Your executive director forwards an email with a PDF attached and the subject line "Please advise." It is a demand letter. A law firm you have never heard of says your website is inaccessible to a client of theirs, cites the ADA, lists a handful of failures, and proposes a settlement figure. Your board meets in three weeks.
That letter is not rare. If your association is based in Missouri, something changed today that affects how that letter plays out. If it is based anywhere else, nothing changed at all, and the difference is worth understanding before somebody in your organization reads a headline and relaxes.
What the Missouri Law Actually Does
Senate Bill 907, the Act Against Abusive Website Access Litigation, was signed by the governor and takes effect today, 28 August 2026. It does not create an accessibility standard. It changes the economics of suing over one.
The mechanism is notice, then a cure window. Before filing, a plaintiff has to give written notice of the alleged website or web content access violation. That starts a ninety-day window. If the defendant receives that notice and in good faith initiates substantial steps to correct the problem inside those ninety days, the law creates a rebuttable presumption that a suit filed anyway is abusive.
Where it goes from there is what gives it force. A court can order the plaintiff and the plaintiff's attorneys to pay the defendant's fees and costs, both for defending the access suit and for prosecuting the abuse claim. On top of that, sanctions or punitive damages can run up to three times the attorney fee award. The Missouri Attorney General can bring an action on behalf of Missouri residents or intervene in one already pending. And it reaches backward: the act applies to litigation pending on today's date, not only to cases filed from here forward.
Who It Protects, and Who It Does Not
Here is the part that most coverage buries, and the part your board needs stated plainly.
The protections run to Missouri residents as defendants. If your association is headquartered in Virginia, or the District, or Maryland, this law does nothing for you. It is not a national safe harbor. It is a change to what happens in Missouri, to Missouri defendants.
More importantly, the law does not touch the underlying obligation. And even in Missouri, it changes the litigation, not the duty. The Americans with Disabilities Act is federal law. Your obligation to make your website usable by members with disabilities is exactly what it was yesterday. What Missouri has altered is the cost of bringing a certain kind of lawsuit against a certain set of defendants. A member who cannot register for your conference is no better served today than they were last week, and that is still the actual problem.
Why These Lawsuits Exist in the First Place
The volume explains the legislation. In 2016, fewer than 200 ADA website lawsuits were filed. In 2025 the figure was over 4,000, and more than half of those came from just 33 individuals. Typical settlement demands run between $5,000 and $20,000, which is the number that makes the business model work: high enough to hurt, low enough that paying is cheaper than defending.
Associations are squarely inside the target profile. That is the dynamic Missouri is aiming at, and it is a real one. It is also why the cure-window structure matters more than the fee shifting. A defendant who fixes the problem is no longer a target, which is a better outcome than a defendant who wins in court eighteen months later.
The Same Shape Is Moving Through Congress
Missouri is not alone. H.R. 7328, the Protecting Small Businesses from Predatory Website Lawsuits Act, was introduced on 3 February 2026 by Representative Sam Graves of Missouri. It uses the same architecture: notice first, then a cure period, though the federal version proposes 180 days rather than 90.
Do not build a strategy on it. It is a bill, not a law, and most bills do not become law. Plan around what is enacted, not what is introduced. But the pattern is worth noticing, because two legislatures independently reached for the same instrument, and that instrument assumes something specific about you: that when you receive notice, you are capable of executing a fix on a deadline.
The Deadlines That Actually Bind Your Association
Set Missouri aside. These are the obligations that apply to an association or nonprofit regardless of where it sits, and they have dates.
- ADA Title III, today. There is no compliance deadline because the obligation is already in force. Places of public accommodation are expected to be accessible now. This is the exposure that produces the demand letters, and it is the one Missouri addresses only for its own residents.
- ADA Title II, 26 April 2027. Public entities with a population of 50,000 or more must meet WCAG 2.1 AA by 26 April 2027, extended by a year from the original date. Smaller public entities and special district governments have until 26 April 2028. If your association contracts with or operates alongside public entities, this shapes what they will require of you.
- Section 504, 11 May 2027. Recipients of HHS financial assistance with 15 or more employees must meet WCAG 2.1 AA by 11 May 2027. This one catches a great many nonprofits who do not think of themselves as federal grantees, and we covered exactly who it applies to when the rule landed.
Notice what is missing from that list: Missouri. Those are the dates a board should be looking at. None of them moved this week, and none of them care which state you are incorporated in.
Ninety Days Is a Real Constraint. Treat It as a Plan.
The most useful thing in the Missouri law is not the legal protection. It is the number.
That is not a coincidence. Ninety days is roughly what it takes to bring a mid-sized association website to WCAG 2.1 AA if the work is scoped properly and somebody owns it. Both legislatures landed on a fixed window because a fixed window is how remediation actually gets done. Open-ended accessibility work does not finish. It becomes a standing agenda item that gets deferred every quarter until a demand letter arrives and the timeline is set by somebody else.
A scoped project with a dated finish is also the version a board will approve. "We are going to improve accessibility" is not a motion anyone can vote on. "We will reach WCAG 2.1 AA on these templates and these document types by this date, at this cost" is.
What Ninety Days of Remediation Actually Contains
If you were to run this as a defined project rather than an ongoing intention, it has a recognizable shape.
- Weeks one and two. An audit that produces a list of specific failures tied to specific templates, not a compliance score. A score tells you nothing about what to fix first.
- Weeks three through six. The failures that appear on every page: color contrast, focus states, form labels, heading structure, skip links. Template-level fixes retire the largest share of issues for the least effort.
- Weeks seven through ten. Content-level work, which is where associations get stuck. Image alt text, video captions, and the PDF library. Most associations have hundreds of PDFs and no plan for them, and this is the item that determines whether ninety days is realistic.
- Weeks eleven and twelve. Verification against WCAG 2.1 AA, keyboard and screen reader testing on the paths that matter most, which for an association means join, renew, register, and log in. Then a written record of what was done and when.
Keep the documentation either way. That last item is worth more than it looks. Under a notice-and-cure regime, evidence that you initiated substantial steps is the thing that establishes good faith. Under every other regime, it is the thing that shows a regulator, a funder, or a member that you took the obligation seriously.
An Honest Word About Whether You Need Help
If your association runs a small site, has no PDF library, does not gate content behind a login, and has a staff member comfortable with a screen reader, you can do a great deal of this yourself. Run an automated scan, fix the contrast and label issues it surfaces, test your join and renew paths by keyboard, and you will have retired most of your practical risk at no cost.
The organizations that need a partner are the ones with a member portal, an AMS integration, a decade of accumulated PDFs, and templates nobody has audited since launch. That is a project, not an afternoon, and pretending otherwise serves nobody.
Where to Start
If a demand letter is already on your desk, the clock is running and the first ninety days matter more than any other ninety days you will spend on this website. If one has not arrived, you have the enormous advantage of setting your own timeline instead of inheriting somebody else's.
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