ADA Title II website rule: the 2027 and 2028 deadlines for local governments, explained

Under the ADA Title II website rule, state and local governments serving 50,000 people or more must make their websites and mobile apps meet WCAG 2.1 AA by April 26, 2027. Governments serving fewer than 50,000 people, and every special district government, have until April 26, 2028. Those dates come from an interim final rule (opens in a new tab) the Department of Justice published on April 20, 2026, which pushed the original deadlines back one year.

The dates could still move. DOJ has said it may propose changes, and a lawsuit asks a federal court to restore the original deadlines. Title II's broader duty to serve people with disabilities applies today, whatever the final date turns out to be. Below: what the rule requires, which deadline applies to you, what's exempt, what's still undecided and how to use the time. It's current as of October 7, 2026.

What is the ADA Title II website rule?

ADA Title II is the part of the Americans with Disabilities Act that covers state and local governments. The website rule, adopted in April 2024 at 28 CFR part 35, subpart H, sets a technical standard for the web content and mobile apps those governments offer. That standard is WCAG 2.1 Level AA.

For years, Title II's regulations said nothing specific about websites. DOJ's final rule of April 24, 2024 (opens in a new tab) filled that gap. It requires a public entity to make sure the web content and mobile apps it "provides or makes available, directly or through contractual, licensing, or other arrangements" are readily accessible to and usable by people with disabilities.

The rule applies to every kind of local government: towns, townships, villages, cities and counties, plus special districts such as utility, transit and mosquito abatement districts. There's no federal funding test. A government is covered because it's a government. For how Muniway approaches the standard, see our accessibility page.

When are the ADA Title II website deadlines?

The deadlines are April 26, 2027 for public entities with a total population of 50,000 or more, and April 26, 2028 for public entities under 50,000 and for all special district governments. The technical standard, WCAG 2.1 AA, is the same for both groups. Only the timing differs.

The 2024 rule first set these dates at April 24, 2026 and April 26, 2027. The April 2026 interim final rule pushed each one back a year. It changed only the two dates in section 35.200(b) (opens in a new tab) and says the amendments "do not alter any other provisions of the 2024 final rule." It took effect the day it was published.

Plenty of guidance written before April 2026 still shows the old dates. A January 2026 Michigan Municipal League update (opens in a new tab), for example, lists April 24, 2026 and April 26, 2027. If a handout or vendor page gives a 2026 deadline, it was written before the extension.

Which deadline applies, and how is population counted?

Most local governments use their population from the 2020 decennial Census. If it's 50,000 or more, the deadline is April 26, 2027. If it's under 50,000, the deadline is April 26, 2028. Special districts use the 2028 date at any size, because the Census Bureau doesn't publish populations for them.

The rule defines "total population" as the figure the Census Bureau calculated for that entity in the most recent decennial Census. The ADA.gov small entity compliance guide (opens in a new tab) says that for most governments, it's a number found in the 2020 Census data. You can look it up on data.census.gov (opens in a new tab).

Departments and agencies that belong to a larger government don't count on their own. A library or police department run by a city uses the city's population, and a county agency uses the county's, according to the ADA.gov fact sheet (opens in a new tab).

For estimated counts of how many governments in a state fall on each date, plus the state open meetings and records rules that sit alongside this one, see our local government website pages by state. Illinois, for example, has 53 townships of 50,000 or more on the 2027 date.

A special district government is one that state law authorizes to provide one function or a limited set of functions, with enough administrative and fiscal independence to count as a separate government. The guide's examples include a mosquito abatement district and a utility district. DOJ gave them the later date partly because they may have no objective population figure to use.

What does WCAG 2.1 AA mean?

WCAG 2.1 AA is a set of 50 testable requirements, called success criteria, for making web content usable by people with disabilities. It's published by the World Wide Web Consortium (W3C). Level AA means a site meets all 30 Level A criteria and all 20 Level AA criteria in the June 2018 version of WCAG 2.1 (opens in a new tab).

The criteria are grouped under four principles: content has to be perceivable, operable and understandable, and it has to work with the browsers and assistive technology people use. In practice that covers things staff deal with every week:

• Text alternatives for images, so a screen reader can describe a photo or a chart.
• Captions for prerecorded video, and captions for live audio in synchronized media, such as a streamed board meeting.
• Enough color contrast between text and background.
• Every link, button and form field reachable and usable with a keyboard alone.
• Form fields with labels, and error messages that say what went wrong.
• Pages with real headings, so people can skim them with assistive technology.
• Content that still works when zoomed or viewed on a phone.

The rule ties to the 2018 text of WCAG 2.1 specifically. Newer versions exist, but the regulation names 2.1.

What content does the ADA Title II rule cover?

The rule covers web content and mobile apps a government provides or makes available, whether staff build them or a vendor does. Web content includes pages, images, video, forms and documents such as PDFs, Word files, slide decks and spreadsheets. A payment portal or app run by a contractor is covered too.

The vendor point matters most for local governments. DOJ wrote in the 2024 rule that "provides or makes available" doesn't mean a government has to create or own the content. Its example is a parking payment app: if a city has an arrangement that lets the public pay for city parking through a private company's app, the app is covered. The fact sheet (opens in a new tab) gives a second example, a county park list built by a local web design company.

That reaches past the main website to:

• Online payment and utility billing portals.
• Permit, license and registration forms.
• Agenda and minutes portals, and meeting video.
• Documents posted after the compliance date, including agendas, minutes, budgets and ordinances.
• New social media posts made after the compliance date.
• Mobile apps for reporting problems, paying fees or getting alerts.

Documents are where most of the volume is. Every new PDF agenda, packet and notice posted after the deadline has to meet the standard. Tools like Document Center can check files when your staff upload them, and Agendas & Minutes turns PDF agendas into web pages, but the obligation stays with your government whichever tools you use.

What is exempt under the ADA Title II website rule?

Section 35.201 lists five exceptions: archived web content, preexisting conventional electronic documents, content posted by a third party, individualized password-protected documents, and preexisting social media posts. Each has conditions, and none removes the duty to give a person with a disability an accessible version when they need it.

The limits below come from the 2024 rule text (opens in a new tab) and the ADA.gov guides.

Archived web content

Content qualifies only if it meets all four conditions. It was created before the compliance date (or reproduces paper or other physical media created before then), it's kept only for reference, research or recordkeeping, it hasn't been changed since it was archived, and it sits in an area clearly labeled as an archive. Old minutes in a labeled archive section can qualify. A past budget mixed in with current documents doesn't meet the fourth condition.

Preexisting conventional electronic documents

PDFs, word processing files, presentations and spreadsheets posted before the compliance date are exempt, with an exception to the exception. If a document is still used to apply for, gain access to or take part in a service, such as a business license application, it has to meet the standard. A document updated after the compliance date loses the exception too.

Content posted by a third party

Comments from residents on a message board, for example. The exception does not cover anything posted by a contractor or vendor working for the government, content the government posts itself, or the tools and platforms the government provides.

Individualized, password-protected documents

Files about one person, property or account that sit behind a password, such as an individual water bill PDF. Web pages behind a login aren't covered by this exception, and neither are documents about many people.

Preexisting social media posts

Posts made before the compliance date. Posts made after it have to meet the standard.

What flexibility does the rule allow?

Four provisions give governments room: conforming alternate versions when direct access isn't possible, equivalent facilitation, the fundamental alteration and undue burden limits, and a narrow allowance for problems with minimal impact on access. Each is narrower than it sounds, and the government carries the burden of proof.

Conforming alternate versions (section 35.202). A separate accessible version of content is allowed "only where it is not possible to make web content directly accessible due to technical or legal limitations." The rule doesn't let a government keep an inaccessible page and post an accessible copy for convenience.

Equivalent facilitation (section 35.203). A government can use other designs or techniques if they give "substantially equivalent or greater accessibility and usability."

Fundamental alteration or undue burden (section 35.204). If meeting the standard would fundamentally change a service or impose undue financial and administrative burdens, the government only has to go as far as that limit. The decision has to be made by the head of the government or a designee, after considering all resources available for the program, with a written statement of reasons. The government still has to take other steps that give people with disabilities the benefit of the service as fully as possible.

Minimal impact on access (section 35.205). A government that doesn't fully conform will still be treated as meeting the rule if it can show the shortfall is so minor it doesn't affect a person's ability to get the same information, complete the same interactions and transactions, and use the same services, with substantially equivalent timeliness, privacy, independence and ease of use. ADA.gov's example is a contrast ratio of 4.45:1 where 4.5:1 is required. The small entity guide (opens in a new tab) is blunt about the limit: "You cannot use this part of the rule to avoid trying to meet WCAG 2.1, Level AA."

DOJ also considered, and rejected, a percentage score. In the 2024 rule it explained that even one error "could prevent an individual with a disability from submitting an application for public benefits," so passing 95% of checks isn't a measure of meeting the rule. An accessibility statement or a staffed phone line isn't a substitute either. DOJ said a statement explaining how to request accessible content doesn't meet the requirement, and that phone lines can't realistically give equal access the way an accessible site can.

Could the ADA Title II deadlines change again?

Yes. The dates in effect today are April 26, 2027 and April 26, 2028. DOJ has said it may propose changes to the rule's substance, and a lawsuit asks a court to bring back the original 2026 and 2027 dates. As of October 7, 2026, neither has produced a change.

Settled:

• The 2024 rule is in effect, with WCAG 2.1 AA as the standard.
• The April 20, 2026 interim final rule moved the deadlines to April 26, 2027 and April 26, 2028. Its comment period closed in June 2026.
• Nothing else in the rule changed: coverage, exceptions and flexibilities stayed the same.

Pending:

First, a possible DOJ proposal. In the interim final rule, DOJ said it "will consider issuing an NPRM," a notice of proposed rulemaking, on the substance of the 2024 rule. It added that if it doesn't, and nothing else calls for a delay, it "fully anticipates implementing the regulation at the new deadline." DOJ's fall 2025 regulatory agenda (opens in a new tab) lists the proposal's date as "To Be Determined." As of October 7, 2026, no such proposal had appeared in the Federal Register.

Second, a recommendation to drop the rule for small governments. On June 23, 2026, the Small Business Administration's Office of Advocacy (opens in a new tab) told DOJ it should withdraw the rule. If DOJ keeps the rule, Advocacy asked it to consider exempting governments under 10,000 people and to add safe harbors against lawsuits. That's a recommendation, not a rule. Nothing changes unless DOJ acts on it.

Third, a lawsuit. The National Federation of the Blind (NFB) sued DOJ and the Department of Health and Human Services on May 21, 2026, in federal court in Maryland (National Federation of the Blind v. Department of Justice (opens in a new tab), No. 1:26-cv-02007). It argues the agencies skipped public notice and comment without good cause and acted arbitrarily, and it asks the court to set aside the extensions. The court set a briefing schedule in June 2026. As of October 7, 2026, the court hadn't ruled. If NFB wins, the earlier dates could come back, and April 24, 2026 has already passed.

So the dates can move in either direction. Planning for the current deadline is the safer bet.

What applies now, before the deadline?

Title II's general rules apply to websites today. Governments have to give people with disabilities an equal opportunity to use their services and communicate with them as effectively as with others. Governments that receive federal funds also have Section 504 duties. DOJ has enforced these against local governments' websites for years, without a deadline.

The interim final rule says it directly: "Regardless of the compliance dates, covered entities have an ongoing obligation" to make services offered through websites and apps accessible under existing Title II rules. DOJ's 2022 web guidance (opens in a new tab) says the same thing, and points to WCAG as a way to meet that duty.

Section 504 of the Rehabilitation Act (opens in a new tab) bars disability discrimination in any program receiving federal financial assistance. For a local government, "program or activity" means all of the operations of the department or agency that receives the money. Some funding agencies have their own web rules. HHS, for one, moved its Section 504 web deadline (opens in a new tab) for recipients with 15 or more employees to May 11, 2027.

Enforcement hasn't waited for the rule. In June 2024, DOJ settled with four Texas counties (opens in a new tab), Colorado, Runnels, Smith and Upton, over election websites that people with vision or manual disabilities couldn't use. The counties agreed to make their online election content accessible, hire an independent auditor, invite reports of barriers, name a coordinator and train staff. Earlier Project Civic Access agreements with cities and counties, such as Denver's (opens in a new tab), included web accessibility terms as well.

What should local governments do before the deadline?

Use the time to find out where the site stands, fix the content people use most, and stop adding new problems. Start with the services residents complete online, then templates, then documents. Put accessibility in every vendor contract, and write down how staff will keep new content accessible after the deadline.

A practical order of work:

1. Confirm the deadline. Look up the population from the 2020 Census. Note whether the government is a special district.
2. Find out where the site stands. Run the homepage and a few key pages through an automated scan, such as our free ADA website checker. Automated checks catch only some issues, so follow up with keyboard testing and a screen reader on the pages that matter most.
3. List every service offered online. Payments, permits, applications, meeting video, alerts. Those can't rely on an exception and residents depend on them.
4. Fix the templates first. Menus, headers, footers, color contrast and form markup repeat on every page. One fix there clears hundreds of errors.
5. Sort the documents. Decide what is current, what can go in a clearly labeled archive, and what can come down. Convert forms people still fill out into accessible web forms or accessible PDFs.
6. Change how new content gets posted. Agendas, minutes, notices and social media posts published after the deadline must meet the standard. Train the staff who post them, and turn PDF-only content into web pages where it makes sense.
7. Ask every vendor. Request a current accessibility conformance report or test results, and add WCAG 2.1 AA requirements to contracts and renewals.
8. Caption meetings. Prerecorded video needs captions. Live streams of board meetings need live captions.
9. Write the policy down. Adopt a web accessibility policy, publish a way for residents to report barriers or ask for another format, and name who responds. The small entity guide (opens in a new tab) suggests describing how staff will test content on a regular schedule.
10. Keep records. Document what was tested, what was fixed, any undue burden decisions and how requests were handled.

None of these steps needs to wait for the court case or a DOJ proposal. They help residents now, whatever the final date turns out to be.