# ADA Title II Web Accessibility Rule: Requirements and Deadlines

Source: https://accessibilityscore.in/ada-title-ii-web-accessibility
Last reviewed: 2026-10-16 by the HalfAccessible accessibility team

In 2024 the US Department of Justice set a technical standard for the websites and mobile apps of state and local governments. In April 2026 it moved the deadlines back a year. This guide sets out who is covered, what is required, the exceptions, and how to get ready.

## Short answer
The ADA Title II rule requires state and local government websites and mobile apps to meet WCAG 2.1 Level AA. After a DOJ interim final rule in April 2026, governments serving 50,000 or more people must comply by 26 April 2027, and smaller governments and special districts by 26 April 2028. Five limited exceptions apply.

## Key facts

- **Rule:** DOJ final rule under Title II of the ADA, published in the Federal Register on 24 April 2024
- **Who is covered:** State and local governments, including special district governments, and their web content and mobile apps
- **Technical standard:** WCAG 2.1 Level AA
- **Deadline, population 50,000 or more:** 26 April 2027
- **Deadline, under 50,000 and special districts:** 26 April 2028
- **Deadline change:** Extended by an interim final rule published on 20 April 2026
- **How population is measured:** Total population from US Census Bureau data; departments use the population of the government they belong to

## Who does the ADA Title II web rule apply to?

It applies to state and local governments: states, counties, cities, towns, public schools and colleges, public transit agencies, courts, libraries, police departments and special district governments such as water or fire districts.

It covers the web content and mobile apps they provide or make available, including those run for them by contractors and vendors. The DOJ's own example: if a city lets people pay for parking through a mobile app, that app must meet WCAG 2.1 Level AA even if a private company runs it.

## When do state and local governments have to comply?

The compliance date depends on the government's total population, using US Census Bureau data. A department or agency without its own population figure, such as a city library or police department, uses the population of the government it is part of.

- Total population of 50,000 or more: 26 April 2027
- Total population under 50,000: 26 April 2028
- Special district governments, whatever their size: 26 April 2028

## What are the exceptions to the Title II web rule?

Content that falls under one of five exceptions does not have to meet WCAG 2.1 AA, though the government must still provide effective communication and reasonable modifications when someone asks. The exceptions are narrow and each has conditions:

- Archived web content: created before the compliance date, kept only for reference, research or recordkeeping, kept in a special archive area, and not changed since it was archived
- Preexisting conventional electronic documents: word processing, presentation, PDF or spreadsheet files available before the compliance date, unless they are still used to apply for, access or take part in services
- Content posted by a third party who is not acting for the government under a contract, licence or other arrangement
- Individualised, password-protected documents about a specific person, property or account, such as a water bill
- Preexisting social media posts made before the compliance date

## How should a state or local government prepare?

With deadlines in 2027 and 2028, there is time to do this properly if you start now:

- Inventory your websites, mobile apps and third-party services, including payment, booking and permitting tools.
- Scan your main templates and highest-traffic pages, and fix critical and serious WCAG failures first.
- Manually test key services, such as paying a bill, applying for a permit or registering for a class, with a keyboard and a screen reader.
- Remediate or replace PDFs that people still use to apply for or access services.
- Add WCAG 2.1 AA requirements, and evidence such as an ACR, to contracts with vendors.
- Publish an accessibility statement with a way for people to report barriers.

## ADA Title II compliance dates before and after the 2026 extension

| Entity | Original date (2024 rule) | Current date (after April 2026) |
| --- | --- | --- |
| Total population 50,000 or more | 24 April 2026 | 26 April 2027 |
| Total population under 50,000 | 26 April 2027 | 26 April 2028 |
| Special district governments | 26 April 2027 | 26 April 2028 |

## Common questions

### What WCAG version does the ADA Title II rule require?
WCAG 2.1 Level AA, for both web content and mobile apps.

### What is the ADA Title II compliance deadline now?
26 April 2027 for state and local governments with a total population of 50,000 or more, and 26 April 2028 for smaller governments and all special district governments, after the April 2026 extension.

### Does the Title II rule apply to public schools and universities?
Yes. Public schools, colleges and universities are part of state or local government and are covered. School districts are not special district governments under the rule.

### Do old PDFs have to be made accessible?
Not if they were posted before the compliance date and are no longer used to apply for, access or participate in a service. PDFs people still use for services must meet WCAG 2.1 AA.

### Does the rule cover third-party apps and vendors?
Yes, when they provide the government's services, such as payment or booking tools. Content posted by members of the public who are not acting for the government is excepted.

### Does meeting WCAG 2.2 AA satisfy the rule?
WCAG 2.2 includes every WCAG 2.1 success criterion except the obsolete 4.1.1 Parsing, so content that meets 2.2 AA also meets the 2.1 AA requirements. This is not legal advice.

### Does Title II apply to private businesses?
No. Title II covers state and local governments. Businesses open to the public are covered by Title III, which has no specific web technical standard in its regulations.

## Sources

1. [US DOJ: Fact sheet on the Title II web and mobile app rule](https://www.ada.gov/resources/2024-03-08-web-rule/)
2. [Federal Register: Title II final rule (24 April 2024)](https://www.federalregister.gov/documents/2024/04/24/2024-07758/nondiscrimination-on-the-basis-of-disability-accessibility-of-web-information-and-services-of-state)
3. [Federal Register: Interim final rule extending compliance dates (20 April 2026)](https://www.federalregister.gov/documents/2026/04/20/2026-07663/extension-of-compliance-dates-for-nondiscrimination-on-the-basis-of-disability-accessibility-of-web)
4. [US DOJ: Guidance on Web Accessibility and the ADA](https://www.ada.gov/resources/web-guidance/)
5. [W3C: Web Content Accessibility Guidelines (WCAG) 2.1](https://www.w3.org/TR/WCAG21/)
6. [W3C WAI: What's New in WCAG 2.2](https://www.w3.org/WAI/standards-guidelines/wcag/new-in-22/)

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