28 CFR Part 35 · Subpart H — Web and Mobile Accessibility
§ 35.200 Requirements for web and mobile accessibility
Last updated June 11, 2026
What 28 CFR §35.200 requires of state and local governments.
In Plain Language
This is the core web accessibility requirement for public entities. All web content and mobile applications provided by or on behalf of a public entity must conform to WCAG 2.1 Level AA. Large entities (generally those in jurisdictions with 50,000+ population, state agencies, school districts) must comply by April 26, 2027. Smaller entities and special districts have until April 26, 2028. This requirement covers websites, web applications, PDFs and documents posted online, online forms, videos, and mobile apps.
This summary is educational, not legal advice. The official text below controls.
Official Regulatory Text — 28 CFR § 35.200
Verbatim from 28 CFR Part 35, current through June 9, 2026.
(a) General. A public entity shall ensure that the following are readily accessible to and usable by individuals with disabilities:
(1) Web content that a public entity provides or makes available, directly or through contractual, licensing, or other arrangements; and
(2) Mobile apps that a public entity provides or makes available, directly or through contractual, licensing, or other arrangements.
(b) Requirements. (1) Beginning April 26, 2027, a public entity, other than a special district government, with a total population of 50,000 or more shall ensure that the web content and mobile apps that the public entity provides or makes available, directly or through contractual, licensing, or other arrangements, comply with Level A and Level AA success criteria and conformance requirements specified in WCAG 2.1, unless the public entity can demonstrate that compliance with this section would result in a fundamental alteration in the nature of a service, program, or activity or in undue financial and administrative burdens.
(2) Beginning April 26, 2028, a public entity with a total population of less than 50,000 or any public entity that is a special district government shall ensure that the web content and mobile apps that the public entity provides or makes available, directly or through contractual, licensing, or other arrangements, comply with Level A and Level AA success criteria and conformance requirements specified in WCAG 2.1, unless the public entity can demonstrate that compliance with this section would result in a fundamental alteration in the nature of a service, program, or activity or in undue financial and administrative burdens.
(3) WCAG 2.1 is incorporated by reference into this section with the approval of the Director of the Federal Register under 5 U.S.C. 552(a) and 1 CFR part 51. All material approved for incorporation by reference is available for inspection at the U.S. Department of Justice and at the National Archives and Records Administration (“NARA”). Contact the U.S. Department of Justice at: Disability Rights Section, Civil Rights Division, U.S. Department of Justice, 150 M St. NE, 9th Floor, Washington, DC 20002; ADA Information Line: (800) 514-0301 (voice) or 1-833-610-1264 (TTY); website: www.ada.gov [https://perma.cc/U2V5-78KW]. For information on the availability of this material at NARA, visit www.archives.gov/federal-register/cfr/ibr-locations.html [https://perma.cc/9SJ7-D7XZ] or email fr.inspection@nara.gov. The material may be obtained from the World Wide Web Consortium (“W3C”) Web Accessibility Initiative (“WAI”), 401 Edgewater Place, Suite 600, Wakefield, MA 01880; phone: (339) 273-2711; email: contact@w3.org; website: https://www.w3.org/TR/2018/REC-WCAG21-20180605/ and https://perma.cc/UB8A-GG2F.
[AG Order No. 5919-2024, 89 FR 31337, Apr. 24, 2024, as amended by AG Order No. 6742-2026, 91 FR 20912, Apr. 20, 2026]
What § 35.200 Means in Practice
- Web content and mobile apps that state and local governments provide or make available must conform to WCAG 2.1 Level AA
- Public entities with a total population of 50,000 or more must comply by April 26, 2027 (extended from April 24, 2026 by DOJ's April 2026 interim final rule)
- Entities under 50,000 and all special district governments must comply by April 26, 2028. The deadline moved; the work didn't
- The rule covers content the entity provides through contractors and vendors, not just what it hosts itself
- This is the first time a specific technical standard has been written into ADA regulations
Common Questions
Does this apply to our internal employee systems?
This section covers public-facing web content and apps. Internal systems fall under employment provisions, though accessibility is good practice throughout.
We contract out our website — are we still responsible?
Yes. You are responsible for the accessibility of services you provide to the public, even through contractors. Include accessibility requirements in all contracts.
Does § 35.200 apply to your entity?
You don’t need to fix everything today. You need to know what matters first. We’ll help you find it.
Prefer to talk it through? Call the Title II Line: (608) 960-8830