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ADA Title II website compliance: a public-sector guide

What the DOJ's Title II rule requires of state and local government websites, apps and PDFs, how the five exceptions work, and where to start.

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Pavel Charkasau

ADA Title II website compliance means a state or local government's web content and mobile apps meet WCAG 2.1 Level AA, the technical standard the Department of Justice wrote into its 2024 rule (Federal Register, 89 FR 31320). That covers cities, counties, school districts, public universities, libraries, courts, transit agencies and special districts. It also covers the vendors and apps they use to deliver services. The current compliance dates are April 26, 2027 for governments with a population of 50,000 or more, and April 26, 2028 for smaller governments and all special districts (ADA.gov fact sheet).

The scope is wide: pages, online forms, PDFs and other documents, video, and apps. The rule has five exceptions, and each one is narrower than it first reads. Below is what is in scope, how the exceptions and the compliance-measurement provisions work, and a practical order for the work. If you only want the deadline news, our post on the DOJ's 2026 deadline extension covers it. If you're not sure you're a Title II entity at all, start with Title II vs Title III.

Who must comply with the ADA Title II web rule?

Any public entity under Title II of the ADA. The DOJ's fact sheet lists state and local governments and their agencies and departments, special purpose districts, Amtrak and commuter authorities (ADA.gov fact sheet). Which deadline you get depends on your total population, which generally comes from the 2020 Census. It does not depend on how many people you employ or how many use your website (ADA.gov first steps). School districts follow their city or county, or the latest Census SAIPE estimate if they're independent.

Public entityCompliance date
Total population 50,000 or moreApril 26, 2027
Total population under 50,000April 26, 2028
Any special district governmentApril 26, 2028

Federal agencies are a different regime. They answer to Section 508, not Title II.

What does the rule require, exactly?

WCAG 2.1 Level AA, for "web content" and for mobile apps the government provides or makes available. The DOJ is explicit that the standard is mandatory even though WCAG calls itself guidelines (ADA.gov first steps). Web content is defined to include text, images, sound, videos and documents (ADA.gov fact sheet).

WCAG 2.1 AA is a fixed, testable list (W3C, WCAG 2.1). A few criteria that come up constantly on government sites:

  • 1.1.1 Non-text content: the seal in the header, the map of polling locations and the chart in the budget report all need text alternatives.
  • 1.2.2 Captions (prerecorded): the recorded council meeting on your video page needs captions.
  • 1.3.1 and 4.1.2: every field on the permit form needs a programmatic label, not just grey placeholder text.
  • 2.1.1 Keyboard: the "Pay now" button on the utility portal has to work without a mouse.
  • 1.4.3 Contrast: normal text needs at least 4.5:1 against its background.

Our WCAG checklist lists every Level A and AA criterion if you want the full set as a working document.

Do PDFs, apps and vendor platforms count?

Yes, all three, and this is where most of the work hides.

Documents. PDFs, Word files, slide decks and spreadsheets are in scope. Older ones get an exception (below), but any document posted or updated after your compliance date has to conform. So do the forms people use to apply for things, whenever they were posted.

Mobile apps. Apps the government provides or makes available are covered, including ones a private company runs for you. The DOJ's own example is a city parking payment app, which "must meet WCAG 2.1, Level AA even if the app is run by a private company" (ADA.gov fact sheet).

Vendors. You can't contract your way out. If a vendor posts content or runs a service for you (online bill pay, a tuition portal, a permit system), you're still responsible for it meeting the standard. A plain link to an unrelated private site, like a local hotel, generally doesn't carry the same obligation (ADA.gov first steps). In practice the procurement office ends up doing as much of this work as the web team does.

What are the five exceptions?

The rule exempts five categories of content. Each comes with conditions (ADA.gov first steps):

  1. Archived web content. It has to have existed before your compliance date, be kept only for reference, research or recordkeeping, never be updated after archiving, and live in a clearly marked archive area.
  2. Preexisting conventional electronic documents. PDFs and office files posted before the compliance date. This doesn't cover documents people still use to apply for, access or take part in your services.
  3. Content posted by third parties. Only content from truly unaffiliated parties posting on their own behalf, such as a resident's comment on a public forum. A contractor you pay to post doesn't count.
  4. Individualized, password-protected documents. Documents about a specific person, property or account, like a single resident's water bill PDF behind a login.
  5. Preexisting social media posts. Posts made before your compliance date. New posts have to conform.

The exceptions narrow what you have to remediate up front. They don't remove the ADA's general duty to communicate effectively: if a resident with a disability asks for an archived report in an accessible format, you still have to provide one (ADA.gov fact sheet).

My honest read, after looking at a lot of municipal sites: the archive exception is the one teams lean on hardest, and the one they most often get wrong. A "Documents" folder that staff still link to from live pages and occasionally update is not an archive. The test is in the rule's definition, not in the folder name.

How does the DOJ measure compliance?

Four provisions matter here, and none of them is a shortcut.

Conforming alternate versions are allowed only where making the content directly accessible isn't possible because of technical or legal limitations (28 CFR 35.202). A separate "accessible version" of a page you could have fixed doesn't qualify.

Equivalent facilitation lets you use another approach if it gives substantially equivalent or greater accessibility and usability than WCAG 2.1 AA. You carry the burden of showing that (ADA.gov fact sheet).

Minimal impact. Under 28 CFR 35.205, you can be treated as meeting the standard despite a failure, but only if you can show the failure has such a minimal impact on access that people with disabilities can still get the same information, interactions and transactions, with "substantially equivalent timeliness, privacy, independence, and ease of use." The DOJ's fact sheet says this isn't a way to avoid the standard (ADA.gov fact sheet). A slightly off contrast ratio on a footer link might qualify. A submit button that keyboard users can't reach won't.

Fundamental alteration and undue burden limits still exist, but the entity has to show them, and the analysis depends on its own resources (ADA.gov fact sheet).

Are the 2027 and 2028 deadlines final?

They're the operative dates, but they're contested. The DOJ issued the one-year extension as an Interim Final Rule on April 20, 2026 (Federal Register, 91 FR 20902). On May 21, 2026 the National Federation of the Blind sued the DOJ and HHS in the U.S. District Court for the District of Maryland. The suit argues the extensions skipped required notice-and-comment procedure and asks the court to vacate them (Civil Rights Litigation Clearinghouse, No. 1:26-cv-02007; Route Fifty). As of this writing the public docket shows procedural orders and a briefing schedule, but no merits ruling.

I'm not going to predict the outcome. The planning point is simpler: a government that plans to the 2027 date with no slack is exposed if the court restores the original 2026 schedule. A team that is already working through its backlog barely notices either way.

Where should a public entity start?

The DOJ's own first-steps guide is a sensible order (ADA.gov first steps). Here's how it looks in practice:

  1. Confirm your population and date. It takes five minutes and settles the planning argument.
  2. Name an owner, and include procurement. Most of your highest-traffic services probably run on vendor platforms.
  3. Inventory. Websites, subdomains, apps, social accounts and the document library. The document count usually surprises people.
  4. Apply the exceptions honestly. Mark what's genuinely archived, and flag every older PDF that's still part of a live process.
  5. Test. Run an automated scan across every template and key page, then do manual testing with a keyboard and a screen reader on the journeys people actually complete: paying a bill, applying for a permit, registering for a program.
  6. Fix shared templates first. A broken header or form component repeats on every page, so one fix clears thousands of findings.
  7. Put accessibility in contracts and publishing workflows, so new content and renewed vendor deals arrive accessible.

Be realistic about step 5. Automated testing finds a real share of WCAG issues, about 30 to 57% depending on whether you count by issue volume or by success criteria (Deque). The rest needs a person. A scanner can tell you a form field has no label. It can't tell you whether your error message makes sense when a screen reader reads it out. Our PDF accessibility checker has the same limit: it flags structural problems in a document, and a person still has to judge reading order and whether the alt text is meaningful.

It's also worth publishing an accessibility statement that says what you've tested, what's still being fixed, and how residents can ask for an accessible alternative. The Title II rule doesn't require one. Residents still need a way to report a barrier, and a statement records your effort without claiming more than you've done.

FAQ

What standard does ADA Title II require for government websites?

WCAG 2.1 Level AA. The DOJ's 2024 rule adopts it for state and local government web content and mobile apps, and the 2026 extension changed only the dates, not the standard (ADA.gov fact sheet).

When do state and local governments have to comply?

April 26, 2027 for governments with a total population of 50,000 or more, and April 26, 2028 for smaller governments and all special districts. A federal lawsuit challenging those extended dates is pending (Clearinghouse).

Are old PDFs exempt?

Only if they were posted before your compliance date and aren't used to apply for, access or take part in a service. A PDF application form posted years ago is still in scope, and any document updated after the date has to conform (ADA.gov first steps).

Are we responsible for a vendor's payment portal or app?

Yes. Content and apps provided for you through a contract, license or similar arrangement must meet WCAG 2.1 AA, and the government stays responsible even when the work is outsourced (ADA.gov first steps).

Can an automated scan show we're compliant?

No. A scan finds roughly 30 to 57% of issues, depending on how they're counted (Deque). Showing conformance to WCAG 2.1 AA also needs manual testing with a keyboard and assistive technology.

See what's on your pages today

A scan won't finish the job, but it will give you the map. Run a free accessibility scan against WCAG 2.1 AA and you get each violation with the exact selector, which is what your web team and your vendors need to start fixing.

Written by Pavel Charkasau, founder of wcagc.com. I build accessibility testing tools and read the Title II rule and its exceptions so public-sector teams can plan from the regulation, not from vendor summaries of it.

Last updated: October 14, 2026

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