The ADA Title II Web Rule: Deadlines, Requirements and Exceptions

Who is covered

Title II of the Americans with Disabilities Act applies to state and local governments. The Department of Justice’s 2024 rule, codified at 28 CFR part 35, subpart H, extends that obligation explicitly to the web content and mobile apps those governments provide or make available, including content provided through contractors. The rule sets different dates by total population and treats special district governments as their own group. Businesses open to the public are covered by Title III instead, which has no equivalent technical regulation; the difference is covered in Section 508 vs ADA vs WCAG.

The technical standard: WCAG 2.1 AA

The rule names WCAG 2.1 Level AA as the technical standard for state and local governments’ web content and mobile apps, as the Justice Department’s fact sheet states. Level AA includes every Level A success criterion plus the AA criteria such as minimum color contrast, resize text and consistent navigation.

Building to WCAG 2.2 AA is a sensible target. WCAG 2.2 became a W3C Recommendation on October 5, 2023, and the W3C notes that the 2.0 and 2.1 success criteria are essentially the same in 2.2, with one exception: 4.1.1 Parsing was removed. Meeting 2.2 AA therefore covers what 2.1 AA asks for and adds criteria such as 2.5.8 Target Size (Minimum). Our WCAG 2.2 checklist lists every Level A and AA criterion, and WCAG 2.1 vs 2.2 explains what changed.

Compliance dates

The deadline depends on the government’s total population. The current dates come from the interim final rule published in the Federal Register on April 20, 2026 (91 FR 20902).

What the 2026 extension changed, and what it did not

The interim final rule took effect on April 20, 2026, and the Department accepted comments through June 22, 2026. It moved the compliance dates by one year for each group. It did not change the technical standard, who is covered, or the exceptions. Every requirement described on this page applies on the new dates exactly as it would have on the old ones. The practical consequences are in The ADA Title II deadline moved to April 2027.

The five exceptions

Each exception has conditions. Content that fails any condition is covered.

The document exception is the one most often misread. A PDF posted years ago is excepted only while nobody needs it to apply for or access a service. If it is a current permit application, fee schedule form or enrollment packet, it is covered.

Equivalent facilitation and undue burden

The rule allows a different approach if it provides “the same or more accessibility and usability” than WCAG 2.1 AA would. That is equivalent facilitation. Separately, a conforming alternate version, a second accessible copy of inaccessible content, is allowed only where a technical or legal limitation prevents making the main content accessible. It is not a general workaround.

The usual ADA limits also apply. A government is not required to take an action that would fundamentally alter a service or impose an undue burden. These limits are narrow and are not a substitute for planning.

Contractors and vendors

Content a government provides through a contractor is covered. Payment portals, permit systems, agenda management tools, recreation booking sites and the website itself are all in scope even when a vendor builds or hosts them. Content posted by a contractor, or through a platform the government provides, cannot use the third-party exception. That makes procurement language as important as remediation: contracts should require WCAG 2.1 AA (or 2.2 AA) conformance and evidence of testing.

Mobile apps

Mobile apps a government provides or makes available are covered by the same WCAG 2.1 AA standard. Transit apps, utility payment apps and 311 reporting apps are the common examples. They need the same audit and remediation cycle as the website.

What to do before your date

The order below front-loads the work that fixes the most pages per hour.

1. Inventory. List every site, subdomain, portal and app you provide, including vendor-hosted ones, and the documents people use to apply for or access services.
2. Run an automated scan. Automated tools catch only part of WCAG, but they find the repeated template errors fast. Our accessibility checker runs a first pass on any page.
3. Test manually. Keyboard-only navigation, visible focus, screen reader output, zoom to 200% and reflow cannot be fully judged by a tool.
4. Fix templates first. Navigation, footers, forms and page layouts repeat on every page; one fix there clears thousands of instances.
5. Remediate the documents still in use. Prioritize PDFs and forms that people need to apply for or access services; archive or replace the rest.
6. Update procurement language. Require WCAG 2.1 AA or 2.2 AA conformance and test evidence in new contracts and renewals.
7. Publish an accessibility statement and a feedback path. Give people a way to report a barrier and get the information another way.
8. Monitor. Content keeps being published. Re-scan on a schedule and test new templates before launch.

For context on where public websites start from, our study of 95 California government homepages found automatically detected WCAG 2.1 A/AA failures on 66.3% of them. Teams replacing an older CMS as part of this work can see Drupal to Next.js, and the standard is defined in plain words at What is ADA Title II? and What is WCAG?