ADA Title II Web Accessibility: What the 2027 and 2028 Deadlines Mean for Public Agencies

In April 2024 the U.S. Department of Justice issued a final rule under Title II of the Americans with Disabilities Act that set a technical standard for the websites and mobile apps of state and local governments: the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA. In April 2026 an interim final rule gave public entities an extra year to comply. The standard itself did not change.

The current compliance dates

• Public entities with a total population of 50,000 or more: April 26, 2027 (previously April 24, 2026).
• Public entities with a population under 50,000, and special district governments: April 26, 2028 (previously April 26, 2027).

The Department has said it may propose changes to the substance of the 2024 rule during the extension period, and it accepted public comment on the new dates through June 22, 2026. Agencies should watch for further rulemaking, but planning around WCAG 2.1 Level AA remains the prudent assumption.

Organizations that receive funding from the U.S. Department of Health and Human Services, including state Medicaid and human services agencies and HHS-funded colleges and universities, have a parallel requirement under Section 504 of the Rehabilitation Act. In May 2026 HHS moved its dates to May 11, 2027 for recipients with 15 or more employees and May 10, 2028 for smaller recipients, also using WCAG 2.1 Level AA.

What the extension does not change

Public entities already have a duty to communicate effectively with people with disabilities and to provide equal access to their programs and services. That obligation applies today, and residents can still file complaints about inaccessible online services. The extra year is time to do the work properly, not a reason to pause it.

What is in scope

The rule covers web content and mobile apps that a public entity provides or makes available, including content delivered through contractors and vendors. For most agencies that means:

• Public websites and online services such as permit applications, payments, job applications and benefits portals.
• Documents posted online, including PDFs, forms, agendas and reports.
• Audio and video content, which needs captions and, where relevant, audio description.
• Third-party platforms the agency uses to deliver services, such as payment, scheduling, case-management or learning systems.

The rule includes limited exceptions, for example for certain archived content and for older documents that are not used to apply for or access services. Each exception has conditions, so confirm how they apply with counsel before relying on one.

A practical plan for the next twelve months

1. Inventory. List every website, subdomain, portal, app and vendor platform, with an owner for each. Most agencies find more than they expected.
2. Prioritize by service. Start with the content people need to apply for, pay for or access a service, then high-traffic pages and documents.
3. Test against WCAG 2.1 AA. Combine automated scanning with manual testing using a keyboard and a screen reader. Automated tools find only part of the problems.
4. Fix templates first. Problems in a site's header, navigation, forms or color palette repeat on every page. Fixing the template fixes them everywhere.
5. Address documents. Decide which PDFs to remediate, convert to accessible web pages, archive or remove.
6. Hold vendors to the standard. Add WCAG 2.1 AA requirements, accessibility conformance reports and remediation timelines to contracts and renewals.
7. Build accessibility into publishing. Train content authors, add checks to the publishing workflow, and assign someone to monitor and report progress.

Document decisions and progress as you go. A clear record of what was tested, what was fixed and what remains is useful to leadership and in responding to complaints.

Where to start

Many agencies pair their internal web teams with an independent assessment to establish a baseline and verify fixes. AlphaGov provides accessibility assessments and technology assurance as part of its cybersecurity, privacy and technology assurance work.

This article is general information, not legal advice. Agencies should confirm their obligations with their own counsel.