ADA Title II Web Accessibility Deadlines: April 2027 and April 2028

The two deadlines, and which one applies to you

The rule splits covered entities into two groups by the population they serve. Public entities serving 50,000 or more people must conform by April 26, 2027. All other public entities - smaller local governments - plus special district governments of any size, have until April 26, 2028.

Note that special district governments (school districts, transit authorities, water and utility districts, library districts and similar bodies) fall into the later 2028 group regardless of the population they serve.

• April 26, 2027 - public entities serving a population of 50,000 or more
• April 26, 2028 - public entities serving fewer than 50,000 people
• April 26, 2028 - special district governments, whatever their size
• Technical standard for both: WCAG 2.1 Level AA

Who counts as a 'public entity' under Title II

Title II reaches state and local government at every level, and a lot of organizations are surprised to find themselves inside it. If you are funded and operated by state or local government, assume you are covered until you have confirmed otherwise.

• State agencies, departments and commissions
• County and municipal government
• Public colleges, universities and community colleges
• Public school districts (K-12)
• State and local courts
• Public transit authorities
• Public libraries, hospitals and utility districts
• Any special purpose district created by state or local government

What has to be accessible

The rule covers web content and mobile applications that a public entity provides or makes available - whether the entity built them, bought them, or contracted them out. Procurement does not transfer the obligation: if a vendor's product is part of how you deliver a public service, its accessibility is still your exposure.

That last point is the one that most often derails a compliance programme. Learning management systems, payment portals, permit and licensing systems, job application platforms, board-meeting video and third-party mapping widgets are all commonly outsourced and commonly inaccessible.

• Public-facing websites and every page template within them
• Native mobile apps on iOS and Android
• Third-party and vendor-supplied platforms used to deliver services
• PDFs, forms and documents published on the site
• Video and audio content, including captions and audio description

Why WCAG 2.1 AA, when WCAG 2.2 exists

The rule names WCAG 2.1 Level AA as its technical standard. WCAG 2.2 is the newer W3C recommendation and is backwards compatible - it keeps every 2.1 criterion and adds a small number of new ones, mainly around focus visibility, dragging alternatives and target size.

Our recommendation for most public entities is to audit against WCAG 2.2 AA even though the rule cites 2.1. You satisfy the legal standard either way, the additional criteria are not expensive to meet if you are already remediating, and you avoid a second remediation cycle when the referenced standard eventually moves.

The limited exceptions - and why not to lean on them

The rule includes narrow exceptions, including archived web content, certain pre-existing electronic documents, third-party content not posted by or on behalf of the entity, individualized password-protected documents, and pre-existing social media posts.

Treat these as edge cases rather than a strategy. Each exception is conditional and fact-specific, and misclassifying live content as 'archived' is a common and costly mistake. If content is still being used to deliver a service, it is almost certainly in scope.

How to use the extra year

An extension is only valuable if it changes what you do. The entities that struggled with the original date were generally the ones that waited for a single large remediation project instead of building capability. A realistic 12-month plan looks like this:

• Months 1-2: inventory every digital property, including vendor systems and mobile apps. You cannot remediate what you have not found.
• Months 2-3: baseline audit against WCAG 2.2 AA, combining automated scanning with manual assistive-technology testing.
• Months 3-4: triage by user impact and legal exposure, not by ease of fixing. Blocked transactions and inaccessible forms come first.
• Months 4-9: remediate, starting with shared components and page templates so one fix resolves many pages.
• Ongoing: add accessibility acceptance criteria to procurement contracts and to your definition of done, so new content does not regress.
• Final quarter: verification re-test and a documented conformance statement you can produce on request.

The extension does not pause legal risk

This is the point most commonly misread. The compliance date for the Title II rule moved, but the underlying non-discrimination obligation under the ADA has been in force for decades. Individuals can still assert claims about inaccessible public services during the extension period, and private-sector Title III litigation is entirely unaffected by this change.

In practical terms: the deadline is when a regulator can hold you to a specific technical standard. It is not the date at which accessibility starts to matter.