ADA Title II Website Accessibility Deadlines

The Justice Department's ADA Title II web rule requires state and local government websites and mobile apps to meet WCAG 2.1 Level AA. As of October 2026, the deadline is April 26, 2027 for governments with a total population of 50,000 or more, and April 26, 2028 for smaller governments and all special district governments. Both dates are still ahead: an April 2026 interim final rule moved each original date back one year.

The current compliance dates

The rule was published on April 24, 2024, at 89 FR 31320, and added a new subpart H to 28 CFR part 35. On April 20, 2026, four days before the first deadline, the Justice Department published an interim final rule (91 FR 20902) that pushed both compliance dates back one year. It took effect the day it was published. The current text of 28 CFR 35.200(b) carries the new dates, and ADA.gov's fact sheet shows them too.

No compliance date has passed yet. The old April 24, 2026 date, which many web pages still show, no longer applies.

"Total population" means your Census Bureau population from the most recent decennial Census. Independent school districts use the Census Bureau's Small Area Income and Poverty Estimates instead. A "special district government" is a public entity, other than a county, city, township or independent school district, that state law sets up to perform one function or a few, with enough fiscal and administrative independence to count as a separate government, and whose population the Census does not calculate. The definitions are in 28 CFR 35.104.

The interim final rule took comments through June 22, 2026. In it, the Department said it will consider proposing changes to the rule's substance during the extension period. As of October 3, 2026, the Federal Register shows no later amendment, proposal or stay. The Department also wrote that public entities have an ongoing duty under Title II to make their online services accessible, whatever the compliance dates say.

What the rule requires

Your agency must make sure its web content and mobile apps meet the Level A and Level AA success criteria of WCAG 2.1. The rule covers content you provide directly and content you provide "through contractual, licensing, or other arrangements." A vendor's payment page, permit portal or meeting-agenda tool counts as your content.

The rule incorporates the June 2018 version of WCAG 2.1. W3C has since published WCAG 2.2, which the rule does not name. W3C says pages that conform to WCAG 2.2 also conform to WCAG 2.1. One caveat: WCAG 2.2 dropped success criterion 4.1.1 (Parsing), so if you build to 2.2, still test 4.1.1.

The rule allows some flexibility:

• Conforming alternate versions. You may offer a separate accessible version only when making the content itself accessible is not possible because of technical or legal limits.
• Equivalent facilitation. You may use another method if it gives substantially equal or greater accessibility.
• Undue burden or fundamental alteration. You must comply unless you can show that doing so would fundamentally change a program or create undue financial and administrative burdens. Only the head of your agency, or a designee, can make that call, after considering all available resources, and the reasons must be written down. You must still provide as much access as you can.
• Minimal-impact noncompliance. A small failure that does not keep people with disabilities from getting the same information, interactions and transactions, with substantially equal timeliness, privacy, independence and ease of use, is treated as compliant. This is narrow. Do not plan around it.

The five exceptions

The rule lists five kinds of content that do not have to meet WCAG 2.1:

1. Archived web content. It must meet all four tests: created before your compliance date (or a copy of older paper or media), kept only for reference, research or recordkeeping, not changed after archiving, and stored in an area clearly labeled as an archive.
2. Preexisting conventional electronic documents. PDFs, word processing files, presentations and spreadsheets posted before your compliance date. The exception does not apply to documents people still use to apply for, gain access to or take part in a service.
3. Content posted by a third party. Public comments on a forum, for example. It does not cover a third party that posts because of a contract or other arrangement with your agency.
4. Individualized, password-protected documents. Documents about a specific person, property or account, like a utility bill, that are secured behind a login.
5. Preexisting social media posts. Posts made before your compliance date.

The pattern matters: these exceptions protect what is already there. New documents, new posts and new pages after your date must conform.

Section 504 and Section 508

Section 504 (HHS). If your agency receives financial assistance from the U.S. Department of Health and Human Services, a separate rule also applies. HHS adopted the same WCAG 2.1 AA standard on May 9, 2024 (89 FR 40066), in 45 CFR 84.84. An HHS interim final rule (91 FR 25496, May 11, 2026) moved its dates to May 11, 2027 for recipients with 15 or more employees and May 10, 2028 for recipients with fewer than 15. These dates are a few weeks off the Title II dates, so track both.

Section 508. Section 508 of the Rehabilitation Act applies to federal agencies when they develop, procure, maintain or use information technology. It does not by itself apply to cities, counties or school districts. Some states apply Section 508 standards to their own agencies by state law. See the Florida page for one example and the North Carolina page for a state whose standard points to WCAG 2.1 AA.

A plan for the months ahead

If your date is April 26, 2027, you have less than a year. ADA.gov's First Steps guide suggests this order:

1. Name who owns accessibility, and train the staff who publish content.
2. Inventory your websites, mobile apps and documents.
3. Sort out what falls under an exception and what must conform.
4. Test what must conform against WCAG 2.1 AA.
5. Fix the most-used and most important services first: payments, applications, permits, meeting agendas and emergency information.
6. Review vendor contracts, and require WCAG 2.1 AA in new ones.
7. Write an accessibility policy, and keep it current.

PDFs are often the slowest part. Each budget, agenda packet and form you post after your date has to conform, so fix the template, not just the file.

What to do next

Check your Census population to confirm your date, then run the inventory. If your site needs more than fixes, a website redesign on an accessible CMS can stop editors from publishing new problems. eRegister audits and remediates agency sites to WCAG 2.1 AA and keeps them conformant through ongoing maintenance, so tell us about your site. We are a private vendor, not a government agency, and nothing here is legal advice, so confirm your obligations with your counsel.

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