ADA Title II Website Deadline: April 2027 and April 2028 Explained | How-to Guide

The DOJ moved the ADA Title II web and app accessibility deadlines to April 26, 2027 and April 26, 2028. Who is covered, which date is yours, what WCAG 2.1 AA requires, the five exceptions, and a month-by-month plan.

State and local governments in the US now have until April 26, 2027 (if they serve 50,000 people or more) or April 26, 2028 (if they serve fewer, or are a special district) to make their websites and mobile apps meet WCAG 2.1 Level AA. Those dates come from an interim final rule the Department of Justice published on April 20, 2026, which pushed back the deadlines in its 2024 rule by a year. This page explains which date applies to you, what the rule covers and leaves out, and how to use the extra year well. It is general information, not legal advice.

The short answer

Your organisationOriginal 2024 dateDate now (2026 interim final rule)
State or local government entity with a total population of 50,000 or moreApril 24, 2026April 26, 2027
Entity with a total population under 50,000April 26, 2027April 26, 2028
Special district government (any size)April 26, 2027April 26, 2028

The 2026 rule changed the dates only. Its text says the amendments "do not alter any other provisions of the 2024 final rule", so the technical standard, the exceptions and who is covered are the same as before.

What happened, in order

  1. April 24, 2024. The DOJ published its final rule on the accessibility of web information and services of state and local government entities (89 FR 31320). It added subpart H to 28 CFR part 35 and adopted WCAG 2.1 Level AA as the technical standard for web content and mobile apps.
  2. April 20, 2026. The DOJ published an interim final rule (91 FR 20902) extending both compliance dates by about a year. It took effect on publication. The Department said it had overestimated how ready covered entities were, in staffing and technology, to comply in the original time frames.
  3. June 22, 2026. The public comment period on the new dates closed.
  4. What may come next. The interim rule says the Department "will consider" proposing changes to the rule's substance during the extension. It also says that if no such proposal is issued and nothing else suggests further delay, it fully expects to implement the rule at the new deadlines. When we checked on October 25, 2026 we found no follow-up proposal published in the Federal Register. Check again before you rely on this page.

One point the DOJ repeats: the deadlines are for the technical standard. The underlying Title II duty to make programs, services and activities accessible, including online ones, already applies and did not move.

Who is covered

Title II covers public entities. In practice that means:

The rule covers both web content and mobile apps that the entity provides or makes available. Private businesses are not covered by this rule; they fall under Title III, which we cover in ADA website compliance for small businesses.

How "total population" is worked out

For most governments it is the population of the jurisdiction, as defined in the rule (see the definition of "total population" in 28 CFR 35.104). A public school district uses the population of the city or county it belongs to, or, for an independent district, the Census Bureau's Small Area Income and Poverty Estimates. If your figure is close to 50,000, take the earlier date. Missing the later one by a year is a bigger problem than finishing early.

What WCAG 2.1 Level AA asks for, in plain terms

WCAG 2.1 is a W3C Recommendation published in June 2018. Level AA means meeting every Level A and Level AA success criterion. For a typical government site, the work clusters into a few areas:

For a full working list, use our website accessibility checklist and the longer WCAG guide. WCAG 2.2 is now the current W3C version and is backward compatible, so content that meets 2.2 AA also meets 2.1 AA.

The five exceptions, and their limits

The rule lists five kinds of content that do not have to meet WCAG 2.1 AA. Each one has conditions, and the ADA.gov fact sheet notes that even excepted content still falls under the general duties to communicate effectively and make reasonable modifications.

  1. Archived web content. Content created before the compliance date (or reproducing pre-date physical media), kept only for reference, research or recordkeeping, held in a special area marked as archived, and not changed since it was archived. All four conditions must be met. Old agendas you still link from the current meetings page are not archived.
  2. Preexisting conventional electronic documents. PDFs, word processing files, presentations and spreadsheets posted before the compliance date. The exception does not apply if people still use the document to apply for, get or take part in a service, such as an application form posted in 2019.
  3. Third-party content. Content posted by members of the public who are not acting for the government, such as comments on a forum. Content posted by your contractors, or by your own staff on a third-party platform, does not qualify.
  4. Individualized, password-protected documents. Files about a specific person, property or account, such as a water bill, that are secured. If the person who needs it asks for an accessible version, you still have to provide one.
  5. Preexisting social media posts. Posts made before the compliance date. New posts must meet the standard.

The rule also allows limited relief where conforming would cause a fundamental alteration or undue burden (decided case by case, and you must still provide access another way), and treats some noncompliance with minimal impact on access as not a violation. Neither is a plan. Plan to conform.

A plan for the time you have left

Counting from late October 2026, a large entity has about 18 months and a small one about 30. This sequence works for either; stretch the middle for the later date.

WhenWhat to doWhat you have at the end
Month 1Name one accountable owner. List every public site, subdomain, app, portal and embedded vendor tool (payments, permits, agendas, maps, job applications, library catalogue).An inventory with an owner per item
Months 2 to 3Test a sample of each template and each vendor tool with an automated scanner plus a manual keyboard and screen-reader pass. Ask every vendor for their accessibility conformance documentation and a remediation date.A defect list ranked by how many people a page serves
Months 3 to 4Decide what to retire, archive, fix or rebuild. Move true archives into a labelled archive area. Delete pages nobody needs.A smaller site and a written decision per section
Months 4 to 9Fix shared templates first (header, navigation, forms, footer), because one fix covers thousands of pages. Replace the most-used PDF forms with HTML forms.Accessible templates and top services
Months 6 to 12Train every person who publishes. Add an accessibility check to your publishing approval step. Caption meeting video going forward.New content that stops adding defects
Months 10 to 15Work through the remaining defect list. Put accessibility requirements and testing rights into every vendor renewal.Contracts that keep you compliant
Before the dateRetest, publish an accessibility statement with a working feedback route, and set a recurring audit.Evidence you can show

If you are replacing your website platform as part of this, our government website RFP template and procurement checklist put accessibility testing into the contract rather than the brochure. If you are unsure which accessibility law applies to which part of your organisation, see Section 508 vs ADA Title II vs WCAG.

Common mistakes

Where We.Inc fits, and where it does not

We.Inc runs a white-label website platform that departments can use under one government brand, with owner, admin and member roles, approval before a site is published, an audit log of organisation actions, and full code download. Sites are built with AI, so the output is a starting point: your team must test every site against WCAG 2.1 AA before publishing, and we do not claim that any site built on the platform conforms. If you want to see how departments would work in it, book a demo. More on the setup is on our website platform for government agencies page.

Sources

Last checked 2026-10-25.

This guide is general information, not legal advice. Rules and dates can change; check the Federal Register and ADA.gov, and speak to your own counsel about your situation.

Frequently asked questions

What is the ADA Title II website deadline now?

Under the DOJ interim final rule published April 20, 2026, state and local government entities with a total population of 50,000 or more must comply by April 26, 2027. Entities under 50,000 and special district governments must comply by April 26, 2028.

What were the original Title II web rule deadlines?

The 2024 final rule set April 24, 2026 for entities with 50,000 or more people and April 26, 2027 for smaller entities and special districts. The 2026 interim final rule moved each date back by about a year.

Did the 2026 extension change the technical standard?

No. The interim final rule changed only the compliance dates. The standard is still WCAG 2.1 Level AA, and the exceptions are unchanged.

Does the Title II web rule apply to vendors and contractors?

It applies to web content and mobile apps a public entity provides or makes available, including through contracts, licences or other arrangements. Content a vendor runs on your behalf counts as yours.

Are old PDFs covered?

PDFs and similar documents posted before your compliance date are excepted, unless people still use them to apply for, access or take part in a service. Documents posted after the date must meet WCAG 2.1 AA.

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