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ADA Title II web rule: the 2027 and 2028 deadlines and how to be ready

State and local governments in the US must make their web content and mobile apps meet WCAG 2.1 Level AA. An interim final rule of April 20, 2026 moved the dates to April 2027 and April 2028. If you run a public-sector website, or build or supply one, this is what applies and what to do with the time.

Who must comply, and by when

The rule was published on April 24, 2024. It names WCAG 2.1 Level AA as the technical standard for web content and mobile apps of state and local governments. The interim final rule of April 20, 2026 extended the original dates by a year:

Public entityCompliance date
Serves a population of 50,000 or moreApril 26, 2027
Serves a population under 50,000April 26, 2028
Special district governmentsApril 26, 2028

Covered: all state and local governments and their agencies and departments, special purpose districts, Amtrak and other commuter authorities. That includes cities, counties, public schools and universities, courts, libraries, transit and utilities. School districts use the population of their city or county, or census estimates if independent.

If you are a vendor or contractor

The duty sits with the government, and it extends to what others do for it: contractors that provide public services on a government's behalf must follow Title II too. In practice that reaches you in three ways:

If your product or the sites you build will be in front of residents in 2027, the testing has to happen now, while there is time to fix.

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The five exceptions

  1. Archived web content: created before the compliance date, kept only for reference, research or recordkeeping, stored in a dedicated archive area, and not changed since.
  2. Preexisting conventional electronic documents: word processing, presentation, PDF and spreadsheet files posted before the compliance date, unless people currently use them to apply for or access services.
  3. Third-party content: posted by members of the public who are not acting under a contract or arrangement with the government.
  4. Individualized password-protected documents: files about a specific person, property or account, behind a login.
  5. Preexisting social media posts: made before the compliance date.

The exceptions are narrow, and they do not remove the duty to provide effective communication and reasonable modifications when someone asks.

How to use the time

  1. List your templates and resident tasks: finding information, searching, paying, applying, booking, contacting.
  2. Test them against WCAG 2.1 AA now. We test against 2.2 AA, which includes it. Check a page free.
  3. Fix by template, starting with forms and navigation.
  4. Retest every month until the date, and after it. The rule expects ongoing conformance; a site drifts with every new page.
  5. Keep the dated log and publish a statement with a contact route for barriers.
  6. Plan the human testing. Have a person test the key tasks with a screen reader before launch. Our report lists exactly what is left for that session.

Our audit covers public web pages. It does not cover PDF documents, mobile apps or pages behind a login, all of which the rule can reach, so plan those separately.

Questions

What is the ADA Title II compliance deadline?

April 26, 2027 for public entities serving 50,000 people or more, and April 26, 2028 for smaller entities and special district governments. These dates come from the interim final rule of April 20, 2026, which extended the original ones.

Which WCAG version does ADA Title II require?

WCAG 2.1 Level AA, for web content and mobile apps.

Does ADA Title II apply to private businesses?

Not directly. Title II covers state and local governments. A business is reached when it provides a public service on a government's behalf, or when a government buys its product and passes the requirement into the contract. Businesses open to the public fall under Title III.

Are PDFs covered by the Title II rule?

Yes, with a narrow exception for documents posted before the compliance date that are not currently used to apply for or access services. Our audit does not test PDFs.

Paste your address and see what fails WCAG 2.2 AA, where, and the code that fixes it. Starter $39/mo · Pro $129/mo. Refund within 14 days if it misses.

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More about WCAG Audit

Sources (checked 2026-11-11): www.ada.gov/resources/2024-03-08-web-rule/ · www.w3.org/TR/WCAG21/ · www.upwork.com/jobs/~022118164621938243878