ADA Title II web rule deadlines (April 2027 / April 2028) for cities, counties and school districts

Updated 2026-10-24 · Altlark guides

In April 2024 the U.S. Department of Justice published a rule under Title II of the Americans with Disabilities Act that sets a technical standard for the websites and mobile apps of state and local governments. In April 2026 the Department extended the dates by one year. This page summarizes the rule as published, with links to the official sources, so you can plan. It isn't legal advice: for decisions about your organization, read the rule itself and talk to your counsel.

Last checked against the sources below: October 24, 2026.

The current dates

On April 20, 2026, the Department published an Interim Final Rule in the Federal Register that moved both dates back one year. According to the Department's fact sheet on ada.gov and the current text of 28 CFR 35.200 on eCFR:

April 26, 2027: state and local government entities with a total population of 50,000 or more (other than special district governments). The original date was April 24, 2026.
April 26, 2028: public entities with a total population of less than 50,000, and all special district governments. The original date was April 26, 2027.

The Interim Final Rule took effect on April 20, 2026 and invited public comments until June 22, 2026. Because it's an interim rule, check ada.gov for any later changes before relying on these dates.

Who it covers

Title II applies to state and local governments and their agencies and departments. The ada.gov fact sheet lists examples including benefits and social-services offices, public schools, community colleges and public universities, police departments, courts, elections offices, public hospitals and clinics, parks and recreation programs, public libraries and public transit agencies. It also covers special purpose districts, Amtrak and other commuter authorities. Governments that contract with other organizations to provide public services for them also have to make sure those contractors follow Title II.

School districts: the fact sheet says a school district is not a special district government. A city school district uses the city's population; a county school district uses the county's; an independent school district uses the population estimate in the most recent Census Small Area Income and Poverty Estimates.

Departments of a larger government, like a city library or police department, use the population of the government they belong to.

The standard: WCAG 2.1 Level AA

The rule adopts the Web Content Accessibility Guidelines (WCAG) 2.1, Level A and AA success criteria, as the technical standard for web content and mobile apps. It applies to content the government provides directly and to content provided "through contractual, licensing, or other arrangements". The fact sheet's examples include a county web page built and updated by an outside design company, and a parking-payment app run by a private company for a city.

WCAG 2.2 is the newer W3C version, but the rule names 2.1. The success criteria that Altlark checks all exist in both versions.

The exceptions, in brief

The rule has five limited exceptions. Each comes with conditions, so read the fact sheet's full explanations:

Archived web content: created before the entity's date, kept only for reference, research or recordkeeping, kept in a special archive area, and not changed since it was archived.
Preexisting conventional electronic documents (word processing, presentation, PDF and spreadsheet files) available before the entity's date, unless they're currently used to apply for, access or participate in services.
Content posted by third parties who aren't posting on the government's behalf. Third-party tools the government puts on its site (calendars, maps, payment and scheduling systems) are not exempt.
Individualized, password-protected documents about a specific person, property or account (like a PDF water bill).
Preexisting social media posts made before the entity's date.

The fact sheet stresses that even where an exception applies, existing ADA obligations still require effective communication, reasonable modifications and equal opportunity, for example by providing an accessible version on request.

Where to start

The rule's scope is everything a public entity publishes, so it helps to start with a list:

Inventory: main website, sub-sites (parks, library, courts), mobile apps, and third-party systems for payments, permits, scheduling, agendas and job applications.
Prioritize pages people need to use services: applications, payments, contact forms, meeting agendas, emergency information.
Run automated checks to find the frequent, fixable issues quickly. Altlark's free scan checks one page at a time for missing alt text, empty links and buttons, unlabeled form fields, missing page language and titles, heading problems, untitled iframes and autoplaying media. Monitoring rescans up to 100 pages per site daily and alerts you when new issues appear, which helps once fixes are in place.
Test manually: keyboard-only use, zoom, color contrast, captions, and a screen-reader pass through your key tasks. Automated tools can't cover most of WCAG 2.1 AA on their own.
Check your vendors: ask third-party platform vendors how their product meets WCAG 2.1 AA and for their documentation, since their content on your site is in scope.
Documents: decide which PDFs are still in active use and need remediation or an HTML replacement.

Common issues on government sites, with fixes

Automated checks on public-sector sites tend to find the same handful of patterns. Two examples:

A payment or permit form where the field names are only shown as placeholders:

Before (flagged)

<input type="text" name="acct" placeholder="Utility account number">
<button><img src="/img/arrow.png"></button>

After (fixed)

<label for="acct">Utility account number</label>
<input type="text" id="acct" name="acct" inputmode="numeric">
<button type="submit">Look up my bill</button>

A meeting-agenda list where every link says the same thing:

Before (flagged)

<li>City Council, October 14 <a href="/agendas/2026-10-14.pdf">Download</a></li>
<li>City Council, October 28 <a href="/agendas/2026-10-28.pdf">Download</a></li>

After (fixed)

<li><a href="/agendas/2026-10-14.pdf">City Council agenda, October 14 (PDF)</a></li>
<li><a href="/agendas/2026-10-28.pdf">City Council agenda, October 28 (PDF)</a></li>

The PDFs themselves also need to be accessible if they're new or in active use; that's outside what an HTML scan checks. See missing form labels and ambiguous link text for more.

A note on what a scan does and doesn't show

A scan report, including ours, is a list of issues that specific automated checks found on specific pages on a specific date. It doesn't certify anything and isn't a legal assessment. Use it as an engineering to-do list alongside manual testing and, where needed, an expert audit.

Official sources

Questions about the rule itself can go to the Department's ADA Information Line, listed on ada.gov.

Automated checks find some, not all, accessibility issues (they catch only a portion of WCAG problems). This is not legal advice, not a legal assessment and not a certification.