NSDA respectfully submitted a letter today to the Small Business Administration's Office of Advocacy as they consider improvements to the Web Content Accessibility Guidelines (“WCAG” 2.1) adopted under Title II of the Americans with Disabilities Act for small entities. 

Here are a few key concepts:

1. Allow a reasonable (7 to 14-days) remediation and/or cure period for organizations demonstrating good-faith efforts, including maintaining (1) an accessibility statement and (2) a process to address requests for accommodation or to report problems 
2. For documents, an explicit statement that HTML is an acceptable format so long as they are substantially accurate, downloadable, has equivalent functionality, and especially for complex documents where live or responsive assistance is provided  
3. Closed captions:  understand and recognize automated captions may be permissible if there is (a) a human on the call that can answer questions if captions are unclear; and (b) captions are reasonably reviewed for general accuracy 
4. An explicit statement covering social media that content meets the standard where there is (1) alt text and/or (2) if they make the same content available on their public website (ideally their gov)
5. More reassurances around archived content that protect transparency, records retention, and historical preservation obligations. Folks are still being advised to “remove everything” that is non-compliant, which may not be appropriate depending on their jurisdiction, governing law, transparency obligations, and other legal requirements.

Read here for more information and stay tuned. 

L. NSDA SBA 5.29.26.docx