ADA Title II web accessibility deadlines

• April 26, 2027: state and local governments with a total population of 50,000 or more.
• April 26, 2028: governments with a population under 50,000, and all special district governments.

We scanned 191 homepages across state portals, cities, counties and public universities to see how far the sector has to go: 77% had a serious accessibility failure, and cities and counties were three times as likely as state portals to carry a critical one.

The 2024 rule originally set these a year earlier, at April 24, 2026 and April 26, 2027. The Department of Justice extended them with an interim final rule published in the Federal Register on April 20, 2026.

The rule covers state and local government agencies and departments, special purpose districts, Amtrak and commuter authorities, and contractors that provide services on a government's behalf. In practice that takes in public universities and community colleges, school districts, public libraries, transit agencies, courts and utilities run by a government.

It applies to web content and to mobile apps. A county that sends residents to a payment portal or a permitting system run by a vendor is still responsible for that service being accessible, which is why procurement teams now ask vendors for an accessibility conformance report.

The technical standard is WCAG 2.1 Level AA. WCAG 2.2 is not required, but testing against 2.2 AA covers everything in 2.1 AA, and the extra criteria in 2.2, such as the 24 by 24 pixel minimum for targets, are cheap to meet at the same time. The WCAG 2.2 checklist groups the criteria by what you fix.

Each exception has conditions, and content that misses any one of them has to meet the standard.

• Archived web content. Created before the compliance date, kept only for reference, research or recordkeeping, held in a special area for archived content, and not changed since it was archived.
• Preexisting conventional electronic documents. Word processing, presentation, PDF and spreadsheet files that were on the site or app before the compliance date. The exception does not apply to a document someone currently uses to apply for, access or take part in a service, so a PDF application form still in use has to be fixed.
• Content posted by third parties. Only where the third party posts without a contract or other arrangement with the government. Content the government posts, content a contractor posts, and the tools that let the public post are all still covered.
• Individualized, password-protected documents. Documents in those same file formats, about a specific person, property or account, and secured behind a password or similar. A tax bill in a resident's account is the typical case.
• Preexisting social media posts. Posts made before the compliance date.

The wording above follows the Department of Justice's own summary. Read the rule itself before relying on an exception for anything important.

Only the dates moved. The standard is still WCAG 2.1 AA, the same entities are covered, and the exceptions and their conditions are unchanged. A government that had planned for 2026 has an extra year; one that had not started has a year less than it would have liked.

The extension also does nothing for private businesses, because Title III has no equivalent web regulation. Their exposure comes through lawsuits and demand letters, covered in the ADA website compliance guide.

A separate 2024 rule from the Department of Health and Human Services applies WCAG 2.1 AA to the websites and mobile apps of programmes that receive HHS funding under Section 504 of the Rehabilitation Act, which takes in hospitals and many state health programmes. HHS extended its dates too, with an interim final rule on May 7, 2026:

• May 11, 2027 for recipients with 15 or more employees (previously May 11, 2026).
• May 10, 2028 for recipients with fewer than 15 employees (previously May 10, 2027).

A public hospital can sit under both rules. Our scan of 99 health-system homepages shows where that sector stood in mid-2026.

• List what you publish. Sites, subdomains, apps, and every vendor-run service residents reach from them: payments, permits, booking, learning platforms.
• Ask vendors for their conformance reports now. A report that predates WCAG 2.1, or that marks every row "Supports", tells you where to push. How a VPAT should be filled out helps you read one.
• Scan your templates. Most failures repeat across every page built from the same template, so fixing the template clears them everywhere. The free scan above covers the machine-checkable part; keyboard and screen reader testing covers the rest.
• Sort your documents. Forms and documents people still use to get services need fixing. Old material nobody uses can move into an archive area that meets all four conditions.
• Keep records. Scans over time, fixes shipped and vendor correspondence show the work, whatever date applies to you.

None of this is legal advice. If you need a reading of the rule for your organisation, ask counsel.