ADA Title II Web Accessibility Rule: Requirements and Deadlines

Who does the ADA Title II web rule apply to?

It applies to state and local governments: states, counties, cities, towns, public schools and colleges, public transit agencies, courts, libraries, police departments and special district governments such as water or fire districts.

It covers the web content and mobile apps they provide or make available, including those run for them by contractors and vendors. The DOJ's own example: if a city lets people pay for parking through a mobile app, that app must meet WCAG 2.1 Level AA even if a private company runs it.

When do state and local governments have to comply?

The compliance date depends on the government's total population, using US Census Bureau data. A department or agency without its own population figure, such as a city library or police department, uses the population of the government it is part of.

• Total population of 50,000 or more: 26 April 2027
• Total population under 50,000: 26 April 2028
• Special district governments, whatever their size: 26 April 2028

What are the exceptions to the Title II web rule?

Content that falls under one of five exceptions does not have to meet WCAG 2.1 AA, though the government must still provide effective communication and reasonable modifications when someone asks. The exceptions are narrow and each has conditions:

• Archived web content: created before the compliance 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 or spreadsheet files available before the compliance date, unless they are still used to apply for, access or take part in services
• Content posted by a third party who is not acting for the government under a contract, licence or other arrangement
• Individualised, password-protected documents about a specific person, property or account, such as a water bill
• Preexisting social media posts made before the compliance date

How should a state or local government prepare?

With deadlines in 2027 and 2028, there is time to do this properly if you start now:

• Inventory your websites, mobile apps and third-party services, including payment, booking and permitting tools.
• Scan your main templates and highest-traffic pages, and fix critical and serious WCAG failures first.
• Manually test key services, such as paying a bill, applying for a permit or registering for a class, with a keyboard and a screen reader.
• Remediate or replace PDFs that people still use to apply for or access services.
• Add WCAG 2.1 AA requirements, and evidence such as an ACR, to contracts with vendors.
• Publish an accessibility statement with a way for people to report barriers.