The Title II web rule: who must comply, and when
What happened
In April 2024 the Department of Justice published a final rule under Title II of the Americans with Disabilities Act setting, for the first time, a specific technical standard for government websites: the web content and mobile apps that state and local government entities provide must conform to WCAG 2.1 Level AA. Before this rule, Title II's general nondiscrimination duty applied to websites without naming a standard; now the standard, the scope, and the dates are all written down.
Who is covered
Every state and local government entity — the rule's reach is the same as Title II's: cities and towns, counties, state agencies, public schools and school districts, community colleges and public universities, courts, police and fire departments, transit agencies, public hospitals and health departments, libraries, parks districts, water and power districts. It also reaches web content a vendor provides on the entity's behalf — the payment portal, the agenda-management system, the recreation-signup platform. Private businesses are not covered by this rule (their websites live under Title III and its case law — a different practice).
The two dates
- April 24, 2026 — public entities with a total population of 50,000 or more.
- April 26, 2027 — public entities with a population under 50,000, and all special district governments regardless of size.
Population is measured by the entity's own census figures; for school districts and special districts there are specific counting rules in the regulation. If your entity is anywhere near the 50,000 line, confirming which date applies is a ten-minute exercise worth doing early — the two dates are a year apart and the work scales with the site.
What "comply" means on the date
On the compliance date, the entity's web content has to conform to WCAG 2.1 AA — with specific exceptions for archived and preexisting content, and general limits the ADA has always had (fundamental alteration, undue burdens). Conformance is a property of the actual pages and documents, which is why the realistic path is an inventory and audit now, remediation through the templates and documents, and a dated conformance record on file before the date arrives.
Why start before the deadline forces it
Not fear — arithmetic. Government sites accumulate documents: agendas, minutes, forms, notices, often thousands of PDFs. The rule's document exceptions remove some of them from scope, but sorting which, remediating the rest, and fixing the templates that generate new ones is months of calendar time even when the engineering is straightforward. Entities that inventory early buy themselves the cheap version of the same work.
Contact
Email [email protected]. You'll get a reply from me — usually the same day, always from a person.