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Words by
Kaine Shutler

TL;DR
Key takeaways
Under the ADA (Americans with Disabilities Act), the US Department of Justice says businesses open to the public must make the goods and services they offer online accessible to disabled people.
Inaccessible online learning has cost organisations from $5,000 paid to one learner (Teachers Test Prep) to more than $1.5 million in legal fees (Harvard), plus years of required fixes and audits.
Public universities, community colleges and state agencies must meet WCAG (Web Content Accessibility Guidelines) 2.1 AA from April 2027 or 2028, including content their vendors provide.
When Harvard settled a lawsuit over uncaptioned online videos in 2019, it agreed to caption what it posts from then on and to pay the other side's lawyers more than $1.5 million (The Harvard Crimson). A university in Louisiana paid a blind student $23,543 after an online course tool didn't work with their screen reader (US Department of Justice). An exam-prep company paid $50,000 because its online course videos had no captions (US Attorney's Office).
The same law reaches small businesses too, usually by letter. On 28 October, a law firm wrote to a small business owner about their website. A visually impaired client of the firm had tried to use the site with a screen reader and couldn't use many of its features. The letter cited the ADA (Americans with Disabilities Act) and California's Unruh Civil Rights Act, asked to discuss "having someone fix the website and the settlement of his claims", and gave a deadline of 11 November. That's two weeks.
The owner posted it on r/WordPress with one line: "Little freaked out about this tbh." It drew 186 comments.

Under the Unruh Act alone, a business found to have discriminated owes at least $4,000 per violation, plus the other side's legal fees (California Civil Code § 52). I think it's worth knowing what this has cost other organisations, because a learning platform has a lot more to get right than most websites. I'm not a lawyer, so treat this as a starting point for a conversation with one.
What ADA website compliance means
A lot of the replies said letters like this are a scam and can be ignored. Some of them probably are sent in bulk. But the legal basis is real, and the numbers are going up.
The US Department of Justice (DOJ) says the ADA requires businesses open to the public to give disabled people equal access to their goods and services, and that this applies to "those offered on the web" (ADA.gov). There's no detailed federal regulation for private businesses. Instead, the DOJ points to existing standards, including the Web Content Accessibility Guidelines (WCAG), as guidance.
Courts don't all read it the same way. California's courts have held that a business that only operates online isn't covered by the ADA, which may be why letters like this one also cite the Unruh Act. Even so, federal website accessibility lawsuits went from 2,452 in 2024 to 3,117 in 2025, and those figures don't include state-court cases or demand letters (Seyfarth Shaw, via Mondaq).
There's a second deadline that matters more for training providers. State and local governments, including public universities and community colleges, have to meet WCAG 2.1 AA on their websites and apps by 26 April 2027, or 26 April 2028 for smaller ones (ADA.gov). The rule also covers content provided through vendors. So if you sell training to a public university or a state agency, your LMS (learning management system) is probably part of what they have to make accessible.
Businesses open to the public: ADA Title III, plus state laws such as Unruh in California. WCAG is the DOJ's reference. Applies now.
State and local governments serving 50,000+ people, including public universities: ADA Title II web rule, WCAG 2.1 AA, by 26 April 2027.
Smaller governments and special districts: ADA Title II web rule, WCAG 2.1 AA, by 26 April 2028.
What non-compliance has cost
The cost usually comes in three parts: money paid to the people affected or as a penalty, the other side's legal fees, and years of required fixes and reporting. Here's what that looked like in cases involving online learning and other websites.
Harvard, 2019. Online videos without captions. More than $1.5m in the plaintiffs' legal fees, and a commitment to caption all new content, and old content within 5 business days of a request.
MIT, 2020. Online videos without captions. More than $1m in legal fees, and captions on its online content.
An exam-prep company, 2019. Online course videos without captions. $40,000 to four deaf learners and a $10,000 civil penalty.
Teachers Test Prep, 2018. Online video courses without captions. $5,000 to the complainant, and captions on its courses.
Miami University, 2016. Websites, course materials and its LMS. $25,000 to students, and its LMS and web content brought to WCAG 2.0 AA.
Louisiana Tech University, 2013. An online learning product. $23,543 to the student, and course content brought to WCAG 2.0 AA.
edX, 2015. Its course platform and website. WCAG 2.0 AA within 18 months, an accessibility coordinator and outside audits for 4 years.
H&R Block, 2014. Website, online tax tool and apps. $45,000 in damages, a $55,000 civil penalty and 5 years of audits.
Netflix, 2012. Streaming video without captions. $755,000 in legal fees and costs.
Target, 2008. Its online store. A $6m damages fund for the class, plus 3 years of monitoring.
Some of the cost never shows up as a number. After the Department of Justice found that UC Berkeley's free online lectures weren't accessible, Berkeley took more than 20,000 videos out of public view rather than fix them all (Inside Higher Ed). Five years later it still signed a consent decree to make its online content meet WCAG (US Department of Justice).
The DOJ can also seek a civil penalty of up to $118,225 for a first violation of the ADA's rules for businesses, and $236,451 for a later one (Federal Register).
The legal fees are usually bigger than the fix
In the first website case to go to trial under the ADA, Winn-Dixie was ordered to make its site meet WCAG 2.0 AA and to pay $105,271 in the plaintiff's fees and costs. An expert had estimated the fix at under $37,000 (Legal Newsline). An appeals court later vacated the judgment, but only after years of litigation (Justia).
It's the same in other cases. In the Netflix captioning case nobody was paid damages, but the fees and costs came to $755,000. Robles v. Domino's went to the Supreme Court, which declined to hear it, and the case settled in 2022, six years after it started (JD Supra). I'd guess most never get that far. Many settle early, and as one firm that defends them puts it, the plaintiff's fees "can quickly eclipse the cost of actually making the compliant modifications" (Kubicki Draper).
So the cheapest version of this, by a long way, is finding and fixing the problems before anyone writes to you.
Why an LMS has more to check than a brochure site
The letter above was about a WordPress marketing site. A learning platform has that, plus everything a learner does after they log in: the course player, videos, quizzes and timed exams, downloadable PDFs, certificates and checkout, and things like that. Each of those has to work with a keyboard and a screen reader, and video needs captions.
PDFs are the one I'd look at first. One commenter, who runs the website of a large state organisation, said an independent auditor found they mostly passed but had around 5,000 scanned PDFs that weren't accessible. Those PDFs belonged to lots of different departments, so fixing them took several rounds of training. Learning platforms often carry a lot of PDFs too. For one aviation client, every practical assessment came with a PDF checklist until we moved the checklists into the course itself.
It also matters who you sell to. On our sales calls, accessibility came up with 8% of larger organisations and none of the smaller ones. Among clients who went on to scope a build with us, it was 24%. When a university or health system asks for an accessibility report during procurement, the answer depends on the platform. A missing report can hold up the renewal or the contract while it's sorted out.
Another commenter, who said they'd dealt with these letters at an agency many times, said the firms sending them often just run an automated scan of the site first. If that's right, the problems a free scanner can find are the ones to fix first.
What we check in an accessibility health check
If a letter like this arrived tomorrow, I think the most useful thing you could have is a recent, written record of where your platform stands and what you're fixing. That's what our health check gives you, whichever LMS you're on.
Designers and developers review the platform together. For accessibility, we test the pages learners use most against WCAG 2.1 AA, with automated tools and a screen reader, on desktop and on a phone. In the same review we look at security and data, reporting, integrations and performance, because a customer's procurement team usually asks about all of them at once.
You get a fix list ordered by impact and effort, with a cost for each item, written so your own developers, a freelancer or our team can act on it. The accessibility and security notes can go straight into a customer's vendor questionnaire. It takes a few days of our time, and you keep everything we find.
If we already build or run your platform, I'd suggest doing this before your next renewal or procurement round rather than after a letter. If you're on another platform, it works the same way.
Want to know where your LMS stands? Book a health check.
If a letter does arrive
The advice in the Reddit thread that I'd agree with: speak to a lawyer before you reply, don't ignore it, and start fixing what you can straight away. Keep a record of what you found and what you fixed, and when. One commenter also suggested publishing an accessibility statement that says how people can report a problem, which I think is sensible whether or not you get a letter.
FAQ
What is ADA website compliance?
It means disabled people can use your website, including its content, forms and checkout, on equal terms. The DOJ says the ADA applies to goods and services businesses offer on the web, and points to WCAG as guidance (ADA.gov).
How much does an ADA website lawsuit cost?
It varies widely. Settlements involving online courses have ranged from $5,000 paid to one learner to more than $1.5 million in the plaintiffs' legal fees, and most also require years of fixes and audits. In California, the Unruh Act adds a minimum of $4,000 per violation.
Does the ADA apply to online courses and learning platforms?
If you sell training to the public, your LMS is part of how you offer that service, so the same DOJ position applies. Public universities and state agencies must also meet WCAG 2.1 AA under the Title II rule, including content from vendors (ADA.gov).
What should I do if I get an ADA demand letter?
Speak to a lawyer before you reply, and start fixing the accessibility problems straight away. Keep a dated record of what you found and fixed.
When is the ADA Title II web accessibility deadline?
26 April 2027 for state and local governments serving 50,000 people or more, and 26 April 2028 for smaller ones and special districts. The DOJ moved both dates back a year in April 2026 (ADA.gov).

Kaine Shutler is the founder and managing director of Plume, a studio specialising in custom learning technology. With 14 years of experience, Kaine has established expertise in Learning Management Systems, UI/UX design, and scalability, working with clients including Google and training businesses across multiple sectors.
Harvard Paid $1.5m in Legal Fees Over Captions: The Real Cost of an Inaccessible LMS

Words by
Kaine Shutler

TL;DR
Key takeaways
Under the ADA (Americans with Disabilities Act), the US Department of Justice says businesses open to the public must make the goods and services they offer online accessible to disabled people.
Inaccessible online learning has cost organisations from $5,000 paid to one learner (Teachers Test Prep) to more than $1.5 million in legal fees (Harvard), plus years of required fixes and audits.
Public universities, community colleges and state agencies must meet WCAG (Web Content Accessibility Guidelines) 2.1 AA from April 2027 or 2028, including content their vendors provide.
When Harvard settled a lawsuit over uncaptioned online videos in 2019, it agreed to caption what it posts from then on and to pay the other side's lawyers more than $1.5 million (The Harvard Crimson). A university in Louisiana paid a blind student $23,543 after an online course tool didn't work with their screen reader (US Department of Justice). An exam-prep company paid $50,000 because its online course videos had no captions (US Attorney's Office).
The same law reaches small businesses too, usually by letter. On 28 October, a law firm wrote to a small business owner about their website. A visually impaired client of the firm had tried to use the site with a screen reader and couldn't use many of its features. The letter cited the ADA (Americans with Disabilities Act) and California's Unruh Civil Rights Act, asked to discuss "having someone fix the website and the settlement of his claims", and gave a deadline of 11 November. That's two weeks.
The owner posted it on r/WordPress with one line: "Little freaked out about this tbh." It drew 186 comments.

Under the Unruh Act alone, a business found to have discriminated owes at least $4,000 per violation, plus the other side's legal fees (California Civil Code § 52). I think it's worth knowing what this has cost other organisations, because a learning platform has a lot more to get right than most websites. I'm not a lawyer, so treat this as a starting point for a conversation with one.
What ADA website compliance means
A lot of the replies said letters like this are a scam and can be ignored. Some of them probably are sent in bulk. But the legal basis is real, and the numbers are going up.
The US Department of Justice (DOJ) says the ADA requires businesses open to the public to give disabled people equal access to their goods and services, and that this applies to "those offered on the web" (ADA.gov). There's no detailed federal regulation for private businesses. Instead, the DOJ points to existing standards, including the Web Content Accessibility Guidelines (WCAG), as guidance.
Courts don't all read it the same way. California's courts have held that a business that only operates online isn't covered by the ADA, which may be why letters like this one also cite the Unruh Act. Even so, federal website accessibility lawsuits went from 2,452 in 2024 to 3,117 in 2025, and those figures don't include state-court cases or demand letters (Seyfarth Shaw, via Mondaq).
There's a second deadline that matters more for training providers. State and local governments, including public universities and community colleges, have to meet WCAG 2.1 AA on their websites and apps by 26 April 2027, or 26 April 2028 for smaller ones (ADA.gov). The rule also covers content provided through vendors. So if you sell training to a public university or a state agency, your LMS (learning management system) is probably part of what they have to make accessible.
Businesses open to the public: ADA Title III, plus state laws such as Unruh in California. WCAG is the DOJ's reference. Applies now.
State and local governments serving 50,000+ people, including public universities: ADA Title II web rule, WCAG 2.1 AA, by 26 April 2027.
Smaller governments and special districts: ADA Title II web rule, WCAG 2.1 AA, by 26 April 2028.
What non-compliance has cost
The cost usually comes in three parts: money paid to the people affected or as a penalty, the other side's legal fees, and years of required fixes and reporting. Here's what that looked like in cases involving online learning and other websites.
Harvard, 2019. Online videos without captions. More than $1.5m in the plaintiffs' legal fees, and a commitment to caption all new content, and old content within 5 business days of a request.
MIT, 2020. Online videos without captions. More than $1m in legal fees, and captions on its online content.
An exam-prep company, 2019. Online course videos without captions. $40,000 to four deaf learners and a $10,000 civil penalty.
Teachers Test Prep, 2018. Online video courses without captions. $5,000 to the complainant, and captions on its courses.
Miami University, 2016. Websites, course materials and its LMS. $25,000 to students, and its LMS and web content brought to WCAG 2.0 AA.
Louisiana Tech University, 2013. An online learning product. $23,543 to the student, and course content brought to WCAG 2.0 AA.
edX, 2015. Its course platform and website. WCAG 2.0 AA within 18 months, an accessibility coordinator and outside audits for 4 years.
H&R Block, 2014. Website, online tax tool and apps. $45,000 in damages, a $55,000 civil penalty and 5 years of audits.
Netflix, 2012. Streaming video without captions. $755,000 in legal fees and costs.
Target, 2008. Its online store. A $6m damages fund for the class, plus 3 years of monitoring.
Some of the cost never shows up as a number. After the Department of Justice found that UC Berkeley's free online lectures weren't accessible, Berkeley took more than 20,000 videos out of public view rather than fix them all (Inside Higher Ed). Five years later it still signed a consent decree to make its online content meet WCAG (US Department of Justice).
The DOJ can also seek a civil penalty of up to $118,225 for a first violation of the ADA's rules for businesses, and $236,451 for a later one (Federal Register).
The legal fees are usually bigger than the fix
In the first website case to go to trial under the ADA, Winn-Dixie was ordered to make its site meet WCAG 2.0 AA and to pay $105,271 in the plaintiff's fees and costs. An expert had estimated the fix at under $37,000 (Legal Newsline). An appeals court later vacated the judgment, but only after years of litigation (Justia).
It's the same in other cases. In the Netflix captioning case nobody was paid damages, but the fees and costs came to $755,000. Robles v. Domino's went to the Supreme Court, which declined to hear it, and the case settled in 2022, six years after it started (JD Supra). I'd guess most never get that far. Many settle early, and as one firm that defends them puts it, the plaintiff's fees "can quickly eclipse the cost of actually making the compliant modifications" (Kubicki Draper).
So the cheapest version of this, by a long way, is finding and fixing the problems before anyone writes to you.
Why an LMS has more to check than a brochure site
The letter above was about a WordPress marketing site. A learning platform has that, plus everything a learner does after they log in: the course player, videos, quizzes and timed exams, downloadable PDFs, certificates and checkout, and things like that. Each of those has to work with a keyboard and a screen reader, and video needs captions.
PDFs are the one I'd look at first. One commenter, who runs the website of a large state organisation, said an independent auditor found they mostly passed but had around 5,000 scanned PDFs that weren't accessible. Those PDFs belonged to lots of different departments, so fixing them took several rounds of training. Learning platforms often carry a lot of PDFs too. For one aviation client, every practical assessment came with a PDF checklist until we moved the checklists into the course itself.
It also matters who you sell to. On our sales calls, accessibility came up with 8% of larger organisations and none of the smaller ones. Among clients who went on to scope a build with us, it was 24%. When a university or health system asks for an accessibility report during procurement, the answer depends on the platform. A missing report can hold up the renewal or the contract while it's sorted out.
Another commenter, who said they'd dealt with these letters at an agency many times, said the firms sending them often just run an automated scan of the site first. If that's right, the problems a free scanner can find are the ones to fix first.
What we check in an accessibility health check
If a letter like this arrived tomorrow, I think the most useful thing you could have is a recent, written record of where your platform stands and what you're fixing. That's what our health check gives you, whichever LMS you're on.
Designers and developers review the platform together. For accessibility, we test the pages learners use most against WCAG 2.1 AA, with automated tools and a screen reader, on desktop and on a phone. In the same review we look at security and data, reporting, integrations and performance, because a customer's procurement team usually asks about all of them at once.
You get a fix list ordered by impact and effort, with a cost for each item, written so your own developers, a freelancer or our team can act on it. The accessibility and security notes can go straight into a customer's vendor questionnaire. It takes a few days of our time, and you keep everything we find.
If we already build or run your platform, I'd suggest doing this before your next renewal or procurement round rather than after a letter. If you're on another platform, it works the same way.
Want to know where your LMS stands? Book a health check.
If a letter does arrive
The advice in the Reddit thread that I'd agree with: speak to a lawyer before you reply, don't ignore it, and start fixing what you can straight away. Keep a record of what you found and what you fixed, and when. One commenter also suggested publishing an accessibility statement that says how people can report a problem, which I think is sensible whether or not you get a letter.
FAQ
What is ADA website compliance?
It means disabled people can use your website, including its content, forms and checkout, on equal terms. The DOJ says the ADA applies to goods and services businesses offer on the web, and points to WCAG as guidance (ADA.gov).
How much does an ADA website lawsuit cost?
It varies widely. Settlements involving online courses have ranged from $5,000 paid to one learner to more than $1.5 million in the plaintiffs' legal fees, and most also require years of fixes and audits. In California, the Unruh Act adds a minimum of $4,000 per violation.
Does the ADA apply to online courses and learning platforms?
If you sell training to the public, your LMS is part of how you offer that service, so the same DOJ position applies. Public universities and state agencies must also meet WCAG 2.1 AA under the Title II rule, including content from vendors (ADA.gov).
What should I do if I get an ADA demand letter?
Speak to a lawyer before you reply, and start fixing the accessibility problems straight away. Keep a dated record of what you found and fixed.
When is the ADA Title II web accessibility deadline?
26 April 2027 for state and local governments serving 50,000 people or more, and 26 April 2028 for smaller ones and special districts. The DOJ moved both dates back a year in April 2026 (ADA.gov).

Kaine Shutler is the founder and managing director of Plume, a UK-based agency specialising in custom learning technology. With 14 years of experience, Kaine has established expertise in Learning Management Systems, UI/UX design, and scalability, working with clients including Google and training businesses across multiple sectors.
Harvard Paid $1.5m in Legal Fees Over Captions: The Real Cost of an Inaccessible LMS

Words by
Kaine Shutler

TL;DR
Key takeaways
Under the ADA (Americans with Disabilities Act), the US Department of Justice says businesses open to the public must make the goods and services they offer online accessible to disabled people.
Inaccessible online learning has cost organisations from $5,000 paid to one learner (Teachers Test Prep) to more than $1.5 million in legal fees (Harvard), plus years of required fixes and audits.
Public universities, community colleges and state agencies must meet WCAG (Web Content Accessibility Guidelines) 2.1 AA from April 2027 or 2028, including content their vendors provide.
When Harvard settled a lawsuit over uncaptioned online videos in 2019, it agreed to caption what it posts from then on and to pay the other side's lawyers more than $1.5 million (The Harvard Crimson). A university in Louisiana paid a blind student $23,543 after an online course tool didn't work with their screen reader (US Department of Justice). An exam-prep company paid $50,000 because its online course videos had no captions (US Attorney's Office).
The same law reaches small businesses too, usually by letter. On 28 October, a law firm wrote to a small business owner about their website. A visually impaired client of the firm had tried to use the site with a screen reader and couldn't use many of its features. The letter cited the ADA (Americans with Disabilities Act) and California's Unruh Civil Rights Act, asked to discuss "having someone fix the website and the settlement of his claims", and gave a deadline of 11 November. That's two weeks.
The owner posted it on r/WordPress with one line: "Little freaked out about this tbh." It drew 186 comments.

Under the Unruh Act alone, a business found to have discriminated owes at least $4,000 per violation, plus the other side's legal fees (California Civil Code § 52). I think it's worth knowing what this has cost other organisations, because a learning platform has a lot more to get right than most websites. I'm not a lawyer, so treat this as a starting point for a conversation with one.
What ADA website compliance means
A lot of the replies said letters like this are a scam and can be ignored. Some of them probably are sent in bulk. But the legal basis is real, and the numbers are going up.
The US Department of Justice (DOJ) says the ADA requires businesses open to the public to give disabled people equal access to their goods and services, and that this applies to "those offered on the web" (ADA.gov). There's no detailed federal regulation for private businesses. Instead, the DOJ points to existing standards, including the Web Content Accessibility Guidelines (WCAG), as guidance.
Courts don't all read it the same way. California's courts have held that a business that only operates online isn't covered by the ADA, which may be why letters like this one also cite the Unruh Act. Even so, federal website accessibility lawsuits went from 2,452 in 2024 to 3,117 in 2025, and those figures don't include state-court cases or demand letters (Seyfarth Shaw, via Mondaq).
There's a second deadline that matters more for training providers. State and local governments, including public universities and community colleges, have to meet WCAG 2.1 AA on their websites and apps by 26 April 2027, or 26 April 2028 for smaller ones (ADA.gov). The rule also covers content provided through vendors. So if you sell training to a public university or a state agency, your LMS (learning management system) is probably part of what they have to make accessible.
Businesses open to the public: ADA Title III, plus state laws such as Unruh in California. WCAG is the DOJ's reference. Applies now.
State and local governments serving 50,000+ people, including public universities: ADA Title II web rule, WCAG 2.1 AA, by 26 April 2027.
Smaller governments and special districts: ADA Title II web rule, WCAG 2.1 AA, by 26 April 2028.
What non-compliance has cost
The cost usually comes in three parts: money paid to the people affected or as a penalty, the other side's legal fees, and years of required fixes and reporting. Here's what that looked like in cases involving online learning and other websites.
Harvard, 2019. Online videos without captions. More than $1.5m in the plaintiffs' legal fees, and a commitment to caption all new content, and old content within 5 business days of a request.
MIT, 2020. Online videos without captions. More than $1m in legal fees, and captions on its online content.
An exam-prep company, 2019. Online course videos without captions. $40,000 to four deaf learners and a $10,000 civil penalty.
Teachers Test Prep, 2018. Online video courses without captions. $5,000 to the complainant, and captions on its courses.
Miami University, 2016. Websites, course materials and its LMS. $25,000 to students, and its LMS and web content brought to WCAG 2.0 AA.
Louisiana Tech University, 2013. An online learning product. $23,543 to the student, and course content brought to WCAG 2.0 AA.
edX, 2015. Its course platform and website. WCAG 2.0 AA within 18 months, an accessibility coordinator and outside audits for 4 years.
H&R Block, 2014. Website, online tax tool and apps. $45,000 in damages, a $55,000 civil penalty and 5 years of audits.
Netflix, 2012. Streaming video without captions. $755,000 in legal fees and costs.
Target, 2008. Its online store. A $6m damages fund for the class, plus 3 years of monitoring.
Some of the cost never shows up as a number. After the Department of Justice found that UC Berkeley's free online lectures weren't accessible, Berkeley took more than 20,000 videos out of public view rather than fix them all (Inside Higher Ed). Five years later it still signed a consent decree to make its online content meet WCAG (US Department of Justice).
The DOJ can also seek a civil penalty of up to $118,225 for a first violation of the ADA's rules for businesses, and $236,451 for a later one (Federal Register).
The legal fees are usually bigger than the fix
In the first website case to go to trial under the ADA, Winn-Dixie was ordered to make its site meet WCAG 2.0 AA and to pay $105,271 in the plaintiff's fees and costs. An expert had estimated the fix at under $37,000 (Legal Newsline). An appeals court later vacated the judgment, but only after years of litigation (Justia).
It's the same in other cases. In the Netflix captioning case nobody was paid damages, but the fees and costs came to $755,000. Robles v. Domino's went to the Supreme Court, which declined to hear it, and the case settled in 2022, six years after it started (JD Supra). I'd guess most never get that far. Many settle early, and as one firm that defends them puts it, the plaintiff's fees "can quickly eclipse the cost of actually making the compliant modifications" (Kubicki Draper).
So the cheapest version of this, by a long way, is finding and fixing the problems before anyone writes to you.
Why an LMS has more to check than a brochure site
The letter above was about a WordPress marketing site. A learning platform has that, plus everything a learner does after they log in: the course player, videos, quizzes and timed exams, downloadable PDFs, certificates and checkout, and things like that. Each of those has to work with a keyboard and a screen reader, and video needs captions.
PDFs are the one I'd look at first. One commenter, who runs the website of a large state organisation, said an independent auditor found they mostly passed but had around 5,000 scanned PDFs that weren't accessible. Those PDFs belonged to lots of different departments, so fixing them took several rounds of training. Learning platforms often carry a lot of PDFs too. For one aviation client, every practical assessment came with a PDF checklist until we moved the checklists into the course itself.
It also matters who you sell to. On our sales calls, accessibility came up with 8% of larger organisations and none of the smaller ones. Among clients who went on to scope a build with us, it was 24%. When a university or health system asks for an accessibility report during procurement, the answer depends on the platform. A missing report can hold up the renewal or the contract while it's sorted out.
Another commenter, who said they'd dealt with these letters at an agency many times, said the firms sending them often just run an automated scan of the site first. If that's right, the problems a free scanner can find are the ones to fix first.
What we check in an accessibility health check
If a letter like this arrived tomorrow, I think the most useful thing you could have is a recent, written record of where your platform stands and what you're fixing. That's what our health check gives you, whichever LMS you're on.
Designers and developers review the platform together. For accessibility, we test the pages learners use most against WCAG 2.1 AA, with automated tools and a screen reader, on desktop and on a phone. In the same review we look at security and data, reporting, integrations and performance, because a customer's procurement team usually asks about all of them at once.
You get a fix list ordered by impact and effort, with a cost for each item, written so your own developers, a freelancer or our team can act on it. The accessibility and security notes can go straight into a customer's vendor questionnaire. It takes a few days of our time, and you keep everything we find.
If we already build or run your platform, I'd suggest doing this before your next renewal or procurement round rather than after a letter. If you're on another platform, it works the same way.
Want to know where your LMS stands? Book a health check.
If a letter does arrive
The advice in the Reddit thread that I'd agree with: speak to a lawyer before you reply, don't ignore it, and start fixing what you can straight away. Keep a record of what you found and what you fixed, and when. One commenter also suggested publishing an accessibility statement that says how people can report a problem, which I think is sensible whether or not you get a letter.
FAQ
What is ADA website compliance?
It means disabled people can use your website, including its content, forms and checkout, on equal terms. The DOJ says the ADA applies to goods and services businesses offer on the web, and points to WCAG as guidance (ADA.gov).
How much does an ADA website lawsuit cost?
It varies widely. Settlements involving online courses have ranged from $5,000 paid to one learner to more than $1.5 million in the plaintiffs' legal fees, and most also require years of fixes and audits. In California, the Unruh Act adds a minimum of $4,000 per violation.
Does the ADA apply to online courses and learning platforms?
If you sell training to the public, your LMS is part of how you offer that service, so the same DOJ position applies. Public universities and state agencies must also meet WCAG 2.1 AA under the Title II rule, including content from vendors (ADA.gov).
What should I do if I get an ADA demand letter?
Speak to a lawyer before you reply, and start fixing the accessibility problems straight away. Keep a dated record of what you found and fixed.
When is the ADA Title II web accessibility deadline?
26 April 2027 for state and local governments serving 50,000 people or more, and 26 April 2028 for smaller ones and special districts. The DOJ moved both dates back a year in April 2026 (ADA.gov).

Kaine Shutler is the founder and managing director of Plume, a UK-based agency specialising in custom learning technology. With 14 years of experience, Kaine has established expertise in Learning Management Systems, UI/UX design, and scalability, working with clients including Google and training businesses across multiple sectors.
Plan your next learning platform with our founder
About Plume
As the leading custom learning platform provider serving training businesses in the US and Europe, we help businesses design, build and grow pioneering learning tech that unlocks limitless growth potential.

Plan your next learning platform with our founder
About Plume
As the leading custom learning platform provider serving training businesses in the US and Europe, we help businesses design, build and grow pioneering learning tech that unlocks limitless growth potential.

Plan your next learning platform with our founder
About Plume
As the leading custom learning platform provider serving training businesses in the US and Europe, we help businesses design, build and grow pioneering learning tech that unlocks limitless growth potential.



