City and county libraries, library districts, consortia
ADA Title II Website Accessibility for Public Libraries
Last updated June 11, 2026
Libraries exist to give everyone access to information. The ADA Title II web rule asks libraries to live that mission online: the catalog, the ebook apps, the event calendar, and the digitized collections all need to meet WCAG 2.1 Level AA. Here is what that means for your library and where to begin.
Why Title II Applies to Your Library
Almost every public library in America is a public entity. City and county libraries are departments of their parent government. Independent library districts are special purpose districts, which Title II covers by name. Either way, the library's services, programs, and activities fall under 28 CFR Part 35, Subpart H, the web accessibility rule, regardless of the library's size or budget.
The twist for libraries is how much of your digital presence is rented rather than built. Your catalog, your ebook platform, your event software, and your databases all come from vendors. The rule is blunt about this: content you provide or make available through contractual or licensing arrangements is covered. A patron who cannot search Libby with VoiceOver has been denied a library service, and the responsibility under the ADA sits with the library, not with the app's developer.
Patrons with disabilities are also disproportionately your heaviest digital users. People with print disabilities rely on ebooks and audiobooks. People who cannot drive rely on online renewal and holds. When the digital branch fails them, there is often no workaround.
What Library Web Content Is Covered
- The catalog and discovery layer. OPAC search, holds, renewals, and account management, whether self-hosted or run by a vendor like BiblioCommons or through a consortium
- Ebook and streaming platforms. OverDrive and Libby, hoopla, Kanopy, Freegal. You license them, you make them available, the rule covers them
- Research databases. EBSCO, Gale, Ancestry Library Edition, language-learning tools. Same logic as ebooks: licensed services are library services
- Event calendars and registration. Storytime signups, summer reading programs, author talks. If registering requires a mouse, the program is not open to everyone
- Room booking and museum passes. Meeting room reservations, study room booking, equipment lending, and pass reservation systems
- Library card applications and forms. Online card signup, interlibrary loan requests, purchase suggestions, volunteer applications
- Digitized collections and local history. The interfaces, finding aids, and exhibit pages are covered. The scanned historical items themselves may qualify for the archived content exception, with conditions
Your Deadline
It depends on what kind of library you are. A library that is a department of a city or county shares its parent government's date: April 26, 2027 if the population is 50,000 or more, April 26, 2028 if it is under 50,000. An independent library district is a special district government, and all special districts have until April 26, 2028 no matter how many people they serve.
Consortium members should not assume the consortium is handling it. Each member library remains responsible for the services it provides through shared systems. Confirm your date on the deadlines page.
The Exceptions That Matter Most for Libraries
- Archived web content. The most useful exception in the building. Digitized newspapers, photo collections, and old annual reports can remain as-is if they are kept for reference, research, or recordkeeping, stored in a clearly identified archive area, and left unaltered. The search tools around them still have to work for everyone
- Preexisting conventional electronic documents. PDFs and similar files posted before your compliance date are excepted, unless patrons currently need them to apply for or access services. An old book club flyer qualifies. The current meeting room policy PDF does not
- Third-party content. Reviews patrons post in your catalog and comments on your blog are not your obligation. Vendor platforms you license are not third-party content in this sense. They are covered
- Preexisting social media posts. Your decade of Facebook event posts does not need remediation. New posts should be accessible from here forward. The conditions for all of these live in § 35.201
Three Ways to Start This Quarter
- Map the digital branch. List every system a patron can touch: website, catalog, ebook apps, databases, calendar, room booking, wifi splash page. Note which vendor owns each and when the contract renews. The compliance checklist turns this into a working document
- Request accessibility conformance reports. Email every vendor on that list and ask for a current ACR or VPAT against WCAG 2.1 AA. The replies tell you which vendors are partners and which are risks, before renewal season
- Keyboard-test your top five patron tasks. Search the catalog, place a hold, register for an event, book a room, apply for a card, using only the Tab and Enter keys. Whatever breaks goes to the top of the fix list. First steps shows you the full sequence
Library Questions
Is our library catalog (OPAC) covered by the ADA web rule?
Yes. The catalog is how the public finds and requests your collection, which makes it a core service. Whether it runs on Polaris, Sierra, Koha, or a hosted discovery layer like BiblioCommons, it must meet WCAG 2.1 AA by your deadline. Hosting by a vendor does not change your responsibility.
What about OverDrive, Libby, hoopla, and other ebook platforms?
Platforms you license to deliver library services are covered because you provide them, even though a vendor builds them. Ask each vendor for a current accessibility conformance report, put WCAG 2.1 AA in renewals, and have a plan for patrons who hit barriers in the meantime.
Do we have to remediate our digitized historical collections?
Often no. Digitized newspapers, photographs, and manuscripts kept for reference or research typically qualify as archived web content if they are kept in a dedicated archive area and not updated. But the finding aids, search interfaces, and pages around them are not archived, and a scanned document a patron currently needs to access a service loses the exception.
Which deadline applies to our library?
If the library is a department of a city or county, you share that government's deadline: April 26, 2027 if its population is 50,000 or more, April 26, 2028 if under. If you are an independent library district, you are a special district government and have until April 26, 2028 regardless of population.
Our website is run by a small staff with no developer. Where do we start?
Start with the pages patrons use to get services: the catalog search, the events calendar, room and museum pass booking, and the library card application. Test those with a keyboard, fix the templates, and push your vendors on the rest. You do not need a developer to make most content fixes in a modern CMS.
How accessible is your digital branch?
An assessment of your website, catalog, and key vendor platforms tells you exactly where patrons get stuck, what to fix yourself, and what to demand from vendors at renewal.