Digital accessibility is no longer enforced only by regulators or a small group of plaintiff firms. AI tools now make it easy for individuals to prepare and file complaints on their own, and web accessibility lawsuits are following. Cases arrive faster, with less context, and often land on teams that are already stretched.
The expectation itself has not changed. If a website has barriers that stop people from completing tasks, those barriers still matter, and courts continue to treat them as significant. What has changed is how quickly issues can be turned into legal action. Understanding how AI-generated complaints are assembled and why they are showing up more often helps teams respond with more control instead of reacting under pressure.
The New Wave of Pro Se Plaintiffs Using AI
A growing share of accessibility cases are now filed by individuals representing themselves. In legal terms, these filers are pro se plaintiffs. Pro se litigation has existed for a long time, but its role in Americans with Disabilities Act (ADA), enforcement has expanded quickly.
In 2025, federal data shows a sharp rise in pro se ADA Title III filings, increasing about 40% over 2024 according to Seyfarth Shaw. This democratization of litigation means that anyone with access to a large language model and basic tools can generate a legally sufficient complaint, lowering the cost of entry that once required retaining an attorney.
For organizations, the enforcement landscape looks different from what it did a few years ago. Complaints now come from a larger mix of people and can appear in higher volume. Some raise legitimate barriers. Others arrive with long lists of issues that do not reflect how the site actually behaves. Either way, they require time, money, and attention from teams that rarely have extra capacity.
How AI-Generated ADA Complaints Are Built
AI-assisted complaints tend to follow a common pattern. The details vary, but the steps are similar.
Drafting the Complaint
A plaintiff starts by describing what happened and where. That narrative becomes a prompt. The AI tool returns a complaint with legal framing, structure, and citations modeled on previous filings. AI tools like ChatGPT and similar large language models can draft these complaints in minutes, generating legal language and structured allegations automatically.
Gathering “Evidence”
Free and low-cost accessibility scanners are used to crawl key pages. They surface potential barriers related to the Web Content Accessibility Guidelines (WCAG) and compile reports and screenshots.. These tools do not detect every barrier, and they can mislabel or overstate issues, but the output looks technical and complete. Those reports are often attached as primary exhibits.
Reusing Templates
Complaints that seem effective or are shared online often become templates. Names, URLs, and dates are updated, while large sections of text stay the same. This makes it easy to file similar complaints against many organizations with only small edits.
Filing Online
Electronic court portals allow filings to be submitted from anywhere. There is no need to schedule time with counsel or navigate in-person paperwork to start a case.
Taken together, these steps compress the process. Work that once took days or weeks can now happen in hours. For a small number of individuals, this efficiency makes high-volume filing possible. That is where many business owners feel the impact: not from a single complaint, but from the sense that they can be targeted repeatedly with little warning.
Red Flags That Suggest AI Played a Major Role
Courts and defense teams are starting to recognize patterns that often suggest heavy AI involvement. These signals do not automatically invalidate a case, but they can help teams decide what to verify first.
Common signs include:
Citations That Do Not Exist
Some complaints reference cases that cannot be located in any legal database.
Misstated Holdings
The case is real, but the description of what the court decided is wrong or misleading.
Compressed Timelines
Lengthy, well-structured briefs appear very quickly, especially from non-lawyers who have limited experience with legal drafting.
Generic Lists of Barriers
The complaint lists issues that do not appear on the site, such as CAPTCHA problems when no CAPTCHA is used, or components that the interface does not rely on.
Mismatch Between Writing and Presentation
The legal documents read as if prepared by an experienced litigator, whereas the filer’s explanation in court or correspondence is far less sophisticated.
Even when these patterns are present, judges still look at the underlying question: are there real barriers that prevent people from using the site? For organizations, the practical response is to separate signal from noise. That means confirming which issues are genuine, technical but low impact, or exist only because an automated tool misread the interface. Time and budget are better spent on changes that fix real problems than on chasing every line of AI-generated text.
AI as Assistive Technology Does Not Change Legal Duties
AI is also changing assistive technology. Screen readers and related tools now use AI to generate richer image descriptions, interpret layouts, and infer relationships between elements. For some users, these improvements make certain sites more usable than they were a few years ago.
That progress does not change the legal standard. ADA enforcement focuses on whether the website or application itself is accessible. People are not required to rely on advanced or paid tools to get around avoidable barriers.
If someone using a common screen reader, keyboard navigation, or magnification tool cannot complete a task because of missing labels, incorrect semantics, or inaccessible controls, the barrier still exists. AI support tools do not erase that responsibility.
Courts are also starting to respond when AI is misused in filings. Some federal judges have sanctioned litigants for submitting materials that include fabricated cases or inaccurate citations, and in certain matters have restricted the use of AI in court filings altogether. These responses are still evolving, but they show that judges are paying attention to how AI is being applied in litigation.
From a risk perspective, it helps to treat AI-powered assistive tools as a supplement. They may help some users, but they do not replace the need for accessible design and development. They also do not insulate an organization from complaints if basic tasks remain inaccessible.
Where Web Accessibility Lawsuits Are Landing
Early data from Useablenet’s 2025 mid-year report shows more than 2,000 digital accessibility cases filed in the first half of the year, with projections approaching 5,000 by year’s end. A growing share of these web accessibility lawsuits involve AI-generated or AI-assisted complaints.
Most of these cases are not evenly spread across the web. They cluster in certain industries and patterns:
- E-commerce and transactional experiences
Close to 70% of cases involve e-commerce sites. Product discovery, cart, and checkout flows draw attention because they are easy to test and directly tied to revenue. - Mid-sized organizations
Around 64% of cases involve companies with annual revenue of less than 25 million dollars. These organizations often have lean teams and limited internal legal support. That can make them appear more likely to settle quickly, which in turn can attract more filings. - Sites using widgets and overlays
More than 20% of recent cases involve sites that installed an accessibility overlay. Complaints often point out that the overlay did not fix underlying issues in templates, components, or key flows.
For executives and product leaders, the pattern is clear. AI is amplifying enforcement in environments where business-critical experiences are not fully accessible and where teams do not have a strong, documented accessibility program in place. The risk is not only the presence of barriers, but the combination of barriers and a filing landscape that now moves faster and at greater scale.
Building an Accessibility Program That Holds Up
In this environment, the most effective response is not to plan around individual cases, but to build a program that stands up to both user expectations and legal scrutiny.
Core elements include:
Anchor on WCAG 2.1 Level AA
Courts and regulators continue to lean on this standard when they evaluate access. Using it as your baseline keeps internal expectations aligned with external review.
Use Both Automated and Manual Testing
Automated tools are useful for catching common issues early and monitoring regressions, but they do not see everything. Manual testing with screen readers, keyboard-only navigation, zoom, and voice tools gives a clearer picture of what people experience and highlights problems automation misses.
Prioritize Templates and Critical Flows
Start with navigation, search, account creation, forms, cart, and checkout. Improvements in these areas remove barriers that show up often in complaints and protect the journeys most tied to revenue and trust.
Integrate Accessibility Into Existing Workflows
Add practical checks into design reviews, code reviews, and QA. Keep them focused and repeatable so they fit into current processes. When accessibility is part of the way releases ship, it becomes harder for issues to build up unnoticed.
Document What You Are Doing
Keep records of audits, remediation work, training, vendor requirements, and standards for components and content. This documentation helps teams stay aligned and provides a concrete way to show effort if a demand letter or complaint arrives. Over time, this kind of documentation becomes one of the strongest defenses an organization can bring to the table when facing web accessibility lawsuits.
For leadership, this approach places accessibility in the same category as security and privacy: an ongoing operational responsibility. It also creates a clearer position when responding to AI-assisted complaints that blend legitimate issues with errors or overreach.
Responding When an AI-Generated Complaint Arrives
When a complaint comes in, whether clearly AI-generated or not, the first goal is to reduce confusion and avoid unnecessary escalation.
Helpful steps include:
Validate the Issues
Test the specific barriers named in the complaint. Sort them into groups: incorrect claims, technically accurate but low-impact issues, and serious barriers that block tasks. This makes remediation plans more realistic and gives legal teams better information.
Review Citations and References
Confirm that cited cases exist and that the summaries are accurate. Flag problems so counsel can address them with the court or opposing party.
Avoid Rushed Surface Fixes
Installing a new overlay or making untested changes can introduce new issues or send a signal that accessibility is being treated as a checkbox. Focus on changes that are tested, documented, and consistent with your broader standards.
Feed Lessons Back Into the Program
Use what you learn to update components, patterns, and checks. Close gaps in design systems and QA so similar issues are less likely to reappear.
Handled this way, a complaint becomes part of an ongoing process rather than a series of disconnected emergencies.
Reducing Risk in an Era of AI-Generated Web Accessibility Lawsuits
The pace and shape of accessibility enforcement are changing, and no organization is fully prepared for the speed that AI has introduced into the process. Even teams that care about accessibility and make steady improvements can feel caught off guard when a complaint arrives that was drafted quickly and filed with little warning. You are not alone in that experience. Every industry is adjusting to a landscape where expectations remain familiar, but the mechanics are new.
There is still uncertainty in how digital Title III claims will evolve, especially as AI lowers the barrier to filing. What organizations can control is how they operate. Maintain a steady accessibility practice, align with established standards, and document decisions and remediation. That combination does not eliminate risk, but it holds up far better than reactive changes made under pressure and gives you a stronger footing when facing web accessibility lawsuits driven by AI.
If you need support building that foundation, we can help.
At 216digital, we can help develop a strategy to integrate WCAG 2.1 compliance into your development roadmap on your terms. To learn more about how our experts can help you confidently create and maintain an accessible website that supports both your business goals and the needs of your users, schedule a complementary ADA Strategy Briefing today.