What an ADA Demand Letter Actually Asks a Store to Fix
Demand letters follow a pattern: the standard cited, the barriers named, a deadline, and a settlement figure. Knowing the pattern takes the panic out of the first one.
The letter arrives by email or post, and the first paragraph names a law, a standard, and a deadline. Most store owners read the dollar figure first and the rest never. That is the wrong order. A demand letter is a list of specific barriers with a price attached, and the barriers are the part you can actually do something about.
These letters follow a template, and the template is worth knowing before one lands. The firm that sent it has sent the same letter to dozens of stores, and the barriers it names are usually real, even when the tone is not.
The anatomy of the letter
A typical letter names the plaintiff, cites Title III of the Americans with Disabilities Act, and states that the store's website is a place of public accommodation. It cites WCAG 2.1 or 2.2 Level AA as the standard the site allegedly fails, then lists barriers: images without alternative text, form fields without labels, a checkout a keyboard cannot complete, videos without captions, contrast below 4.5 to 1 on body text. The list is usually specific enough to reproduce.
Then comes the demand: fix the barriers, pay a settlement figure, and agree to keep the site accessible. The deadline is usually measured in weeks, not months. The letter often notes that the same plaintiff has filed against other retailers, which is meant to signal that this is a business, not a one-off complaint.
What to do in the first week
Do not ignore it, and do not agree to anything in writing before a lawyer has read it. Send it to counsel the same day, and ask for an accessibility audit of the named barriers specifically, not a general scan. A scan will find hundreds of issues; the letter names a dozen, and those dozen are the ones that matter for the negotiation.
Preserve the site as it is. Do not push a redesign that changes the pages the letter describes, because the other side will compare the live site to the version their tester used. Fix nothing until counsel advises, then fix the named barriers first and document each fix with a screenshot and a date.
Why the barriers are usually real
The firms that send these letters test with real assistive technology, and the barriers they name tend to be genuine: a keyboard trap in the mini cart, a checkout step that cannot be reached by Tab, a product image with no alternative text. Treating the letter as pure extortion misses the point. The site has real problems, and fixing them is cheaper than the next letter.
The useful response is a remediation plan with dates, not a press release. Fix the named barriers, then fix the same class of barrier everywhere else on the site, because the next tester will find the sibling pages. A store that fixes only the named URLs gets a second letter about the pages it skipped.
Related reading: Repeat Defendants: What the 2025 Filing Numbers Say About Second Lawsuits, Reading Theme Release Notes Like an Accessibility Watch List, Watching Live Chat Widgets for Keyboard Traps and Focus Loss.
Frequently asked questions
What does an ADA demand letter usually cite?
Title III of the Americans with Disabilities Act, and WCAG 2.1 or 2.2 Level AA as the standard the site allegedly fails. The letter then lists specific barriers, such as missing alternative text, unlabeled form fields, or a keyboard-inaccessible checkout, with a deadline and a settlement figure.
Should I fix the site before a lawyer reads the letter?
No. Send it to counsel the same day and preserve the site as it is, so the pages the letter describes do not change before they can be assessed. Fix the named barriers once counsel advises, and document each fix with a screenshot and a date.
Are the barriers in a demand letter usually real?
Usually, yes. The firms that send them test with real assistive technology, and the barriers they name, such as keyboard traps and unlabeled controls, tend to be genuine defects. The letter's tone and price are negotiable; the barriers mostly are not.
Does fixing only the named pages end the risk?
No. The next tester will check the sibling pages. Fix the named barriers, then fix the same class of barrier everywhere on the site, and keep a remediation log with dates so the work is demonstrable.