ADA Title II Web Accessibility Rule: Deadlines and What Public Entities Must Do

For years, US public entities had no specific technical standard for web accessibility under the Americans with Disabilities Act. That changed in April 2024, when the Department of Justice (DOJ) published a final rule under Title II of the ADA. It sets a clear standard, WCAG 2.1 Level AA, and compliance dates for the websites and mobile apps of state and local governments, which the DOJ extended in April 2026.

If you run a public-sector website, or you build and maintain websites for cities, counties, school districts, public universities or transit agencies, here is what you need to know.

Who the rule covers

Title II applies to state and local government entities, including:

• States, counties, cities and towns
• Public school districts, community colleges and public universities
• Public libraries, hospitals, courts and transit agencies
• Special districts such as water, park and utility districts

The rule covers the web content and mobile apps these entities provide or make available, including content created by vendors and contractors on their behalf. That makes it directly relevant to the agencies, developers and software companies that serve the public sector.

The technical standard: WCAG 2.1 AA

Covered websites and apps must meet the Web Content Accessibility Guidelines (WCAG) 2.1 at Level AA. In practice, that means content that people can perceive, operate and understand with assistive technology: text alternatives for images, captions for video, sufficient colour contrast, full keyboard access, clear form labels and error messages, and pages that work when zoomed or viewed on a phone.

Many teams aim straight for WCAG 2.2, the newest version. It includes everything in 2.1 plus a few additional criteria, so meeting 2.2 AA also meets 2.1 AA.

Compliance dates

The original rule set deadlines in 2026 and 2027. On April 20, 2026, the DOJ published an interim final rule that extended both by a year:

The extension gives teams more time, not a reason to wait. A full audit, procurement changes and remediation across websites, apps and documents can easily take a year, and the ADA’s existing duty to communicate effectively with people with disabilities applies today. Always check the DOJ’s guidance on the rule for the latest dates.

Exceptions in the rule

The rule includes limited exceptions, for example:

• Archived web content that is kept only for reference and not updated
• Pre-existing conventional electronic documents, such as older PDFs, unless they are currently used to apply for or access services
• Content posted by third parties, such as members of the public commenting
• Individualised, password-protected documents about a specific person or account
• Pre-existing social media posts published before the compliance date

These exceptions are narrow and come with conditions. If a member of the public needs an excepted document in an accessible format, the entity still has to provide it. Don’t treat them as a way to skip remediation.

A practical compliance plan

1. Inventory your digital estate. List every website, subdomain, portal, mobile app and the PDFs and forms people use to access services.
2. Run a baseline scan. An automated WCAG scan across all pages shows the size of the task and the most common issues.
3. Prioritise critical services. Fix the journeys people depend on first: paying bills, applying for permits, registering for classes, finding emergency information.
4. Test manually. Check key journeys with a keyboard and screen reader. Automated tools can’t catch everything.
5. Fix documents. Remediate or replace PDFs and forms that are still in active use.
6. Update procurement. Require vendors to meet WCAG 2.1 AA and to provide a current VPAT or Accessibility Conformance Report.
7. Publish an accessibility statement with a way for people to report barriers and request accessible formats.
8. Monitor continuously. Websites change daily. Scheduled scans and regression alerts keep you compliant after the deadline.

What this means for agencies and vendors

If you build websites or software for public-sector clients, accessibility is now a contractual expectation, not a nice-to-have. Agencies that can deliver WCAG 2.1 AA work, provide ACRs and offer ongoing monitoring are well placed to win and keep government contracts. The Reguweb partner program gives agencies white-label reports and expert backup to do exactly that.

Frequently asked questions

Does the Title II rule apply to private businesses?

No. Title II covers state and local governments. Private businesses open to the public fall under Title III, where courts commonly use WCAG 2.1 or 2.2 AA as the benchmark in website cases.

Does an accessibility overlay satisfy the rule?

No. The rule requires your content to conform to WCAG 2.1 AA. A widget can help visitors, but it doesn’t fix the underlying code. Read more in overlays vs real compliance.

What about our mobile app?

Mobile apps provided or made available by covered entities are included and must meet WCAG 2.1 AA by the same dates as websites.

Get your public-sector site ready

Reguweb scans every page against WCAG 2.1 and 2.2 AA, checks your PDFs, ranks issues by risk, and produces the reports, statements and VPATs public entities need. Our specialists can also audit and fix your site for you. Run a free scan, or talk to our team about a compliance plan well before your 2027 or 2028 deadline.