Under the Department of Justice’s rule for Title II of the ADA, state and local governments with a population of 50,000 or more must make their web content and mobile apps meet WCAG 2.1 Level AA by April 26, 2027, and smaller entities and special district governments by April 26, 2028. Those dates come from an interim final rule published April 20, 2026, which moved each deadline back one year from April 24, 2026 and April 26, 2027 in the 2024 rule. A parallel HHS rule under Section 504 gives recipients of HHS funding until May 11, 2027 with 15 or more employees, or May 10, 2028 with fewer.
Key Takeaway
The standard is WCAG 2.1 AA, the dates are April 26, 2027 and April 26, 2028, and the rule covers content a vendor provides on a government’s behalf. If you sell software to a city, a county, a public university or a transit agency, their deadline is the date your product’s conformance report starts being asked for.
Who the Rule Covers
Title II applies to state and local government entities: states, cities, counties, public schools and universities, courts, police and fire departments, transit agencies, libraries, and special districts such as water or park authorities. The rule covers the web content and mobile apps those entities provide or make available, including content they provide through contractual, licensing or other arrangements. That last clause is the one that reaches a vendor: a portal, a payment system or a learning platform run by a company on a city’s behalf is the city’s content under the rule.
The Dates, and What Changed in April 2026
| Entity | Date in the 2024 Rule | Date Now |
|---|---|---|
| Population of 50,000 or more | April 24, 2026 | April 26, 2027 |
| Population under 50,000, or any special district government | April 26, 2027 | April 26, 2028 |
The Department published the final rule on April 24, 2024 and the interim final rule extending it on April 20, 2026. Both are on ada.gov’s page for the rule, which is the source for every date on this page, and the extension itself is in the Federal Register. Population comes from the 2020 Census for most governments. A city or county school district uses its city’s or county’s population, a smaller unit such as a city library or police department uses the population of the government it belongs to, and a special district uses the later date regardless of size. An interim final rule takes effect without a proposal stage: this one was effective on publication, took public comment until June 22, 2026, and can still be revised, so verify against ada.gov before you plan around a date. This article was checked on September 6, 2026.
The Technical Standard
The rule names WCAG 2.1 Level AA, which is 50 success criteria across Level A and Level AA. It does not name WCAG 2.2, which the W3C published in October 2023 and which adds six criteria at those levels. Because 2.2 contains everything in 2.1 except one retired criterion, an audit against 2.2 AA answers a 2.1 AA requirement with margin. The differences are set out in WCAG 2.1 vs 2.2.
The Five Exceptions
The rule lists five kinds of content that do not have to meet WCAG 2.1 AA. Each has conditions, and ada.gov gives worked examples for all of them.
- Archived web content. Content created before the compliance date, or reproducing paper documents or other physical media created before it, that is kept only for reference, research or recordkeeping, sits in a clearly identified archive, and has not been changed since it was archived.
- Pre-existing conventional electronic documents. PDFs, word processing files, presentations and spreadsheets posted before the compliance date, unless they are currently used to apply for, gain access to, or participate in the entity’s services, programs or activities.
- Third-party content. Content posted by a third party that is not acting under a contract, license or other arrangement with the entity, such as a resident’s comment on a public forum.
- Individualized password-protected documents. A document about a specific person, property or account, in a conventional document format, behind a password.
- Pre-existing social media posts. Posts made before the entity’s compliance date.
Two things about the exceptions are worth saying plainly. The document exception turns on whether a file is in use, not on how old it is, so the forms and notices residents actually rely on stay in scope. And the exceptions are for the entity; a vendor whose product is the way a resident applies for something is inside the rule whatever the age of the content around it.
What the Rule Means for Vendors
Because contracted content counts as the entity’s own, public buyers pass the requirement to the companies that build and host for them. That arrives as an accessibility clause in the contract, a question on the RFP, and a request for a current conformance report. The document that answers it is an ACR on the VPAT template, ideally the INT edition, which reports WCAG, Section 508 and EN 301 549 at once. Reviewers expect Partially Supports rows with specific remarks; what stalls a deal is having nothing credible to send. If federal agencies are also among your buyers, the same evaluation under the Trusted Tester methodology covers Section 508.
What a Public Entity Can Do Now
- Inventory. Sites, subdomains, apps, vendor portals, and documents, with an owner for each.
- Sort by use. The services residents apply for and pay through come first. The archive can wait and may be excepted.
- Size the documents separately. PDF remediation is priced per page and is often the larger job; published per-page rates are collected in their own article.
- Audit the web content by template. Fifty pages built from one layout share one set of findings, which is why a template count, not a page count, sizes an audit.
- Ask vendors for their ACR now. A vendor with none in hand needs weeks to produce one, and that time is yours to spend or save.
- Publish an accessibility statement with a way for people to report barriers, and keep records of the work. Enforcement is complaint-driven, and a documented record of testing and fixes is what a good-faith response looks like.
The Parallel HHS Rule
Hospitals, clinics, health centers and other recipients of HHS financial assistance are covered by a separate rule under Section 504 with the same standard, WCAG 2.1 AA. HHS extended its dates by an interim final rule effective May 7, 2026 and published in the Federal Register on May 11: recipients with 15 or more employees have until May 11, 2027, and those with fewer than 15 until May 10, 2028. The rule text is in the Federal Register.
Harbor provides technical audits and conformance documentation, not legal advice. Which rule applies to your organization, and how, is a question for counsel.
Common Questions
- When is the ADA Title II website compliance deadline?
- April 26, 2027 for state and local governments with a population of 50,000 or more, and April 26, 2028 for entities under 50,000 and for special district governments. The Department of Justice extended both dates by one year in an interim final rule published April 20, 2026.
- Which WCAG version does the Title II rule require?
- WCAG 2.1 Level AA, which is 50 success criteria. An audit against WCAG 2.2 AA covers all of them plus six criteria added in 2.2, so testing to 2.2 answers a 2.1 requirement.
- Does the Title II rule apply to vendors and contractors?
- The obligation sits with the public entity, and it covers content the entity provides through contractual, licensing or other arrangements. In practice that reaches vendors as a request for a conformance report and for accessible deliverables, and it is increasingly written into RFPs and renewals.
- Are old PDFs covered by the Title II rule?
- Conventional electronic documents such as PDFs, word processing files, presentations and spreadsheets that were posted before the compliance date are excepted, unless they are currently used to apply for, gain access to, or participate in the entity’s services. Documents in active use are in scope.
- What is the HHS Section 504 web accessibility deadline?
- Recipients of HHS financial assistance with 15 or more employees have until May 11, 2027, and those with fewer than 15 until May 10, 2028, under an interim final rule effective May 7, 2026 (published in the Federal Register May 11) that moved each date back one year. The standard is also WCAG 2.1 Level AA.