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The Ultimate ADA Compliance Employer Checklist: A Guide for Businesses with 15+ Employees

October 17, 2024
Author: AccessAbility Officer

This article is designed to help you assess, analyze, and rank both your ADA compliance and disability inclusion against the Americans with Disabilities Act (ADA) and Equal Employment Opportunity Commission (EEOC).

The ADA regulations, EEOC and WCAG compliance requirements referred to in this article apply to businesses, nonprofits, and organizations with 15 or more employees. The ADA compliance checklist for employers herein will cover four critical areas for ADA compliance:

  1. Physical environment accessibility in the workplace. Think about your desks, bathrooms, and other physical areas in your workplace.
  2. Digital environment accessibility in the workplace. Think about your business software, applications, and any technologies required to perform job duties.
  3. Hiring and Recruiting. Think about your job posts, interviews, and everything building up to your new-hire’s first day on the job.
  4. Employee accommodations and onboarding. Think ergonomic chairs, assistive technologies, and how your employees sign up for benefits. 

In addition to each of these above four critical areas to assess, analyze, and rank your disability inclusion program outcomes, we provided an outline to an ADA Compliance Ranking System to help you capture the data, accurately inform leadership, and help your organization make better decisions on how to improve disability inclusion outcomes, accessibility compliance in the workplace, as well as all the additional cultural, productivity, and performance benefits from being a disability inclusive organization! 

If disability inclusion and accessibility compliance at work seems overwhelming, you’re not alone. It’s why businesses, organizations, and agencies choose The Organizational AccessAbility Toolkit (OAT) to deliver exactly what you need to comprehensively assess, address, and advance your disability inclusion outcomes - From executive engagement to disability workplace surveys, disability report frameworks, and step-by-step guidance - for only $5000. You can get started with the Organizational AccessAbility Toolkit here. Additional disability inclusion and ADA compliance resources for the workplace are provided at the end of this article. 

Table of Contents

1. Physical Workplace Accessibility Compliance

Two people in a workplace. The man, who uses a wheelchair, is working on a computer. Your objective with ADA compliance for the physical work environment is to ensure all your facilities are accessible for employees and customers with disabilities.  

Below are 8 common physical workplace ADA compliance violations organizations with 15 or more employees most often experience. While this compliance checklist for ADA compliance and EEOC compliance is a great start, we highly recommend you reviewing the ADA Standards for Accessible ADA Standards for Accessible Design as well as the ADA Title I – Employment compliance guidelines and especially the ADA Enforcement page which provides details on what constitutes an ADA violation. 

  1. Inaccessible Entrances and Exits 

Whether it is a lack of ramps, inadequate width of doorways, or inaccessible exits, the entrance to your building needs to be accessible. Often these violations occur because entrances lack appropriate ramps or automatic doors, or emergency exits don’t meet minimum accessibility standards. 

  1. Insufficient Accessible Parking Spaces 

The ADA requires a certain number of accessible parking spaces relative to the total number of parking spaces. Businesses often and unknowingly overlook this requirement, improperly mark spaces, or the spaces don’t meet size requirements, and then businesses get hit with an ADA legal claim. Be sure that you have the right number of accessible parking spaces, that they are the right size, and marked with appropriate signage and symbols. 

  1. Inaccessible Restrooms 

Restrooms are often designed without consideration for individuals who use wheelchairs, have limited mobility, or are of short stature. If your business facilities have restrooms without accessible stalls, are missing grab bars, or your sinks and counters are at inappropriate heights, get those problems fixed. Commonly, soap dispensers and hand dryers get mounted too high for individuals with some disabilities to access, so if they’re at your shoulder height or higher, correct that sooner than later. 

  1. Inadequate Signage 

While it seems like a “no-brainer,” many businesses are failing ADA compliance standards right now because they have yet to install ADA-compliant signage. What’s ADA compliant signage? From Braille signs, symbols for accessibility features, accessible way finding, and emergency exits. Signage is inexpensive, easy to install, and also communicates to employees your disability inclusion efforts. 

  1. Lack of Proper Emergency Evacuation Plans 

When supporting organizations advance their disability inclusion programs, nearly all lack formalized plans or accommodations for people with mobility, sensory, or cognitive disabilities during an emergency situation. Whether a fire, active shooter, or other emergency, businesses must ensure policies, procedures, and facilities are accessible despite an on-going emergency in progress. Take action by adapting your current emergency preparedness to include a comprehensive evacuation plan that includes accessible exits, alarms with both visual and auditory signals, and designated assistance points. 

  1. Non-Compliant Workstations and Break Areas 

Many businesses today are providing work station accommodations such as standing desks to support the differing and evolving needs of their employees. However, while many of these workstation modernizations were originally intended for people with disabilities, their desks may not be adjustable for wheelchair users, break areas may be missing accessible countertops, and the pathways between workstations, restrooms, and break areas may be in violation of the ADA. 

ADA Compliance Checklist for Physical Workplace Accessibility  

A Man in a Wheelchair Waits in Front of an Elevator

Below is an example ADA and EEOC checklist that includes the requirements, checks you need to perform, and a link to each legal/regulatory compliance reference for accessible entrances, parking spaces, bathrooms, and emergency evacuation plans. 

  1. Entrance & Egress Accessibility 

Requirement: All building entrances should have ramps or elevators where necessary, with appropriate signage. 

Check: Are ramps, entrances, and exits accessible to individuals using mobility devices? 

Reference: ADA Standards for Accessible Design – Entrances 

Score (0-10) 

0: No accessible entrances 

5: 50% entrances are accessible with signage 

10: All entrances fully accessible with signage 

  1. Accessible Parking 

Requirement: Parking facilities must include a minimum number of accessible spaces based on the size of the parking lot. 

Check: Do you have enough accessible parking spots, and are they marked appropriately? 

Score (0-10) 

0: No accessible parking 

5: 50% of parking spaces compliant with ADA guidelines for space numbers and design  

10: Fully compliant with ADA guidelines for space numbers and design 

  1. Restrooms 

Requirement: Restrooms must provide accessible stalls with grab bars, sufficient turning space, and accessible sinks. 

Check: Are restroom stalls and sinks ADA-compliant? 

Reference: ADA Standards for Accessible Restrooms 

Score (0-10) 

0: No accessible restrooms 

5: 50% compliant restrooms with proper signage  

10: Fully compliant restrooms with proper signage 

  1. Emergency Evacuation Plans 

Requirement: Emergency exits must be accessible, and evacuation plans must consider people with disabilities. 

Check: Are evacuation routes accessible to all employees, and do you have plans for individuals with mobility, sensory, and cognitive challenges? 

Score (0-10) 

0: No evacuation plans for people with disabilities 

5: Partially integrated, accessible evacuation procedures (fully integrated for at least 1 disability category) 

10: Fully integrated, accessible evacuation procedures 

2. Digital Accessibility Compliance of Workplace Applications & Software 

A blind woman working with her computer and using a braille display.

Your objective with ADA compliance for the digital work environment is to ensure all your internally-facing workplace applications, software, websites, electronic files, and communications are ADA compliant, conform with WCAG, and are accessible to people with disabilities.  

While digital accessibility awareness today for public-facing assets like websites, mobile apps, and software has exponentially grown over the last couple of years, many businesses with more than 15 employees are not aware of the ADA compliance requirements for digital accessibility of their internal assets. 

Below are four common physical workplace ADA compliance violations organizations with 15 or more employees most often experience. While this compliance checklist for ADA compliance is a great start, we highly recommend you reviewing the documentation on WCAG 2.1 AA compliance, the EEOC requirements, and ADA responsibilities ADA responsibilities for employers.

  1. Inaccessible Company Websites and Intranets 

Employees who rely on assistive technology, such as screen readers or voice navigation, may have difficulty accessing your intranet, employee portals, or other internally facing company websites if digital accessibility compliance, testing, or remediation has not been prioritized. 

The current industry standard for digital accessibility compliance is the Web Content Accessibility Guidelines 2.1 (commonly referred to as WCAG 2.1 AA), however the new WCAG 2.2 guidelines were officially released in October of 2023. The US Department of Justice and Department of Health and Human Services has already mandated federal agencies must comply with these accessibility standards by April of 2025, and even the ADA.gov released a Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments as a result. 

  1. Inaccessible Employee Software Systems 

If your organization has a software or application for employees to complete their daily job duties, it needs to be compliant with the ADA. Internal systems such as HR portals, employee training modules, or performance management tools are included in this scope and must be accessible to individuals using assistive technology like screen readers. 

To assess your risk, conduct an accessibility audit of internal systems and work with software providers to implement accessibility features, such as screen reader compatibility, keyboard-only navigation, and captioning. Barriers when accessing payroll, benefits, or other critical job-related information  are common occurrences that leave organizations vulnerable. 

  1. Non-Accessible Document Formats 

This violation occurs most commonly when teams are sharing assets, documents, or files that have not been made accessible with their co-workers who happen to be visually impaired or blind. Inaccessible documents, slideshow decks, and electronic files are nearly impossible for the blind or visually impair to engage with, which is what leads to an ADA claim being filed against your organization. 

To remediate this risk, ensure documents (PDFs, Word files, etc.) are made accessible, are properly tagged, feature text alternatives for images, and have heading structures that assist screen readers. 

It is important to note that neither Adobe’s Accessibility Checker nor Microsoft’s Accessibility Checker can validate an electronic file that is indeed accessible to assistive technology users. Unfortunately, accessibility automation testing (like with these Adobe and Microsoft accessibility automation tools) cannot and do not ensure your electronic files are accessible. Manual testing and remediation are required. You can learn how to Make Your Word Documents Accessible here.  

  1. Inaccessible Job Applications & Job Application  Platforms 

One of the most difficult things to do as a person with a severe disability is secure employment from an employer. Additionally, as an employer, it is incredibly frustrating to receive a lawsuit from a potential candidate because the job application process or platform does not meet ADA digital accessibility compliance requirements. 

Job application portals and recruitment websites are notoriously inaccessible to individuals with disabilities. The biggest barriers are with unlabeled forms and buttons that prevent an applicant from completing and submitting their application. 

Ensure all your job application platforms are fully accessible and that forms are properly labeled for screen reader navigation by performing manual testing with a screen reader. If potential employees with disabilities are unable to complete the application process, this will lead to discrimination claims under the ADA or EEOC. 

Increasing regulations can feel intimidating. It’s why organizations turn to The Organizational AccessAbility Toolkit (OAT) to deliver exactly what you need to comprehensively assess, address, and advance your disability inclusion outcomes - From digital accessibility compliance to executive engagement, disability workplace surveys, disability report frameworks, and step-by-step guidance - for only $5000. You can bypass problems like this and get started with the Organizational AccessAbility Toolkit here. 

ADA Compliance Checklist for Workplace Applications & Software 

Computer screen displaying an application with a check mark and a 'Standard' status confirmation.

Below is an example ADA digital accessibility compliance checklist for an employer with 15 or more employees that includes the digital accessibility compliance requirements, digital accessibility checks you need to perform, and a link to each legal/regulatory digital accessibility compliance reference for workplace applications and software. 

  1. Website and Web App Accessibility 

Requirement: All websites and web-based applications in the workplace must be accessible according to ADA and WCAG compliance. 

Check: Is your website WCAG 2.1 AA compliant? Use automated accessibility testing tools to get an initial baseline of ADA accessibility compliance. Incorporate manual accessibility testing using a screen reader to ensure your websites and web applications indeed are accessible, meeting or exceeding ADA and WCAG 2.1 AA  compliance standards for accessibility. Download the DIY Digital Accessibility Compliance Guide to learn how to perform manual screen reader testing on your workplace websites and web applications. 

Reference: Web Content Accessibility Guidelines 2.1 also known as WCAG 2.1 AA  

Score (0-10) 

0: Website not accessible 

5: Partially compliant with WCAG 2.1 AA standards 

10: Fully compliant with WCAG 2.1 AA standards 

  1. Document Accessibility 

Requirement: All electronic documents (PDFs, Word, PowerPoint, etc.) must be accessible  and meet ADA and WCAG compliance guidelines. 

Check: Do all documents meet accessibility standards and are usable by people using assistive technology? Run accessibility automation and then perform manual screen reader testing. Ensure compliance with manual testing as accessibility automation testing does not test accessibility completely. Electronic files will pass automated accessibility scans when in fact they are not accessible to assistive technology users 

Score (0-10) 

0: No accessible documents 

5: Over 50% of documents are accessible as confirmed by automation and screen reader testing 

10: All documents are accessible and meet or exceed ADA and WCAG accessibility compliance standards 

  1. Intranet and Employee Platforms 

Requirement: Internal systems, such as HR platforms and employee training systems, must be accessible. 

Check: Are your employee platforms and intranet WCAG 2.1 AA compliant and accessible to employees with disabilities? Perform automated testing and manual screen reader testing as described in the DIY Digital Accessibility Compliance Guide to ensure conformance. 

Score (0-10) 

0: Platforms not accessible 

5: Partially compliant and mostly user-friendly for employees with disabilities  

10: Fully compliant and user-friendly for employees with disabilities 

3. Hiring and Recruitment Practices 

Computer screen displaying a job application

Your objective with ensuring ADA accessibility compliance across your hiring and recruitment practices is to ensure all your job descriptions, accommodations policies and processes, online applications and job boards, and interviews are accessible and inclusive for everyone. 

The recruiting, interviewing, and hiring process can be tricky for employers with 15 or more employees. A candidate with a disability is a risk when organizations have not met the legal requirements to meet ADA accessibility and EEOC standards for inclusion. The greatest areas of vulnerability include job descriptions, job boards, and technologies like automation and artificial intelligence across the recruiting, interviewing, and hiring processes. 

While this compliance checklist for ADA compliance across hiring and interviewing candidates with disabilities is a great start, we highly recommend you reviewing the EEOC’s Job Applicants & the ADA, Recruiting, Hiring, & Retaining Employees with Disabilities, and EARN’s Accessible & Authentic Interviews For Candidates With Disabilities. 

ADA Compliance Checklisfor Hiring and Recruitment Practices 

Below is an example ADA Compliance Checklist for Hiring and Recruitment Practices for an employer with 15 or more employees that includes the compliance requirements, checks you need to perform, and a link to each compliance reference for hiring and interviewing candidates with disabilities. 

  1. Job Descriptions 

Requirement: Ensure job descriptions include language regarding your business’s disability inclusion efforts, that accommodations are available for candidates with disabilities, and you encourage applications from individuals with disabilities. 

Check: Do your job postings have alternative methods of applying, such as submitting applications over email or phone? Are you using inclusive language that reflects your disability readiness? Do you state applications from people with disabilities are encouraged? 

Score (0-10) 

0: No accommodations mentioned in job postings 

5: For most job postings, accessibility has been tested, alternative methods of applying are communicated, and disabled candidate applications are encouraged. 

10: All job postings have been tested for accessibility, alternative methods of applying are communicated, and disabled candidate applications are encouraged. 

  1. Job Applications & Job Board Digital Accessibility 

Requirement: Ensure your online job board or application system meets or exceeds ADA website accessibility standards so it is accessible to people with disabilities reliant on assistive technology like screen readers, speech-to-text, and switch controls. 

Check: Manually test the digital accessibility compliance of your job board and job applications using a screen reader to confirm each step in the application process is compliant with ADA website accessibility laws. 

Reference: WCAG 2.1 AA compliance and EEOC requirements. 

Score (0-10) 

0: Not accessible 

5: Partially accessible with WCAG 2.1 AA guidelines with little or no severe accessibility violations  

10: Fully accessible with WCAG 2.1 AA guidelines with no severe accessibility violations. 

  1. Interview Process Accommodations 

Requirement: Employers must provide reasonable accommodations during the interview process, such as accessible interview locations, sign language interpreters, or adaptive technology for virtual interviews. 

Check: Are accommodations like providing interpreters, extended interview time, or remote interview options available and offered for all interview candidates? Are interview spaces physically accessible, including ramps, elevators, and accessible restrooms? 

Score (0-10) 

0: No accommodations are offered, nor are interviews made to be accessible and inclusive. 

5: Accommodations are usually offered to candidates and interviews are accessible for nearly all candidates. 

10: Accommodations are always offered to every candidate and interviews are universally designed for people of all abilities. 

  1. Training on Disability Sensitivity for HR Staff 

Requirement: Provide training for HR personnel and hiring managers on ADA requirements, accommodations, and disability etiquette to prevent discrimination and unconscious bias during the interview and hiring process. 

Check: Have all hiring managers received training on ADA compliance and disability sensitivity? Have they passed an exam that validates their disability readiness? 

Score (0-10) 

0: No training provided 

5: 50% or more of HR staff are fully trained in the ADA, EEOC, and disability best-practices. 

10: All HR staff are fully trained in the ADA, EEOC, and disability best-practices. 

4. Employee Accommodations and Onboarding 

A programmer who has Down syndrome.

Your objective for disability inclusion and compliance across accommodations and onboarding is ensuring employees with disabilities are aware of accommodations available, the onboarding processes are accessible, and trainings have been optimized for compliance with the ADA and WCAG. 

Training and onboarding have the highest risk of ADA compliance violations for employers as most of these systems, software, and benefit portals are developed by third parties who may not have a digital accessibility compliance team. Sometimes, these onboarding, training, and benefit platforms are unable to be remediated into compliance. Employers should assess these platforms using a trusted accessibility partner to prevent non-compliance.  

While this compliance checklist for ADA accommodations and onboarding employees with disabilities is a great start, we highly recommend you reviewing the EEOC’s Job Applicants & the ADA, and Recruiting, Hiring, & Retaining Employees with Disabilities. 

ADA Compliance Checklist For Employee Accommodations & Onboarding 

Below is an example ADA Compliance Checklist for Hiring and Recruitment Practices for an employer with 15 or more employees that includes the compliance requirements, checks you need to perform, and a link to each compliance reference for hiring and interviewing candidates with disabilities. 

  1. Reasonable Accommodations for Employees 

Requirement: Employers must provide reasonable accommodations such as ergonomic workstations, assistive technology, or modified work schedules for employees with disabilities. 

Check: Are accommodations provided promptly and effectively for all employees with disabilities? What is the process and timeline from the point of an accommodation request to a decision, to delivering the accommodation? 

Score (0-10) 

0: No accommodations in place 

5: Accommodations are provided on a case-by-case basis 

10: Comprehensive accommodations provided with streamlined review and approval process. 

  1. Accessible Onboarding Materials 

Requirement: Onboarding materials must be accessible, including training videos, documents, and digital systems. 

Check: Are all training materials WCAG-compliant and available in multiple formats like audio or large print.? 

Score (0-10) 

0: New-hire onboarding and trainings do not meet accessibility compliance standards 

5: New-hire onboarding and trainings partially meet accessibility compliance standards 

10: New-hire onboarding and trainings meet or exceed accessibility compliance standards 

Example Employer ADA Compliance Ranking System 

Businesses needing a more formal assessment and analysis of their recruiting, interviewing, hiring, onboarding, training, and accommodations rely on the Organizational AccessAbility Organizational AccessAbility Toolkit (OAT) to deliver exactly what you need to comprehensively assess, address, and advance your ADA compliance and disability inclusion outcomes - From executive engagement to disability workplace surveys, disability report frameworks, and step-by-step guidance - for only $5000. Get started with the Organizational AccessAbility Toolkit here. 

If leveraging the Organizational AccessAbility Toolkit (OAT) to ensure you’re a disability inclusive, disability ready employer with robust policies, practices, and accommodations, then use this compliance guide and checklist with your team to begin assessing where you stand. 

Answer the questions and add up your scores. Compare and contrast your organization’s results with the scoresheet below. 

Scoring Your Organizational Accessibility Readiness for Employees with Disabilities 

The below table will help you quantify where your organization is overall, gaps in your disability inclusion efforts, and next steps. 

Note. This table offers a very simplified version of quantitative results with high-level feedback based on the assessments and analysis an organization can expect when leveraging the Organizational AccessAbility Toolkit. 

Table that outlines three different score ranges with corresponding rankings and analysis regarding a business's compliance with ADA (Americans with Disabilities Act) and accessibility regulations. The table is structured into three columns: Score, Ranking, and Analysis. Score range 80–100: Ranking is 'Disability Inclusive & Ready.' The analysis states that the business is well-aligned with ADA, EEOC (Equal Employment Opportunity Commission), and accessibility regulations. Periodic assessments are recommended to maintain compliance as regulations evolve. Score range 60–79: Ranking is 'Partially Disability Inclusive – Needs Improvement.' The analysis mentions multiple areas where ADA compliance is lacking, making the business moderately vulnerable to ADA lawsuits. A customized assessment, road map to address gaps, and legal protection are suggested. Score range 0–59: Ranking is 'Not Compliant, Nor Disability Inclusive, & Legally Vulnerable.' The analysis notes significant ADA compliance gaps, and the business should not recruit, interview, or hire people with disabilities in this state. There is a high risk of ADA lawsuits. It is recommended to work with a disability inclusion and digital accessibility expert if the business plans to hire people with disabilities in the future.

Schedule an introductory strategy call for advancing your disability inclusion efforts here 

Comprehensive ADA Compliance Checklist for Employers Conclusion 

This ADA Compliance assessment and checklist provides businesses with actionable steps, compliance references, and method to rank their adherence to the ADA and EEOC. 

While this article and checklist focuses on human resources functions, the Organizational AccessAbility Toolkit helps you advance ADA compliance across your company, including executive and leadership, interdepartmental accessibility, cultural disability inclusion, and much more. For just $5000, your organization will dramatically advance your organizational approach toward disability inclusion, disabled employees, and ADA compliance. 

If you are not ready for the OAT, below are additional disability inclusion resources you can begin to implement into your organization today! 

Share this article with other professionals in your organization who are committed to advancing disability inclusion and ensuring compliance with the Americans with Disabilities Act. 

Additional Disability Inclusion & Digital Accessibility Resources 

Use these disability inclusion and ADA compliance resources to achieve better outcomes in your organization! 

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