ADA Title II · Web content and mobile apps
The dates, and where they come from
The Title II web rule sets WCAG 2.1 Level AA as the technical standard for state and local government web content and mobile apps, subject to the rule’s exceptions and other provisions. The April 2026 extension changed the dates, not that standard.
- Public entities with a total population of 50,000 or more, other than special districts
- Public entities with a total population below 50,000, and special districts of any size
What it covers. Your web pages, online forms, posted documents and videos, and mobile apps, including content a vendor provides for you. A few exceptions apply, such as some archived content and some older documents, each with conditions.
What changed. The rule was adopted in April 2024. On April 20, 2026, the Department moved both compliance dates back by one year. The technical standard did not change.
Schools and departments. School districts are not special district governments under this rule. City and county school districts use the relevant city or county population; independent school districts use the Census estimate described in DOJ guidance. A department generally uses the population of the government it belongs to. Check DOJ’s population guidance before choosing a date.
Exceptions need a content-by-content check. An old PDF is not automatically exempt: documents currently used to apply for or participate in a government service generally remain covered. An archive label alone is also not enough. Vendor-operated payment, booking and form services are not automatically exempt third-party content. The DOJ fact sheet explains the conditions.
Funded by HHS? Many health departments and hospitals receive funding from the U.S. Department of Health and Human Services. Those that do also fall under a matching Section 504 rule. Its dates are May 11, 2027 for organizations with 15 or more employees, and May 10, 2028 for those with fewer. Read the HHS extension.
Title II dates and coverage checked . These are the dates currently published by DOJ. Read the Justice Department’s fact sheet and the April 2026 extension in the Federal Register (91 FR 20902). Confirm your entity’s classification, exceptions and any additional duties with your legal adviser.