📋 GRC compliance for CMMC 2.0, CPCSC, CPA Canada, IIROC…SaaS discovery for data governanceFree enriched web chat widget🚀 Enriched remote support without your laptop

Government & public sector

ADA Title II web & mobile accessibility

Conform to WCAG 2.1 Level AA · deadlines April 26, 2027 and April 26, 2028

The Department of Justice rule, published April 24, 2024 under Title II of the Americans with Disabilities Act, requires the web content and mobile apps of state and local governments to meet WCAG 2.1 Level AA. An interim final rule on April 20, 2026 extended the deadlines: April 26, 2027 for a population of 50,000 or more, and April 26, 2028 for smaller entities and for special district governments regardless of population.

Assess ADA Title IISee the deadlines

What are the deadlines?

Two dates, set by which kind of entity you are, not by when you start. The interim final rule of April 20, 2026 moved the original deadlines to these, so read the date against your population and your type.

Public entityCompliance date
Serving a population of 50,000 or moreApril 26, 2027
Serving a population under 50,000April 26, 2028
Special district governments (any population)April 26, 2028

The standard is the same for everyone on both dates: WCAG 2.1 Level AA. Only the deadline moves.

What does it actually cover?

This is broader than a website, and the surprises are usually the systems a city thinks of as separate products.

It reaches the online payment portal, the permit and licensing system, the agenda and minutes packets you publish as PDFs, the council meeting video, the parks and recreation registration system, and any mobile app the entity offers. That includes apps a vendor operates on your behalf. Vendor-hosted does not mean vendor-owned as a compliance matter: the obligation stays with the public entity, so accessibility conformance belongs in the vendor contract, not just in your own web team's backlog.

Who enforces it, and what is the real risk?

Enforcement runs two ways: a complaint to the Department of Justice, and a private lawsuit. For a city, the practical exposure is the second one.

The demand letter that precedes a private suit is where most of the cost and disruption starts. The work to conform is real, but it is bounded and plannable, and it is far cheaper to do before the deadline than to do under a demand letter after it. Treating the date as a project rather than a surprise is the whole difference.

How Lavawall® helps you evidence ADA Title II

Lavawall gives you an ADA Title II assessment split the way the rule is: one track for entities serving 50,000 or more (due April 26, 2027) and one for smaller entities and special districts (due April 26, 2028). It walks the WCAG 2.1 AA obligations across the properties that count — your site, your PDFs, your portals, and vendor-run apps — records where each stands, and keeps that evidence current, so a complaint or a demand letter meets a documented program instead of a scramble.

  • Assess against WCAG 2.1 AA on the track that matches your population and entity type.
  • Track vendors so the accessibility obligation that stays with you is written into the contracts where the work actually happens.
  • Evidence your conformance and remediation with timestamped records, dated against the April 2027 and April 2028 deadlines.

Related

Primary source: the U.S. Department of Justice, ADA Title II web and mobile accessibility rule. Last verified August 27, 2026.

Frequently asked questions

When does ADA Title II web accessibility take effect?

Two dates. April 26, 2027 for public entities serving a population of 50,000 or more, and April 26, 2028 for smaller entities and for special district governments regardless of population. An interim final rule on April 20, 2026 extended the original deadlines to these.

What standard do we have to meet?

WCAG 2.1 Level AA. The Department of Justice rule, published April 24, 2024 under Title II of the Americans with Disabilities Act, requires the web content and mobile applications of state and local governments to conform to that standard.

Does it cover PDFs, videos, and vendor-run apps?

Yes. It reaches the online payment portal, the permit and licensing system, agenda and minutes packets published as PDFs, council meeting video, registration systems, and any mobile app offered on the entity's behalf. Vendor-hosted does not mean vendor-owned: the obligation stays with the public entity, so it belongs in the contract.

We are a special district. Which deadline applies?

April 26, 2028, regardless of the population you serve. The 50,000 threshold that sets the earlier date applies to general-purpose public entities, not to special district governments.

Who enforces this and what is the real exposure?

Enforcement is by complaint to the Department of Justice and by private lawsuit. For a city, the practical exposure is the private lawsuit and the demand letter that precedes it. The work is bounded, and it is far cheaper before the deadline than after a demand letter arrives.

Did the compliance deadline change?

Yes. An interim final rule on April 20, 2026 extended the original dates. They now stand at April 26, 2027 for populations of 50,000 or more and April 26, 2028 for smaller entities and special districts.