ADA Title II Deadlines: April 2027 and 2028 for Government Sites

The U.S. Department of Justice (DOJ) has set new compliance dates for web accessibility under Title II of the Americans with Disabilities Act (ADA). State and local governments serving 50,000 people or more must meet the rule by April 26, 2027. Smaller governments and special district governments have until April 26, 2028. The standard is WCAG 2.1 Level AA, and the extension did not change it.

This article is general information, not legal advice. Confirm dates and details with your counsel and with ADA.gov.

The deadlines

DOJ published its original rule in April 2024. On April 20, 2026, it published an interim final rule in the Federal Register that pushed each date back one year.

The summary of the rule on ADA.gov shows the new dates. An interim final rule takes effect right away. DOJ still took public comments on it until June 22, 2026. In its explanation, DOJ said it had overestimated how quickly governments could get the staff and tools to comply.

Population is based on the entity’s total population, using U.S. Census Bureau data, as the rule describes it. Special district governments are single-purpose bodies such as water, fire, library or transit districts.

An extra year does not mean the obligation starts later. Title II has long required equal access to a public entity’s services, and that includes services offered online. People can still file complaints or lawsuits about inaccessible government websites before the dates. The rule adds a clear technical yardstick and a date by which you are expected to meet it.

Could the rule change again?

Possibly. DOJ said it plans more rulemaking on the rule’s substantive requirements and may publish a notice of proposed rulemaking. That would open a new public comment period before anything changed. As of early October 2026, we have not seen a published proposal. The technical standard is still WCAG 2.1 Level AA.

Do not plan around a change that may never come. Almost everything you fix to meet WCAG 2.1 AA (labeled forms, keyboard access, captions, readable contrast) will be needed under any version of the rule. It also helps the residents who use your site today.

Who is covered

Title II applies to state and local governments and their departments, agencies and instrumentalities:

• Cities, towns, counties and townships
• State agencies and boards
• Public school districts
• Public colleges and universities
• Special districts, such as water, library, parks, fire and transit districts
• Public hospitals and other publicly run services

Many public hospitals, clinics and universities also receive funding from the Department of Health and Human Services (HHS). Their websites are covered by a separate HHS rule under Section 504 of the Rehabilitation Act. It uses the same WCAG 2.1 AA standard. In May 2026, HHS extended its dates to May 11, 2027 for recipients with 15 or more employees, and May 10, 2028 for smaller ones. If both rules apply to you, plan for the earlier date.

Title II does not directly cover private businesses. Those fall under Title III, where there is no equivalent technical rule. If you are a private contractor building or hosting a government website, however, the rule affects you through your client.

What has to comply

The rule covers web content and mobile apps that a public entity provides or makes available, including through third parties:

• Your main website and department sites
• Online forms, applications and payment systems
• Permit, records, meeting and utility portals
• Content hosted by a vendor on your behalf, such as an online payment system or a meeting-video service
• Mobile apps you publish

The technical standard is WCAG 2.1 Level AA. The W3C says content that conforms to WCAG 2.2 also conforms to 2.1, so many teams build to 2.2 AA and cover both. We explain what 2.2 adds in WCAG 2.2 changes for WordPress.

What is exempt

The rule lists five kinds of content that do not have to meet WCAG. In summary:

• Archived web content: old material kept only for reference or recordkeeping, not edited since it was archived, and clearly labeled as archived.
• Pre-existing conventional electronic documents: PDFs, Word and similar files posted before the compliance date, unless people currently need them to apply for, access or participate in a service.
• Pre-existing social media posts: posts made before the compliance date.
• Content posted by third parties: for example, public comments on your site, unless the third party posts it under a contract, license or similar arrangement with you.
• Individualized, password-protected documents: files such as PDFs about one specific person, property or account, like a utility bill or tax statement. You must still give that person an accessible version when they need it, under Title II’s general rules.

There are also two limited defenses: fundamental alteration (compliance would change the nature of the service) and undue financial and administrative burden. They are narrow. The undue burden defense generally requires a written statement from the head of the entity, and it looks at the whole entity’s resources, not one department’s budget. Do not plan on either as your strategy.

An exception for password-protected course content appeared in DOJ’s draft rule but not in the final one. Course materials at public schools and colleges are covered.

If you rely on an exemption, document why. For a PDF library, that often means deciding which documents are truly archived and which are still in use.

Where public sector WordPress sites usually fall short

Many government sites run on WordPress, and the problems tend to follow the same patterns:

• Document libraries. Hundreds or thousands of scanned or untagged PDFs for agendas, minutes, forms and notices. New ones must be accessible, and any still used to access a service need remediation.
• Meeting video. Livestreams and recordings without captions, plus embedded players that trap the keyboard.
• Forms and payments. Missing labels, errors shown only in red, CAPTCHAs, and third-party payment pages the entity does not control but is still responsible for.
• Themes and page builders. Menus that need a mouse, removed focus outlines, skipped heading levels and low-contrast text.
• Maps, calendars and chat widgets. Embedded tools that vendors built without accessibility in mind.
• Editors without training. Staff publish new content daily and each upload can add a new failure.

A plan for the months ahead

As of October 2026, the April 26, 2027 date for the 50,000-plus group is less than seven months away. Smaller governments have until April 26, 2028, about 18 months. They should still start now, because remediation usually takes longer than people expect. Large document libraries and vendor contracts take the longest.

1. Inventory your digital services. List sites, subdomains, portals, apps, vendors and document collections. You cannot fix what you have not found.
2. Decide what is exempt and what is not. Mark archived content, pre-existing documents and third-party content, and write down the reasoning.
3. Audit the highest-traffic and highest-need services first. Pay, apply, report, register and find-a-meeting pages come before the history page. Test with a keyboard and a screen reader as well as automated tools. See how to audit WordPress accessibility.
4. Fix at the source. Repair the theme, templates and forms so a single change clears many pages. Do not rely on overlay widgets, which do not make a site compliant; see why overlays do not work.
5. Update your vendor contracts. Require WCAG 2.1 AA, ask for an Accessibility Conformance Report (ACR) for each product, and keep records of vendor responses. Remember that content a vendor provides on your behalf is still your responsibility.
6. Train staff. Anyone who posts content, documents or video needs a short checklist and, for documents, a process to review PDFs before they go up.
7. Publish an accessibility statement and a way to report barriers, and respond to the reports you receive.
8. Test continuously. Add accessibility checks to your update and release process so regressions are caught before they go live. See safe WordPress updates with staging and tests.

Why start before the deadline

Compliance dates matter, but they are not the whole story. DOJ itself says covered entities have an ongoing obligation to make online services accessible under existing ADA rules, and residents with disabilities can file complaints today. A public entity that can show an audit, a prioritized fix list and steady progress is in a far better position than one that started the week before the date. The same records also help in a dispute, which we cover in why ADA website lawsuits are rising and why compliance helps you win.

Get help with a Title II WordPress site

We audit WordPress sites against WCAG 2.2 Level AA (which covers the 2.1 AA that Title II requires), fix themes, forms and content at the source, and set up automated checks so the site stays accessible. Our ADA compliance service covers the full project. If you want a prioritized findings report for your own team or another vendor, our accessibility audit delivers one. Contact us with your site address and your population tier, and we will tell you what we would do first.

Frequently asked questions

What is the ADA Title II web accessibility deadline?

Public entities with a total population of 50,000 or more must comply by April 26, 2027. Entities with a population under 50,000, and special district governments, must comply by April 26, 2028. DOJ moved both dates back one year in an interim final rule published April 20, 2026.

Which technical standard does Title II require?

WCAG 2.1 Level AA. The April 2026 extension changed the dates only, not the standard. Content that meets WCAG 2.2 AA also meets 2.1 AA.

Does Title II apply to my city, county or school district website?

Yes. Title II covers state and local governments and their departments and agencies, including cities, counties, public school districts, public colleges and universities, and special districts such as water, library or transit districts.

Could the Title II rule change again?

Possibly. DOJ took comments on the extension until June 22, 2026, and said it plans future rulemaking on the rule's substantive requirements. Any change to the standard would have to go through a new proposal and public comment first. Until then, WCAG 2.1 AA and the 2027 and 2028 dates are the rule.

Do old PDFs have to be fixed?

Often not. The rule exempts most pre-existing conventional electronic documents, such as PDF and Word files, if they were posted before the compliance date and are not currently used to apply for, access or participate in a service. New documents and ones people need to use a service must be accessible.

Is a vendor's website or payment portal my responsibility?

Generally yes, if you provide it through a contract, license or other arrangement. The rule covers web content and apps that a public entity makes available through third parties on its behalf.