ADA Title II Deadline: April 2027 and 2028 Dates

State and local governments in the US must make their websites and mobile apps meet WCAG 2.1 Level AA by 26 April 2027 if their population is 50,000 or more. Smaller governments and all special district governments have until 26 April 2028. Those are the dates in force on 15 October 2026: they are on ADA.gov's fact sheet for the rule, and they are in the current text of the regulation, 28 CFR 35.200, which the eCFR lists as up to date to 13 October 2026.

This guide covers what is specific to the Title II web rule: how to tell whether your government counts as large or small, what the rule exempts, what WCAG 2.1 AA asks of a typical city or county site, and a dated checklist from now to 2028. It is general information, not legal advice.

TL;DR: The DOJ web rule's compliance dates are 26 April 2027 (total population 50,000 or more) and 26 April 2028 (under 50,000, plus special district governments). Population means the Census figure for your government, not the number of people you serve or employ. Five kinds of content are exempt, including old PDFs and archived pages, but a PDF people still use to apply for something is not. HHS-funded bodies may face an earlier Section 504 date. A federal lawsuit asks a court to undo the 2026 extension, so plan to the dates and watch the case.

The Current Title II Compliance Dates

DOJ issued the web and mobile app rule on 24 April 2024 with deadlines in 2026 and 2027. An interim final rule dated 20 April 2026 moved each deadline back by one year, effective the same day (Federal Register, 91 FR 20902, 2026).

Sources: DOJ interim final rule and ADA.gov fact sheet, checked 15 October 2026.

Only the dates changed. The interim rule says "The amendments do not alter any other provisions of the 2024 final rule", so WCAG 2.1 Level AA is still the standard and the exceptions are unchanged. Its public comment period closed on 22 June 2026.

We also checked for anything newer. A search of the Federal Register on 15 October 2026 found no later DOJ document changing these dates, and ADA.gov's first steps guide gives the same two dates.

Could the dates move again?

Possibly, in either direction.

• Later, or a lighter rule. In the interim rule, DOJ says it "will consider issuing an NPRM" on the substance of the 2024 rule during the extension. It adds: "If the Department does not issue such an NPRM and if circumstances suggesting further delays of this deadline do not exist, the Department fully anticipates implementing the regulation at the new deadline" (91 FR 20902). No such proposal had appeared in the Federal Register by 15 October 2026.
• Earlier. The National Federation of the Blind sued DOJ and HHS on 21 May 2026 in the US District Court for the District of Maryland (National Federation of the Blind v. Department of Justice, No. 1:26-cv-02007, court docket). It asks the court to find the extensions unlawful and vacate them (Government Executive, 2026). The case was still open on the public docket on 15 October 2026.

If the extension were set aside, large entities could be back under a 24 April 2026 deadline that has already passed, and small ones under 26 April 2027. That is a reason to treat the current dates as the latest you can safely plan for, not the earliest.

Large or Small: Which Date Is Yours?

The rule sorts governments by "total population", defined in 28 CFR 35.104. ADA.gov's first steps guide is clear that this is not the number of people you serve, and not your number of employees. In practice:

• Your government has its own Census population: use the 2020 decennial Census figure.
• Independent school district: use the district's figure in the Census Bureau's Small Area Income and Poverty Estimates (ADA.gov points to the 2022 edition). A city school district uses the city's population and a county school district uses the county's (ADA.gov fact sheet).
• A department or agency with no population of its own: use the population of the government it belongs to. A state agency uses the state's.
• A commuter authority or other body that belongs to more than one government: add up the Census populations of those governments.
• Special district government: always 26 April 2028. That means a single-purpose government with enough administrative and fiscal independence to count as a separate government, other than a county, municipality, township or independent school district, and with no Census population of its own.

ADA.gov's worked examples make the rule concrete:

Source: ADA.gov, First Steps Toward Complying, Action Step 2.

The trap in that table is the small office inside a large government. A ten-person parks department or a neighborhood library branch inherits its parent's population, so it is on the 2027 date. ADA.gov lists mosquito abatement districts, utility districts, transit authorities, water and sewer boards and zoning districts as examples of special district governments, which get 2028. If you are unsure which you are, ADA.gov suggests calling its ADA Information Line on 800-514-0301.

Taking HHS money? Check Section 504 as well

Many public bodies also receive funding from the US Department of Health and Human Services, and HHS has its own web accessibility rule under Section 504 of the Rehabilitation Act. HHS extended its dates too, in an interim final rule effective 7 May 2026 and published on 11 May (Federal Register, 91 FR 25496, 2026). HHS sorts by employee count, not population:

Put the two rules together and a small government can face an earlier deadline than its Title II date suggests. Take a county health department or public hospital district serving fewer than 50,000 people, funded by HHS, with 15 or more staff. Its Title II date is 26 April 2028, but its Section 504 date is 11 May 2027, nearly a year earlier. Below 15 employees the order reverses, and Section 504 lands two weeks after Title II. For a government of 50,000 or more with 15 or more staff, the two dates are only 15 days apart in 2027. So if you take HHS money, check both your population and your headcount.

What the Rule Exempts

The rule lists five exceptions in 28 CFR 35.201. Each has conditions, and content that fails any condition has to meet WCAG 2.1 AA. The examples below are ADA.gov's own, from its fact sheet.

1. Archived web content. Exempt only if all four are true: it was created before your compliance date (or reproduces older paper or media), it is kept only for reference, research or recordkeeping, it is stored in a clearly labeled archive area, and it has not been changed since it was archived. A 1998 water quality report in the archive section would probably qualify. Council minutes created after your compliance date would not, even if you file them under "archive".

2. Preexisting conventional electronic documents. PDFs, word processor files, presentations and spreadsheets posted before your compliance date are exempt, unless people currently use them to apply for, access or take part in a service. A 2018 parade flyer qualifies. A 2020 business license application PDF that people still fill in does not. Edit an old document after your date and it loses the exemption.

3. Content posted by unaffiliated third parties. A resident's comment on a town message board is exempt. The message board itself is not. Nor is anything a vendor or contractor posts for you, or tools you embed from outside companies: ADA.gov names calendars, scheduling tools, maps, reservation systems and payment systems.

4. Individualized, password-protected documents. A PDF about one person, property or account, behind a login, is exempt: for example, a household's water bill in its online account. The same bill shown as an HTML page is not, and neither is a PDF about a rate increase sent to every customer.

5. Social media posts made before your compliance date. A 2017 post about trash pickup delayed by snow is exempt. New posts are not.

The rule has four more provisions that work like limits or alternatives:

• Conforming alternate versions (35.202) are allowed only where technical or legal limits make the main content impossible to fix. A separate "accessible version" of a page is not a general workaround.
• Equivalent facilitation (35.203) lets you use a different method if it gives substantially equivalent or greater accessibility.
• Fundamental alteration or undue burden (35.204) can excuse part of the work, but the head of the public entity or a designee must decide it after looking at all available resources and write down the reasons, and you must still do as much as you can short of that burden.
• Minimal impact (35.205) covers small misses that do not affect access. ADA.gov's example is park information with text at a 4.45:1 contrast ratio against the required 4.5:1. ADA.gov also says governments cannot use this provision to avoid trying to meet the standard.

None of the exceptions removes the older ADA duties. If someone needs exempt content, you still have to provide it in a form they can use, such as a captioned copy of an archived video (ADA.gov fact sheet).

What WCAG 2.1 AA Means for a City or County Site

The rule incorporates the June 2018 version of WCAG 2.1. Meeting Level AA means meeting all 30 Level A and 20 Level AA success criteria, 50 in total (W3C WCAG 2.1). Here is where they usually bite on a government site, using the features residents rely on most:

Source: WCAG 2.1, W3C Recommendation, 5 June 2018.

Three practical points follow from the rule's text.

Your vendors' platforms are your problem. The rule covers content and apps you provide "directly or through contractual, licensing, or other arrangements" (35.200). ADA.gov's example: if a city lets people pay for parking through an app run by a private company, that app must meet WCAG 2.1 AA. Payment portals, agenda management systems and permit software all count.

Mobile apps count. The same standard applies to apps you offer, not only websites.

PDFs deserve their own plan. Old documents are mostly exempt, but every new agenda, form and report you post after your date is not. Screen reader users rate PDFs badly: in WebAIM's 2026 survey, 85.6% said a PDF is likely to cause them significant problems (WebAIM Screen Reader Survey #11, 2026). Publishing in HTML in the first place avoids PDF tagging work altogether. More figures like that are in our web accessibility statistics.

Automated scanners catch some of these criteria (contrast, missing labels, missing alt text) and miss others entirely (caption quality, sensible focus order, whether an error message makes sense). Plan for both; we cover the split in automated vs manual accessibility testing. If you want headroom, building to WCAG 2.2 AA with our WCAG 2.2 checklist is a sensible target, though the rule itself names 2.1.

What the Extension Does Not Change

The new dates only govern when the technical standard becomes mandatory. DOJ's interim rule says so directly: "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 to individuals with disabilities in accordance with their existing obligations under title II of the ADA" (91 FR 20902).

DOJ enforced those general duties against public bodies long before any web rule existed:

• Louisiana Tech University, 23 July 2013. DOJ settled over an online learning product that a blind student could not use. The university agreed to make learning technology, web pages and course content conform to WCAG 2.0 Level AA and to train staff, and the student received $23,543 in damages (US Department of Justice, 2013).
• Miami University, 17 October 2016. DOJ filed a proposed consent decree requiring the university's web content and learning management systems to conform to WCAG 2.0 AA, with $25,000 to compensate individuals with disabilities (US Department of Justice, 2016).

Lawsuits against private businesses under Title III are a separate story, with their own numbers; see ADA website lawsuits.

A Dated Checklist From Now to 2028

The legal deadlines are in bold. The rest is our suggested schedule, built on the eleven action steps in ADA.gov's first steps guide. It assumes you start in October 2026.

October to December 2026: find your date and your scope

• Look up your population the way the rule defines it, and record which deadline applies. If you take HHS funding, record your employee count and Section 504 date too.
• Name one person to own compliance, and bring in procurement as well as IT and communications.
• List everything in scope: every website and subdomain, mobile app, vendor portal, embedded tool (payments, calendars, maps, booking), video channel, social account and document library.

By 31 January 2027: measure

• Run an automated scan across your main templates and highest-traffic pages.
• Test the tasks residents cannot do any other way, by keyboard and with a screen reader: paying, applying, registering, reporting a problem, watching a meeting.
• Sort documents into exempt (archived, preexisting, individualized) and not exempt, using the conditions above. Any PDF people still use to apply for a service goes on the fix list.

February to April 2027: fix what people must use

• Fix forms, payments and applications first, then templates, then content.
• Caption recorded meeting video and arrange live captions for streams.
• Move genuinely old content into a clearly labeled archive area and stop editing it there.
• At each vendor contract renewal, require WCAG 2.1 AA conformance, a current accessibility conformance report and a timeline for fixing defects.

26 April 2027: deadline for public entities with a population of 50,000 or more.

11 May 2027: Section 504 deadline for HHS funding recipients with 15 or more employees.

May 2027 to early 2028: smaller governments and special districts

• Work through the same steps, with the 2028 date as your hard stop. ADA.gov's guide also suggests training staff and writing policies (Action Steps 4 and 11); start both early.

26 April 2028: deadline for public entities under 50,000 and special district governments.

10 May 2028: Section 504 deadline for HHS funding recipients with fewer than 15 employees.

After your date: keep it fixed

• Everything new has to conform when you publish it. Add an automated check to your publishing or deployment process so regressions are caught before release; our GitHub Actions guide shows one way. Fixes for the most frequent failures are in the WCAG violations fix guide.
• Do not rely on an overlay widget: it does not change the underlying page. See why accessibility overlays fail.

Frequently Asked Questions

When is the ADA Title II web accessibility deadline?

26 April 2027 for state and local governments with a total population of 50,000 or more, and 26 April 2028 for those under 50,000 and for special district governments (ADA.gov, checked 15 October 2026). The standard is WCAG 2.1 Level AA.

Is my agency large or small under the rule?

It depends on the Census population of your government, not on how many people you serve or employ. A department inside a city or county uses that city's or county's population, a state agency or state university uses the state's, and an independent school district uses its Small Area Income and Poverty Estimates figure (ADA.gov first steps guide).

Do we have to fix old PDFs?

Usually not, if they were posted before your compliance date and nobody uses them to apply for or access a service. A PDF form still in use must conform, and so must any document you edit or post after your date (28 CFR 35.201).

Does the rule cover vendor platforms like payment portals?

Yes. It covers web content and apps a government provides "directly or through contractual, licensing, or other arrangements", and ADA.gov names payment systems, calendars, maps and reservation systems as examples that must conform.

Could the deadline change again?

It could. DOJ has said it will consider proposing changes to the rule, and the National Federation of the Blind is asking a federal court in Maryland to vacate the extension, which could put the original 2026 and 2027 dates back in place. As of 15 October 2026 neither had changed the dates.

The Bottom Line

The dates are 26 April 2027 for governments of 50,000 or more and 26 April 2028 for smaller ones and special districts, and the standard is WCAG 2.1 AA. Work out your population the way the rule defines it, check whether an HHS deadline arrives first, separate exempt content from the rest, and start with the services residents cannot get any other way.

This post is general information about a federal rule, not legal advice. For your own situation, read the rule, call the ADA Information Line or ask your counsel.

Sources (all checked on 15 October 2026)

• DOJ, Extension of Compliance Dates (interim final rule, 91 FR 20902, 20 April 2026, doc. 2026-07663): https://www.federalregister.gov/documents/2026/04/20/2026-07663/extension-of-compliance-dates-for-nondiscrimination-on-the-basis-of-disability-accessibility-of-web
• HHS, Extension of Compliance Dates (interim final rule, 91 FR 25496, published 11 May 2026, doc. 2026-09266): https://www.federalregister.gov/documents/2026/05/11/2026-09266/extension-of-compliance-dates-for-nondiscrimination-on-the-basis-of-disability-accessibility-of-web
• eCFR, 28 CFR part 35 subpart H (web and mobile accessibility), current to 13 October 2026: https://www.ecfr.gov/current/title-28/chapter-I/part-35/subpart-H
• eCFR, 28 CFR 35.104 definitions (total population, special district government, archived web content): https://www.ecfr.gov/current/title-28/chapter-I/part-35/subpart-A/section-35.104
• ADA.gov, Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps: https://www.ada.gov/resources/2024-03-08-web-rule/
• ADA.gov, State and Local Governments: First Steps Toward Complying with the Title II Web and Mobile Application Accessibility Rule: https://www.ada.gov/resources/web-rule-first-steps/
• W3C, Web Content Accessibility Guidelines 2.1, Recommendation of 5 June 2018: https://www.w3.org/TR/2018/REC-WCAG21-20180605/
• National Federation of the Blind v. Department of Justice, No. 1:26-cv-02007 (D. Md.), docket: https://www.courtlistener.com/docket/73378158/national-federation-of-the-blind-v-department-of-justice/
• Government Executive, Disability advocates sue over website accessibility delays, May 2026: https://www.govexec.com/management/2026/05/disability-advocates-sue-over-website-accessibility-delays/413785/
• US Department of Justice, Louisiana Tech University settlement, 23 July 2013: https://www.justice.gov/archives/opa/pr/justice-department-settles-louisiana-tech-university-over-inaccessible-course-materials
• US Department of Justice, Miami University consent decree, 17 October 2016: https://www.justice.gov/archives/opa/pr/miami-university-agrees-overhaul-critical-technologies-settle-disability-discrimination
• WebAIM, Screen Reader User Survey #11, 2026: https://webaim.org/projects/screenreadersurvey11/