The ADA Title II web rule: what state and local governments must do, and by when

The rule in brief

Title II of the ADA covers state and local governments: states, counties, cities, towns, school districts, public colleges, transit agencies, public hospitals and special districts. On April 24, 2024, the Justice Department published a final rule saying their web content and mobile apps must meet WCAG 2.1 Level AA.

It covers content they provide directly and content they provide “through contractual, licensing, or other arrangements”: an outside vendor's payment portal or a third-party app used to deliver a public service is included.

The compliance dates, after the 2026 extension

The original rule gave large governments until April 24, 2026 and smaller ones until April 26, 2027. On April 20, 2026, the Department published an interim final rule extending both by a year:

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

The extension changed only the dates. The technical standard and the rest of the 2024 rule stayed the same. The Department took public comments on the extension until June 22, 2026.

The exceptions

The rule lists specific kinds of content that don't have to meet WCAG 2.1 AA, as long as the conditions are met. In summary:

• Archived web content kept only for reference, that hasn't changed since it was archived and is clearly marked as archived.
• Certain documents posted before the compliance date, unless people still use them to apply for or take part in a service.
• Content posted by third parties who aren't acting for the government, such as public comments.
• Individualized documents for a specific person that are password-protected, such as a utility bill.
• Social media posts made before the compliance date.

The rule also allows a government to show that full compliance would fundamentally alter a service or impose undue financial and administrative burdens. Those limits are narrow, and the government still has to provide access in other ways as far as it can. Read the exact wording on ADA.gov before relying on any exception.

What it means for businesses

The rule applies to governments, not to private businesses, which fall under Title III of the ADA. No regulation sets a technical web standard for Title III. But vendors who build or host websites, apps, forms or payment systems for public agencies should expect those agencies to ask for WCAG 2.1 AA in contracts. For private businesses, WCAG AA remains the usual yardstick in practice; see what the ADA means for your website.

Where to start if you run a public site

1. Make an inventory: websites, apps, online forms, payment portals, PDFs, videos, and the vendors behind them.
2. Scan everything, and prioritize the services people need most: applying, paying, booking, reporting.
3. Fix templates first, since one fix there repairs every page that uses it.
4. Review PDFs and documents people still use; publish them as web pages where you can.
5. Add accessibility requirements to new and renewing vendor contracts.
6. Publish an accessibility statement and a way to report problems, and respond quickly.

Sources

• Federal Register, April 20, 2026: Extension of Compliance Dates (interim final rule)
• ADA.gov: Fact sheet on the web rule for state and local governments (updated for the extension)
• eCFR: 28 CFR Part 35, Subpart H, Web and mobile accessibility