Government website accessibility

ADA Title II website accessibility deadlines

State and local governments with a total population of 50,000 or more have until April 26, 2027 to meet the rule’s WCAG 2.1 Level AA requirements. Smaller governments and special districts of any size have until April 26, 2028. Existing ADA duties still apply before these dates.

Title II guidance checked against the Justice Department’s current sources on .

Accessibility deadline check

When does your website have to meet WCAG?

For Title II, use the public entity’s total population, not website visitors or employee count. Other funding or state requirements may also apply.

Not legal advice. Talk to your attorney about your agency’s obligations.

ADA Title II

Standard
WCAG 2.1 Level AA
Source
DOJ rule, 28 CFR part 35, subpart H

The Justice Department extended this date on April 20, 2026. Existing ADA duties, including effective communication and equal access to services, still apply before the technical compliance date.

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.

Start with the services people use

A practical plan for your government website

Use these steps to organize the work, then use our full website readiness checklist to track it. A completed checklist or an automated scan does not establish WCAG conformance.

1. Name an owner and take stock

  • List websites, apps, forms, PDFs and services supplied by vendors. Record who can change each one.
  • Confirm the entity, population and applicable requirements before setting the project deadline.

2. Test complete public tasks

  • Try paying a bill, applying for a permit, finding a meeting and submitting a form with a keyboard and relevant assistive technology.
  • Combine automated checks with manual review of navigation, focus, labels, errors and instructions.

3. Review documents and exceptions

  • Prioritize documents people need for current services. Check reading order, headings, form fields and alternatives for images.
  • Record the reason for any claimed exception; moving a file into an archive is not enough.

4. Include your vendors

  • Ask for current accessibility documentation and test the actual service your residents use.
  • Agree who will fix issues and when. Use the purchasing guidance when preparing a contract.

5. Track fixes and re-test

  • Give each issue a URL, description, owner and target date. Address barriers to essential services promptly.
  • Re-test the original task after each fix and keep the results with the issue record.

6. Keep new content accessible

  • Train staff who publish pages, documents and videos, and provide a clear way for people to report access barriers.
  • Review new content and vendor updates. Accessibility work continues after the compliance date.

This plan follows the approach in DOJ’s first steps for state and local governments. The checklist supports planning; a scoped assessment must identify what was actually tested and what remains unresolved.

At a glance

Which rules apply to which government

Rules by level of government
RequirementFederalStateCounty and citySpecial district
ADA Title II web rule (WCAG 2.1 AA)—RequiredRequiredRequired
Section 508 (WCAG 2.0 AA)RequiredOften adopted by state law——
OMB M-23-22 federal website standardsRequired———
HTTPS everywhereRequired, HSTS preloadState policyBest practiceBest practice
.gov domainRequiredVariesRequired in NY; CA by 2029Available
Open-meetings agenda posting—State lawState lawState law
Web content as public recordsFederal Records ActState records lawState records lawState records law
Posted privacy policyRequiredRequired in CA, NY, othersBest practiceBest practice
Language access (Title VI)AppliesIf federally fundedIf federally fundedIf federally funded
Cloud security authorizationFedRAMPGovRAMP or TX-RAMP in some statesSecurity questionnaireSecurity questionnaire

Applies directly Depends on state law or funding

The detail

What each rule means for your website

Accessibility

  • ADA Title II: state and local government websites, apps and documents must meet WCAG 2.1 AA. A Justice Department interim rule of April 20, 2026 moved the dates to April 26, 2027 (population 50,000 or more) and April 26, 2028 (smaller entities and special districts).
  • Before the deadline: the extension does not suspend existing ADA duties, including effective communication, reasonable modifications and equal opportunity to use government services.
  • Colorado state and local governments must already comply; the grace period ended July 1, 2025.
  • Section 508 is a separate federal accessibility framework. The Title II web rule specifies WCAG 2.1 AA; satisfying a technical standard does not replace the government’s other ADA obligations.

Federal website standards

  • OMB M-23-22 requires site search, the Digital Analytics Program, HTTPS on every page and a dated privacy policy.
  • Footer links to About, FOIA, Accessibility, Vulnerability Disclosure, No FEAR Act data and Privacy.
  • No scripts, stylesheets or fonts loaded from hosts the agency does not control.
  • OMB M-26-18 (August 2026): sites with sign-in must adopt Login.gov within two years.

Open meetings and notices

  • California Brown Act: agendas posted 72 hours ahead through a prominent, direct link on the home page.
  • Texas Government Code 551.056: the online notice goes up with the physical posting.
  • New York: records for a meeting posted online 24 hours ahead, where practicable.
  • New Jersey requires legal notices on the agency’s own website from March 1, 2026. Florida has allowed website notices since 2022.

Records and .gov

  • Most state archives treat websites and social media as public records with retention schedules. Your CMS should keep and export past versions.
  • New York municipalities of 1,500 or more must run a .gov site carrying notices, agendas, minutes, local laws and budgets.
  • California local agencies must move websites and email to .gov or .ca.gov by January 1, 2029.

Language access

  • Executive Order 13166 was revoked in March 2025 and the Justice Department’s 2002 guidance was withdrawn.
  • Title VI still applies to anyone receiving federal funds, and the Department says denying language services can be evidence of discrimination.
  • State and city laws still apply, such as California’s Dymally-Alatorre Act and New York City’s Local Law 30.

Privacy and security

  • State agencies in California and New York must post a conspicuous privacy policy.
  • Advertising pixels on government sites have led to lawsuits. We do not install them.
  • GovRAMP is required for state cloud contracts in Utah, Indiana, North Carolina and Nevada. TX-RAMP covers Texas state agencies.
  • CJIS applies only when a site handles criminal justice information, not to a police department’s public pages.

The other-law summaries above were last checked in September 2026 and are starting points for your agency’s own review. The Title II dates and coverage were rechecked October 15, 2026.

Read the primary sources

Official Title II guidance

  • DOJ fact sheet

    The technical standard, current dates, coverage and exceptions.

  • DOJ compliance guide

    How to identify the public entity and population, with examples for smaller governments.

  • DOJ first steps

    A practical way to inventory content, assign responsibility and plan accessibility work.

Need a starting point? Send your website address and the public tasks that matter most. We can discuss an initial review and a practical scope for the work.

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