Guide for public entities
The ADA Title II web rule, in plain terms.
What the Department of Justice requires of state and local governments' websites and apps, when, and what to do first. Dates checked on ada.gov on October 18, 2026.
What the rule is
On April 24, 2024 the Department of Justice published a rule under Title II of the Americans with Disabilities Act (28 CFR Part 35, Subpart H) that sets a technical standard for the web content and mobile apps of state and local governments: the Web Content Accessibility Guidelines (WCAG) 2.1, Level A and Level AA. Before the rule, Title II already required effective communication; the rule says what “accessible” means for a website and gives each entity a date.
The deadlines, after the April 2026 extension
An interim final rule published April 20, 2026 extended the original dates by a year. The deadline now depends on the entity’s population:
| Entity | Deadline | Was |
|---|---|---|
| State and local governments with a population of 50,000 or more | April 26, 2027 | April 24, 2026 |
| Governments with a population of 0 to 49,999 | April 26, 2028 | April 26, 2027 |
| Special district governments (no Census population: transit, water, fire, library and similar districts) | April 26, 2028 | April 26, 2027 |
The population is the government’s own, from the 2020 Census. A police department, a library or an agency uses the population of the government it belongs to. School districts are counted by the city or county they serve, or by the Small Area Income and Poverty Estimates if they are independent.
Find your deadline
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2020 Census for most governments; see the basis shown with the result.
Enter the population to see the date.
Who is covered
Every state and local government entity: cities, towns, counties, state agencies, courts, public school districts, community colleges and state universities, public libraries, transit authorities and special districts. The rule covers the web content and mobile apps the entity provides or makes available, including content a contractor or vendor provides on its behalf. A third party’s own posts, where there is no contract or arrangement with the government, are not the government’s responsibility.
The five exceptions
- Archived web content, when all four conditions hold: created before the deadline (or reproducing earlier physical media), kept only for reference, research or recordkeeping, kept in a special archive area, and unchanged since it was archived.
- Preexisting conventional electronic documents: word processing, presentation, PDF and spreadsheet files available before the deadline that are not currently used to apply for or access a service.
- Content posted by a third party that is not posting under a contract, licence or other arrangement with the government.
- Individualized documents that are password-protected: files about a specific person, property or account that are secured.
- Preexisting social media posts made before the deadline.
A separate “accessible version” of an inaccessible page is allowed only where a technical or legal limitation prevents fixing the main page. For most content it is not an option.
What to do first
- Find your date with the lookup above, and put it in front of the governing body with the budget cycle in mind.
- Measure the site against WCAG 2.1 AA. An automated review of the whole site finds the bulk of the defects and tells you which templates cause them. Our free preliminary scan tests ten pages in about fifteen minutes.
- Inventory the documents. Every linked PDF, Word, PowerPoint and spreadsheet file, with a decision for each: fix, replace with a web page, archive, or retire.
- Adopt a policy and publish an accessibility statement with a working feedback route. Our statement generator produces one in a few minutes.
- Write the plan with dates, assign an accountable official, and re-review before the deadline.
The ADA Title II readiness binder does steps 2 to 5 as five documents for a board meeting: the audit, the document inventory, an adoptable policy, the statement, and a dated remediation plan.
Questions
Did the Title II web rule deadlines change in 2026?
Yes. An interim final rule published April 20, 2026 moved the deadline for governments of 50,000 or more people to April 26, 2027, and the deadline for governments under 50,000 and for special district governments to April 26, 2028. The original rule, published April 24, 2024, had set April 24, 2026 and April 26, 2027.
Which WCAG version does the rule require?
WCAG 2.1 Level AA, for web content and mobile apps that a state or local government provides or makes available, directly or through a contractor.
Does the rule apply to public schools and universities?
Yes. Public school districts, community colleges and state universities are state or local government entities under Title II. A city school district uses the city's population, a county school district the county's, and an independent school district the most recent Small Area Income and Poverty Estimates, to find its deadline.
Are PDFs covered?
Yes, with one exception: word processing, presentation, PDF and spreadsheet files that were available before the deadline and are not currently used to apply for or access a service may stay as they are. A PDF someone needs today to use a service must meet the standard.
Can we keep an inaccessible page and offer a separate accessible version?
Usually not. The rule allows a conforming alternate version only where a technical or legal limitation prevents making the main content accessible.
Sources
- ADA.gov: Fact sheet on the web and mobile app accessibility rule, which carries the April 2026 extension.
- ADA.gov: First steps toward complying with the rule.
- ADA.gov: Small entity guide to the rule, the source of the exceptions and the population basis.
- Final rule: 89 FR 31320 (April 24, 2024). Interim final rule extending the dates: 91 FR 20902 (April 20, 2026).
This guide explains a regulation; it is not legal advice. Check the rule text and your counsel before you rely on a date or an exception.
Know where you stand before the date.
A number in fifteen minutes, or the whole binder in three business days.