ADA Title II Web Accessibility Deadlines: 2027 and 2028

What happened in April 2026?

The original 2024 rule set two compliance dates: April 24, 2026 for public entities with a total population of 50,000 or more, and April 26, 2027 for smaller entities and special districts. In April 2026, the Department of Justice issued an interim final rule, effective April 20, 2026, extending both dates by one year.

The new dates are April 26, 2027 and April 26, 2028. Everything else in Subpart H is untouched: the WCAG 2.1 AA standard in section 35.200, the coverage of vendor-provided content, and the five narrow exceptions in section 35.201.

Which bucket is your entity in?

• Population means total population. It comes from the most recent decennial Census, not from website traffic, registered users, or employee headcount
• Cities, towns, and counties use their own Census population. A county of 80,000 is in the 2027 bucket even if the county website is small
• States are 50,000-plus by definition, so state agencies are in the 2027 bucket
• Special district governments, meaning independent special-purpose units like water and sewer districts, transit authorities, library districts, and fire protection districts, all get April 26, 2028 no matter how many people they serve
• Departments and instrumentalities of a larger government follow that government's date. A health department in a county of 200,000 shares the county's 2027 deadline

Not sure where your entity lands? Our Who It Applies To pages walk through schools, libraries, municipalities, police and courts, and more, or read the full Title II web accessibility guide.

What has to be true by your deadline?

Compliance means the web content and mobile apps your entity provides or makes available conform to WCAG 2.1 Level AA. In concrete terms, by your date:

• Your websites, subdomains, and mobile apps pass WCAG 2.1 AA, including pages run by vendors and contractors on your behalf
• The documents people use to access your services, such as PDF forms, applications, and notices, are accessible too
• Password-protected portals, from utility billing to parent gradebooks, meet the same standard
• Anything you claim under an exception, such as archived content, actually meets the exception's strict conditions

That is more than a one-sprint project for almost every public entity. Site remediation, document cleanup, vendor contracts, and staff training routinely take 12 to 18 months. A 2027 deadline means the budget you approve this year is the one that pays for the work.

Why starting now beats waiting

The deadline is when WCAG 2.1 AA becomes mandatory. It is not when your obligations begin. Title II's effective communication and program access requirements have applied to your services for decades, websites included, and residents can file complaints and lawsuits today. The smartest sequence is simple: know where you stand, fix the front door services first, and stop new problems at the source. We lay it out step by step in First Steps, and the Title II checklist turns it into a punch list you can hand to your team this week.