3:1. Critical for users with low vision.

Descriptive Links

Link text must describe the destination or action — not generic "click here" or "read more" phrases.

Accessible Forms

All form fields must have visible, programmatically associated labels. Error messages must be clear and specific.

Section 508

Section 508 of the Rehabilitation Act requires that federal agencies ensure their electronic and information technology is accessible. This applies to:

  • Federal government websites and software
  • Electronic documents and PDFs
  • Software and hardware procured with federal funds
  • Accessible multimedia content

Is Your Site Accessible?

Free tools to test your organization's website:

The Reasonable Accommodation Process

When a blind or visually impaired person needs an accommodation, the ADA envisions an interactive process between the individual and the entity. Both parties are expected to engage in good faith. Here is how the process works in an employment context (the same general framework applies to government services and public accommodations):

Notify

Inform your employer or entity that you need an accommodation due to a disability. You do not need to use legal terminology. Putting it in writing (email is fine) creates a record.

Engage

The entity is required to engage in good-faith interactive discussion to identify an effective accommodation. They may request documentation from a healthcare provider describing your functional limitations — not a diagnosis.

Implement

If the accommodation is reasonable and does not cause undue hardship, it must be provided. You may propose specific accommodations; the employer or entity may choose among effective options — they are not required to provide your first choice if an equally effective alternative exists.

Escalate if Denied

If the request is unreasonably denied, or if the interactive process stalls without progress, file a charge with the EEOC within 300 days in Missouri, or consult a disability rights attorney about direct litigation options.

Tips for a Successful Process

  • Document all communications in writing — save every email
  • Be specific about what you need and why it relates to your disability
  • If the process drags on, send a follow-up email noting the lack of progress

What Is "Undue Hardship"?

An employer can deny an accommodation if it would cause undue hardship — a significant difficulty or expense. Courts consider:

  • Cost of the accommodation
  • Overall financial resources of the employer
  • Size of the business and number of employees
  • Nature of the business operations

Cost Reality Check

The Job Accommodation Network (JAN) reports that 56% of accommodations cost nothing, and the median cost of those that do is under $300. Screen readers, Braille displays, and accessible software are almost never "undue hardship" for established employers.

Filing an ADA Complaint in Missouri

Choose the right agency based on the type of discrimination. Missing a filing deadline can permanently bar your claim.

Situation Agency Deadline Contact
Employment discrimination EEOC 300 days (Missouri) (800) 669-9040
State/local government (Title II) DOJ Civil Rights Division 180 days (800) 877-4339
Business / public accommodation (Title III) DOJ or federal court (no exhaustion required) No federal admin deadline (800) 877-4339
Inaccessible government website DOJ Civil Rights Division 180 days (800) 877-4339
Federal program / school / hospital (Section 504) Relevant federal agency OCR 180 days Varies by agency
Telecommunications (Title IV) Federal Communications Commission (FCC) Varies (888) 883-5322
Missouri Human Rights Act (state law) Missouri Commission on Human Rights 180 days (573) 751-3325

Missouri Commission on Human Rights

Missouri's Human Rights Act closely parallels the ADA. Filing with MCHR preserves both state and federal claims. MCHR investigates complaints and can attempt conciliation between parties.

Get Help from MCB

Not sure which agency to contact, or where to begin? MCB can help you understand your options and connect you with disability rights legal resources in Missouri.

Accessibility at MCB — We Practice What We Advocate

MCB's website is designed and maintained to meet or exceed WCAG 2.2 Level AA/AAA standards — reflecting our organizational commitment to the principles we advocate on your behalf.

Skip Navigation

Prominent skip link to main content on every page — the first element screen readers encounter.

High Contrast

MCB Blue at 11.4:1 contrast on white (AAA rated), exceeding the 7:1 AAA threshold.

Dark Mode

Light/dark toggle via Bootstrap data-bs-theme, persisted in localStorage.

Large Text Mode

One-click text scaling — scales the base rem from 1.0625 to 1.2 sitewide.

Keyboard Navigation

Fully keyboard-navigable — all interactive elements reachable and operable without a mouse.

Semantic HTML

Proper heading hierarchy (H1→H3), landmark regions (nav, main, footer), and ARIA throughout.

External Link Alerts

All external links announce "(opens in new tab)" to screen reader users via aria-label.

Structured Data

Schema.org JSON-LD markup on every page for rich search results and better discoverability.

Found an accessibility barrier on this website?

Please contact us and describe the issue. Accessibility feedback from blind and low-vision users is the most valuable testing we receive, and we are committed to addressing reported barriers promptly.

MCB's ADA Advocacy Work

MCB has advocated for the rights of blind and visually impaired Missourians since 1936. Our ADA advocacy today includes:

Legislative monitoring — tracking ADA and Section 504 enforcement actions in Missouri and reporting to members through the Chronicle and Community Connect

Member education — explaining rights through programs, publications, and the annual convention

ACB partnership — working with the American Council of the Blind on national ADA policy, amicus briefs, and regulatory comments

State engagement — attending Missouri legislative sessions to advance disability rights and accessibility legislation

Frequently Asked Questions

Yes. Nonprofit organizations are covered under ADA Title III if they operate places of public accommodation — including offices open to clients, event venues, or program facilities. Many nonprofits are also subject to Section 504 of the Rehabilitation Act if they receive federal grants or contracts.

Potentially yes. If the provider receives federal funding (Medicare, Medicaid, federal grants), Section 504 of the Rehabilitation Act applies and requires accessible communication. ADA Title III may also apply. File a complaint with the HHS Office for Civil Rights at (800) 368-1019 within 180 days.

For ADA Title III (public accommodations), yes — you can file directly in federal or state court without filing with the DOJ first. For ADA Title I (employment), you must exhaust the EEOC administrative process first and receive a Right to Sue letter before filing in court.

Not specifically Braille. The ADA requires "effective communication," which means providing accessible formats that work for the individual. This could be Braille, large print, audio, accessible electronic text, or a qualified reader — whatever is effective. The entity may choose among options that are equally effective.

Yes. Under a DOJ Final Rule issued in April 2024, all state and local government websites must meet WCAG 2.1 Level AA. Compliance is required by April 24, 2026 for jurisdictions with 50,000 or more residents, and April 26, 2027 for smaller jurisdictions. Federal websites are covered under Section 508.

A reasonable accommodation is any modification or adjustment that enables a person with a disability to enjoy equal access and opportunity. For blind employees, this commonly includes screen-reading software, accessible document formats, modified workstations, and restructured non-essential duties. Employers must provide it unless it causes undue hardship — a significant difficulty or expense considering the employer's size and resources.

ADA Title V prohibits retaliation for exercising or asserting ADA rights, filing a complaint, or assisting someone else in doing so. File a retaliation charge with the EEOC within 300 days in Missouri (for employment) or with the DOJ for other Title II/III retaliation. Document everything — emails, dates, and specifics of any adverse action.

Know the Law. Enforce Your Rights.

MCB's advocacy mission is grounded in the belief that knowledge is power. Join us to stay informed, get connected, and help build a more accessible Missouri.