ADA Title II Web Accessibility Rule: 2027 and 2028 Deadlines Explained

The ADA Title II rule requires state and local governments to make their web content and mobile apps conform to WCAG 2.1 Level AA. After an extension in April 2026, the compliance date is April 26, 2027 for public entities with a total population of 50,000 or more, and April 26, 2028 for smaller public entities and all special district governments. The rule has been in force since June 24, 2024; the 2027 and 2028 dates are when full compliance is required.

Last reviewed: November 15, 2026. This article explains the law in general terms and is not legal advice.

The ADA Title II web rule at a glance
Rule	Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities (U.S. Department of Justice)
Where	28 CFR part 35, subpart H (sections 35.200 to 35.205)
Published and in force	Published April 24, 2024, effective June 24, 2024
Technical standard	WCAG 2.1, Level A and Level AA
What it covers	Web content and mobile apps that a state or local government provides or makes available, directly or through contractual, licensing or other arrangements
Deadline, population 50,000 or more	April 26, 2027
Deadline, population under 50,000 and special district governments	April 26, 2028
Enforcement	Complaints to the Department of Justice or other federal agencies, and private lawsuits

Who must comply?

The rule applies to all state and local governments, including their agencies and departments, special purpose districts, Amtrak and other commuter authorities. ADA.gov gives examples:

What about private companies and vendors?

The rule binds public entities, not private businesses. It does reach their vendors, though: the rule covers content and apps a government provides "directly or through contractual, licensing, or other arrangements." DOJ's own example is a city that lets the public pay for parking through a mobile app run by a private company under an arrangement with the city. That app is covered and must meet WCAG 2.1 Level AA. If you sell websites, software, payment, scheduling or learning platforms to public bodies, expect accessibility requirements in contracts and requests for an Accessibility Conformance Report. Our guide to Section 508 and the VPAT explains how to prepare one.

What does the rule cover?

Two things: web content and mobile apps.

Web content is defined broadly as the information and sensory experience communicated to the user by a browser or other user agent, including the code that defines its structure, presentation and interactions. The rule's examples are text, images, sounds, videos, controls, animations and conventional electronic documents.
Conventional electronic documents are PDF, word processor, presentation and spreadsheet files.
Mobile apps are software applications downloaded and designed to run on mobile devices such as smartphones and tablets.

Covered content must meet the Level A and Level AA success criteria and conformance requirements of WCAG 2.1.

What are the compliance deadlines?

ADA Title II compliance dates
Public entity	Original date (2024 rule)	Current date
Total population of 50,000 or more	April 24, 2026	April 26, 2027
Total population under 50,000	April 26, 2027	April 26, 2028
Special district government	April 26, 2027	April 26, 2028

DOJ moved the dates with an interim final rule published on April 20, 2026 (91 FR 20902), effective the same day. It explained that it had overestimated the staffing and technology capabilities of covered entities, that technology such as generative AI does not yet reliably automate the remediation of inaccessible content at scale, and that entities would otherwise face significant litigation risk. The extension changed nothing else in the 2024 rule: the standard, the scope and the exceptions are the same.

The extension does not pause the ADA itself. In DOJ's words, "regardless of the compliance dates, covered entities have an ongoing obligation to ensure that their services, programs, and activities offered using web content and mobile apps are accessible."

Can the dates change again?

They can, so do not plan on more time. Three things are open as of November 2026:

The extension is an interim final rule. The comment period closed on June 22, 2026, and DOJ has not yet published a final version.
DOJ has said it will consider proposing changes to make some of the 2024 requirements less burdensome. No proposal has been published.
The National Federation of the Blind has asked a federal court to vacate the extensions of both DOJ and HHS (National Federation of the Blind v. Department of Justice, D. Md., No. 1:26-cv-02007, filed May 21, 2026). The case is pending. If a court set the extension aside, the original dates of the 2024 rule could apply again.

How is population determined?

A public entity uses its total population as estimated by the U.S. Census Bureau in the most recent decennial Census, which today means the 2020 Census.

A city police department or a city library uses the population of the city that runs it.
Independent school districts use the Census Bureau's Small Area Income and Poverty Estimates. A city school district uses the population of the city, and a county school district that of the county.
A school district is not a special district government.
Special district governments are those whose population the Census Bureau does not calculate, such as mosquito abatement, utility, transit, water and sewer, or zoning districts. They all have until April 26, 2028.

The five exceptions

Some content does not have to conform to WCAG 2.1 Level AA. Each exception has strict conditions:

Archived web content. All four conditions must be met: the content was created before the compliance date (or reproduces older paper or physical media), it is kept only for reference, research or recordkeeping, it is not altered or updated after archiving, and it is stored in an area clearly identified as an archive. If any condition is missing, the content generally must conform.
Preexisting conventional electronic documents. PDFs and office files available before the compliance date, unless they are currently used to apply for, gain access to or participate in the entity's services, programs or activities. A form people still use to apply for a permit is not excepted, and neither is an old document that is updated later.
Content posted by a third party. For example, public comments posted by residents. The exception does not cover third parties posting under a contract, license or other arrangement with the entity, tools the entity itself provides (calendars, scheduling tools, maps, reservation and payment systems) or the platforms that let third parties post.
Individualized, password protected documents. Conventional electronic documents about a specific person, their property or account that are password protected or otherwise secured, such as a utility bill in PDF. The website and portal around them are still covered.
Preexisting social media posts. Posts published before the compliance date. Posts published after it are covered.

Even excepted content is not exempt from the ADA as a whole. ADA.gov notes that a government would likely still need to provide it in an accessible format to a person with a disability who needs it. The 2024 rule also dropped two exceptions proposed earlier: there is no exception for linked third party content or for course content.

Other provisions worth knowing

Conforming alternate versions may be used only where it is not possible to make the content itself accessible because of technical or legal limitations.
Equivalent facilitation allows other designs or methods that provide substantially equivalent or greater accessibility and usability. DOJ explains that conforming to WCAG 2.2 Level AA can satisfy the rule this way.
Fundamental alteration and undue burden. The entity must prove it. The decision must be made by the head of the entity or their designee with a written statement of reasons, and the entity must still comply as far as it can and provide the benefits by other means to the maximum extent possible.
Noncompliance with minimal impact. Section 35.205 treats an entity as compliant only if it can show that its nonconformance has such a minimal impact that people with disabilities can still access the same information, engage in the same interactions, conduct the same transactions and otherwise participate in the same services, with substantially equivalent timeliness, privacy, independence and ease of use. DOJ declined to create a separate excuse for isolated or temporary problems.

How is the rule enforced?

Anyone can file a complaint with the Department of Justice or with the federal agency responsible for the area, such as the Department of Education for schools and libraries, within 180 days of the alleged discrimination. Agencies can investigate complaints and run compliance reviews. Title II also gives individuals a private right of action: a person can sue whether or not an agency finds a violation.

The parallel rule for health and human services

The Department of Health and Human Services adopted a similar rule under Section 504 of the Rehabilitation Act (45 CFR part 84, subpart I). It applies to organizations that receive federal financial assistance from HHS, which can include private health care and social service providers, and it also requires WCAG 2.1 Level AA. An interim final rule of May 11, 2026 (91 FR 25496) moved its dates to:

Title II and Title III are different

Title III covers businesses open to the public, such as stores, restaurants and online services. DOJ has no Title III regulation with a technical web standard or deadlines: it withdrew that rulemaking in 2017. Its 2022 guidance on web accessibility is still posted on ADA.gov. It says businesses have flexibility in how they comply but must make the goods and services they provide online accessible, and it names WCAG and the Section 508 Standards as helpful technical guidance. The guidance itself is not legally binding. Some states add their own claims and damages on top of the ADA. Read more in ADA website compliance in 2026 and in our overview of state web accessibility laws.

How to prepare for the deadline

Make an inventory. List every website, subdomain and mobile app, the documents you publish and the third party tools you embed, such as payments, scheduling, maps, forms and video players.
Sort content by obligation. Decide what qualifies for an exception and set up a clearly labeled archive that meets all four conditions. Do not count on exceptions for documents people use to apply for services.
Audit. Run an automated scan across all pages to find repeated technical issues, then a manual WCAG 2.1 AA audit of your templates and key tasks, such as paying a bill, applying for a permit, registering for a class or finding meeting minutes. Test with a keyboard and screen readers. Automated tools alone cannot confirm conformance; see automated vs. manual audits.
Fix by impact. Start with barriers that block a task completely. Convert documents that are still in use to accessible HTML or remediate them.
Bring vendors in. Write WCAG 2.1 Level AA into contracts and renewals, ask for an Accessibility Conformance Report and test the vendor's tool yourself before you buy.
Train your editors. Most new problems come from everyday content: images without text alternatives, skipped headings, unclear link text, videos without captions and inaccessible PDFs.
Give people a way to ask for help. Publish how to report a barrier and request content in an accessible format, and answer quickly.
Monitor continuously. Websites change every week. Recheck after releases and content updates instead of treating the audit as a one time certificate.

FAQ

Does the ADA Title II rule apply to private businesses?

Not directly. It applies to state and local governments. Private companies are affected when they provide web content or apps to the public on a government's behalf, through a contract, license or other arrangement.

What is the deadline for a city of 30,000 people?

April 26, 2028. Cities, counties and other public entities with a total population under 50,000 have until that date; those with 50,000 or more have until April 26, 2027.

Is WCAG 2.2 required?

No. The rule requires WCAG 2.1 Level AA. Conforming to WCAG 2.2 Level AA also satisfies it through equivalent facilitation.

Do old PDFs have to be made accessible?

Not if they were available before the compliance date and are not currently used to apply for, access or participate in services. Documents people still use, and every new document, must conform.

Does an accessibility overlay make a website compliant?

The rule measures the content itself against WCAG 2.1 Level AA, and an overlay does not change most of what the criteria test. DOJ's guidance says automated checkers and overlays "need to be used carefully" and that a clean report does not necessarily mean everything is accessible. See what accessibility widgets and overlays can and cannot do.

Do we have to do anything before April 2027?

Yes. The ADA already requires governments to make their services accessible and to communicate effectively with people with disabilities. The compliance date is when the specific WCAG 2.1 Level AA requirement becomes enforceable, and with the dates under review, starting early is the safer plan.

Sources

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