Does a Church Website Have to Be Accessible?

Every so often a church gets an email claiming their website is out of compliance with the ADA and offering, for a fee, to fix it before they get sued.

Before anyone panics or writes a check, the legal picture is worth understanding, because it’s not what those emails imply.

The legal answer

Religious entities are exempt from Title III of the Americans with Disabilities Act, the section covering public accommodations. The ADA National Network, the federally funded network of ADA centers, states the exemption plainly.

The exemption is broader than most people expect. It covers a religious organization’s facilities, programs, and activities, whether those are religious or secular in nature. A religious entity doesn’t lose the exemption because it runs something open to the general public — a private school operated by a religious organization is still covered by the exemption.

Two edges to know about:

Federal funding. A religious entity that receives federal funding may be subject to Section 504 of the Rehabilitation Act, which is a separate law with its own obligations.

Non-religious tenants. If a non-religious business rents your space to run a public accommodation, that tenant isn’t exempt. The exemption follows the religious entity, not the building.

Employment is also separate. Title I obligations can apply to a church with enough employees.

The rule you’ve been hearing about is a different one

In April 2024 the Department of Justice published a final rule requiring WCAG 2.1 Level AA for web content and mobile apps. Its own fact sheet on ADA.gov lays out the scope. It’s real and it’s significant, and it is a Title II rule.

Title II covers state and local government entities. Not churches.

An interim final rule in April 2026 extended the deadlines: April 26, 2027 for public entities serving populations of 50,000 or more, and April 26, 2028 for smaller ones and special district governments.

If a vendor emails your church citing that rule as a legal obligation you’re under, they either haven’t read it or are counting on you not to.

Why the exemption isn’t the end of it

Here’s where we’d gently push back on treating this as settled.

An exemption tells you what you can’t be sued for. It tells you nothing about whether a person with low vision can find your service times, or whether someone hard of hearing can follow last Sunday’s sermon.

The CDC puts it at more than one in four US adults reporting some type of disability. In a congregation of two hundred, that isn’t a hypothetical. It’s a section of your building.

And the group most affected by inaccessible church websites skews older — people with declining vision, reduced fine motor control, hearing loss. That’s frequently the most faithful part of a congregation, and the part least likely to complain about a website. They’ll just quietly stop using it and call the office instead, and you’ll never know that’s why the phone rings.

We’re not going to construct a legal threat that doesn’t exist. But “we are legally permitted to make this hard for people” is a strange place for a church to land.

The list that covers most of it

Accessibility has a reputation for being enormous. WCAG 2.1, published by the W3C, is a large document. But the barriers people actually hit are concentrated in a handful of places, and most of them are quick.

Alt text on meaningful images. A short description of what the image conveys, read aloud by a screen reader. Purely decorative images should be marked as such so they’re skipped. This is also the single most common reason a church’s service times are invisible to search engines and AI assistants — text inside a graphic isn’t text.

Real headings. A heading needs to be marked as a heading in the page structure, not just text made bigger and bold. People using screen readers navigate by jumping between headings, the way you’d skim with your eyes. Fake headings make the page one undifferentiated wall.

Enough contrast. Light grey text on white looks refined in a design mockup and is unreadable on a phone in a parking lot at 2pm. This one affects everybody, not only people with low vision.

Captions on video. Sermon recordings especially. Auto-generated captions are imperfect and vastly better than none, and they help people watching without sound too, which is most people on a phone.

Descriptive links. “Register for VBS” instead of “click here.” Someone tabbing through your links hears them out of context.

Labeled forms. Every field needs a real label attached to it, not just placeholder text that vanishes when someone starts typing.

Keyboard operability. Try navigating your own site with the Tab key only. If you can’t reach the menu or submit the contact form, neither can someone who doesn’t use a mouse.

About those overlay widgets

You’ll be offered a script that promises instant compliance in one line of code.

Be skeptical. Accessibility advocates are broadly critical of overlays, which attempt to patch a page after it loads rather than fixing the underlying markup. At best they’re a supplement. At worst they interfere with the assistive technology someone is already using successfully.

There’s no line of code that makes an inaccessible page accessible. There’s just doing the seven things above.

Where we’d land

You’re almost certainly not legally required to do any of this. If someone tells you otherwise, ask them which title of the ADA they mean, and watch what happens.

Do the list anyway. Not because of a rule, and not out of guilt. Because a website’s whole job is telling people what time you meet and how to get in the door, and it’s worth checking that it does that for everyone who’s trying to come.

Our church website checklist covers what belongs on the site in the first place. This is the other half: making sure the people who need it can actually use it.