ADA Title II web rule: use the extended 2027 and 2028 dates for remediation, not delay

DOJ moved the Title II web and mobile app compliance dates to April 26, 2027 and April 26, 2028. The WCAG 2.1 Level AA standard did not change, and content a vendor posts for a public entity is still covered.

Source facts

The Department of Justice’s Title II rule makes WCAG 2.1 Level AA the technical standard for web content and mobile apps that state and local governments provide or make available. An interim final rule published April 20, 2026 moved the compliance date to April 26, 2027 for entities with a total population of 50,000 or more, and to April 26, 2028 for smaller entities and special district governments (ADA.gov).

Coverage follows the public entity’s content rather than its author. The fact sheet’s examples say a county page made and updated by a local web design company must meet the standard, and content a contractor posts for a government usually must too. Archived content is excepted only when all four listed conditions are present, and a preexisting document loses its exception once it is updated after the compliance date.

The extension changed dates only: the Federal Register notice says it does not alter the substantive requirements of the 2024 rule (Federal Register).

Applicability

Use this for public-sector websites, portals, online forms, payment and reservation tools, and mobile apps, including calendars, maps and payment systems from outside technology companies that a public entity places on its site. The fact sheet lists state and local governments, special purpose districts, Amtrak and other commuter authorities as covered.

DSE recommendation

DSE recommends treating the extra year as remediation time rather than a pause. Inventory every public site, app and embedded vendor tool; record which compliance date applies from the entity’s population; fix current, commonly used and application content first; and write WCAG 2.1 Level AA conformance, remediation and evidence duties into each web design, hosting and app contract.

Verification

Test the main public journeys, such as forms, payments and document downloads, with keyboard-only navigation and a screen reader, and treat automated checkers as a supplement rather than proof. Re-test any preexisting document after it is edited, and keep dated records of each test, defect and fix.

Official references

ADA.gov — Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments. Federal Register — Extension of Compliance Dates (Interim Final Rule, April 20, 2026). Reviewed October 18, 2026.