The ADA Title II web rule: who it covers, deadlines and what to test
Last reviewed October 26, 2026 · 11 min read
Short answer. The DOJ's Title II rule requires state and local government web content and mobile apps to meet WCAG 2.1 Level AA. After an Interim Final Rule published April 20, 2026, the compliance dates are April 26, 2027 for entities serving 50,000 or more people and April 26, 2028 for smaller entities and special district governments.
What the rule is
In April 2024 the Department of Justice published a final rule under Title II of the ADA (28 CFR Part 35, Subpart H) that sets a technical standard for the web content and mobile apps of state and local governments: WCAG 2.1 Level AA. The DOJ's fact sheet describes the rule and its deadlines.
Dates
| Entity | Compliance date |
|---|---|
| Serving a population of 50,000 or more | April 26, 2027 |
| Serving a population of 0 to 49,999 | April 26, 2028 |
| Special district governments | April 26, 2028 |
These dates reflect an extension: the DOJ published an Interim Final Rule on April 20, 2026 that extended the original compliance dates. Dates can change again, so confirm them against the DOJ page before you plan around them.
Who it covers
Title II covers state and local governments: cities, counties, school districts, public universities, transit agencies and similar entities. Private businesses fall under Title III, which has no fixed technical standard (see the ADA website compliance checklist). Businesses that build or host sites for governments, including agencies and software vendors, are often asked by their government customers to meet the same standard.
What "WCAG 2.1 Level AA" means for testing
WCAG 2.1 AA includes every Level A and AA success criterion from WCAG 2.0 plus those added in 2.1, such as reflow (1.4.10), non-text contrast (1.4.11), text spacing (1.4.12) and status messages (4.1.3). WCAG 2.2 adds further criteria such as target size (2.5.8) on top. A site that meets 2.2 AA also meets 2.1 AA, apart from one obsolete criterion: 4.1.1 Parsing, which 2.2 removed. See WCAG levels and versions explained.
What counts as a public entity
Title II covers state and local governments and the organizations they operate: cities, counties, towns, school districts, public colleges and universities, libraries, transit authorities, courts, public hospitals and special districts such as water, fire or park districts. It also reaches what these bodies offer through contractors, so a city's online payment system run by a vendor is still the city's responsibility.
Federal agencies are not covered by Title II. They follow Section 508, which has its own standard and process. If you are unsure which applies, the type of government is what decides it.
How the population thresholds work
The compliance date depends on the size of the population the entity serves. Governments serving 50,000 or more people have until April 26, 2027, and those serving fewer than 50,000 have until April 26, 2028. Special district governments also have until April 26, 2028. The DOJ fact sheet explains how population is counted for different entity types, for example that school districts use the population of their city or county, or federal poverty estimates, depending on the district type.
What the rule covers
- Web content, including pages, forms, portals, documents and videos that the entity posts or that others post for it.
- Mobile apps the entity provides.
- Content on third-party platforms the entity uses to offer its services, where the entity has chosen the platform.
- Content created by contractors and vendors on the entity's behalf.
The five exceptions
The rule excuses some content from the WCAG 2.1 AA standard. The exceptions are narrow, so check each condition before relying on one. Effective communication duties still apply, which means people can still ask for an accessible alternative.
| Exception | In plain terms | Where it stops |
|---|---|---|
| Archived web content | Old material kept only for reference, research or recordkeeping, in a clearly separate archive, and unchanged since it was archived. | Content that is edited after archiving, or information people still use today. |
| Preexisting documents | Word, PDF, presentation and spreadsheet files posted before the compliance date. | Documents updated after that date, and documents people use now to apply for, access or take part in a service. |
| Third-party content | Posts by members of the public not acting for the government, such as comments. | Anything the entity or its contractors post, and the platform itself. |
| Individualized, password-protected documents | Files about one specific person, property or account that are secured. | Documents that serve everyone, such as an HTML bill template or a general rate notice. |
| Preexisting social media posts | Posts made before the compliance date. | New posts after that date. |
Undue burden, fundamental alteration and alternate versions
The rule does not require changes that would fundamentally alter a service or impose an undue financial or administrative burden. The DOJ says those judgments depend on the entity's circumstances and can vary from year to year, and that they must be documented. The rule also strongly limits “conforming alternate versions”: an entity generally should not keep an inaccessible main page next to a separate accessible one. See sections 35.202 and 35.204 of the rule for the conditions.
Vendors, procurement and contracts
Governments buy a lot of their web content and software. Vendors that sell to them are increasingly asked for evidence of accessibility, and contract language is catching up. If you are a vendor, expect to be asked for a current accessibility conformance report, a named standard (WCAG 2.1 AA at minimum), a process for fixing reported issues and a contact person. If you are a public entity, put the standard, the testing method and the response time for fixes into the contract. See VPATs and conformance reports.
Working back from the deadline
| Stage | What to do | Typical output |
|---|---|---|
| Inventory | List every site, subdomain, portal, app, and the vendors behind them. Note who owns each. | A register with owner, vendor and last review date |
| Triage | Rank services by how many people use them and how essential they are: payments, permits, emergency notices, public meetings. | A priority list |
| Baseline testing | Scan representative pages from each template and test key flows by hand and with a screen reader. | Dated findings by criterion |
| Document exceptions | Decide which content really falls under an exception, and record why. | A short exceptions memo |
| Remediate | Fix by template and component first, then by page. Replace PDFs with accessible pages where possible. | A tracked backlog |
| Procurement | Update contracts and require conformance reports from vendors. | Contract clauses and vendor files |
| Verify and maintain | Retest, train staff who publish content, and review on a schedule. | A recheck calendar and training log |
Staff who publish content
Most new problems come from everyday publishing: a PDF uploaded without tags, an image without alt text, a video without captions. Give every content editor a short checklist and a person to ask. Training a handful of people usually prevents more issues than a one-time cleanup.
Testing mobile apps
For apps, test with the phone's built-in screen reader, with the largest text size, in both orientations and with a keyboard or switch input if you can. The same WCAG criteria apply, interpreted for native interfaces.
What this looks like for different entities
| Entity | Highest-priority content | Common trouble spots |
|---|---|---|
| City or town | Online payments, permit and license applications, public meeting agendas, emergency notices | Scanned PDFs, vendor payment portals, event calendars |
| County | Records requests, court and jail information, public health notices | Maps, data tables, third-party search tools |
| School district | Enrollment, lunch and transportation, parent portals, board meeting materials | Learning and parent platforms from vendors, videos without captions |
| Public library | Catalog, account login, events and room booking | Third-party catalog and booking widgets |
| Transit agency | Schedules, trip planning, fares and alerts, mobile app | Interactive maps, real-time feeds, native apps |
| Public college or university | Admissions, registration, course catalog, online learning | Large document libraries, many departmental sites, lecture video |
Mistakes to avoid
- Waiting for the last year. Inventory and vendor changes take longer than fixes.
- Treating the exceptions as a blanket pass. Each one has conditions, and a document people use today to access a service is not covered.
- Relying on an overlay. It does not change the underlying pages. See overlays explained.
- Testing only home pages. Forms, portals and documents are where people get stuck.
- Accepting a vendor's claim without evidence. Ask for a current conformance report and test the key flows yourself.
- Forgetting everyday publishing. New PDFs and images arrive daily; the process matters more than a one-time cleanup.
How to evaluate a vendor's accessibility claim
- Ask which standard and version the report covers, and what date and product version it describes.
- Ask who tested and how: automated tools only, or manual and assistive technology testing too.
- Read the rows for the features you will use, and test those yourself.
- Ask what they will fix and by when, and put it in the contract.
- Ask who to contact when a user reports a barrier, and how quickly they respond.
Questions staff and residents ask
Entities often find that the same questions come up when the rule is first discussed. Having plain answers ready makes the project easier to explain to leadership, vendors and the public.
- Do we have to fix old PDFs? Archived documents that are kept only for reference and that are not needed to use a service may fall under an exception, but documents residents use to apply, pay or participate do not. Read the exception wording with counsel.
- Does the rule cover social media? Content you post on a third-party platform is treated differently from content on a site you control, but the information you publish still has to reach people with disabilities when it is needed to access your services.
- What about a vendor portal? If a vendor's portal is how residents pay or apply, it is part of your service. Ask the vendor for evidence and put requirements in the contract.
- What if we cannot meet the rule for a particular item? The rule includes limited defenses, such as fundamental alteration and undue burden, with conditions. They are not a first resort and need documentation.
- How do we show progress? Keep an inventory, a dated list of tests, a remediation log and a contact route for complaints. See the accessibility statement guide.
Budgeting for the work
Costs depend on the number of pages, the age of the site and who maintains it. In general, the largest expense is not the first scan but the many small fixes across templates, documents and vendor systems. Replacing a template can fix hundreds of pages at once, so start with templates and the most-used services. For ideas on pricing manual reviews, see accessibility audit cost.
A realistic plan
- Inventory public web content and mobile apps, including PDFs, forms and third-party tools such as payment pages and meeting-scheduling widgets.
- Scan representative pages from every template and every high-traffic service.
- Test those same flows by keyboard and with zoom, then with a screen reader.
- Fix by template first, since one corrected component fixes many pages.
- Check what your vendors can show you: a current accessibility conformance report, and a process for fixing problems.
- Set a recheck schedule and keep dated records.
Clir scans a page against the automated WCAG A and AA checks and gives you the findings, evidence and fixes to work from. A manual review by an accessibility specialist is part of a sound plan for government sites.
Common questions
Does the Title II rule apply to my private business?
No. Title II covers state and local governments. Private businesses are covered by Title III, which has no specific technical standard. A business that serves government customers may still be asked to meet WCAG 2.1 AA by contract.
Which WCAG version does the rule use?
WCAG 2.1 Level AA.
Is the Title II deadline still April 2026?
No. The DOJ published an Interim Final Rule on April 20, 2026 that extended the dates. The current dates are April 26, 2027 for entities serving 50,000 or more people and April 26, 2028 for smaller entities and special district governments. Check ada.gov for any further change.
Does this rule apply to federal agencies?
No. Federal agencies are covered by Section 508. See Section 508 website requirements.
Does the rule apply to a school district or public university?
Yes, public schools and public colleges are public entities under Title II. Population for school districts is determined as the DOJ fact sheet describes.
Do old PDFs have to be fixed?
Not necessarily. Files posted before the compliance date may be excepted, but not if they are updated afterward or if people use them now to apply for or access a service. Even excepted documents may need to be provided in an accessible format on request.
Does my private business have to follow the Title II rule?
No. Private businesses fall under Title III. See the ADA website compliance checklist.
What is the ADA Title II web and mobile accessibility rule?
It is a Department of Justice rule that requires state and local governments to make their web content and mobile apps meet WCAG 2.1 Level AA, with listed exceptions, by dates that depend on the size of the population served. It was published in April 2024.
What are the Title II website accessibility requirements?
Web content and mobile apps must meet WCAG 2.1 AA unless an exception applies, such as archived content or certain preexisting documents. Entities must also handle third-party content they link to or rely on. See the plan above.
When is the ADA Title II website compliance deadline?
Entities serving 50,000 or more people have until April 2026, and smaller entities and special districts have until April 2027, under the published rule. Check the Department of Justice site for any later changes, because dates and guidance can be updated.
Does the ADA Title II rule apply to municipalities and local governments?
Yes. Cities, counties, towns, school districts, public libraries and other local governments are covered, along with state agencies and many public colleges. Population size decides which compliance date applies.
Does Title III have a website accessibility rule too?
No. Title III covers private businesses open to the public and has no website-specific regulation. Courts apply the general nondiscrimination rule case by case. See the ADA checklist.
What does the DOJ say about ADA website compliance for governments?
The Department of Justice says that web accessibility is a requirement under Title II and has published a rule and a fact sheet explaining the technical standard, the dates and the exceptions. Use the official fact sheet for the exact wording.
What is the WCAG compliance date for federal agencies?
Federal agencies are covered by Section 508, not the Title II rule, and Section 508 already points to WCAG 2.0 Level AA. See the Section 508 guide.
This guide is general information, not legal advice. Laws and deadlines change; check the linked sources and ask a qualified attorney about your own situation.
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