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ADA Title II

The deadline moved. The accessibility backlog did not.

The extended compliance dates give public entities more time, but websites, mobile apps, digital documents, forms, third-party platforms, and publishing workflows still need to be inventoried, prioritized, and remediated. 508 Audit helps agencies build a practical accessibility roadmap based on service impact, risk, and available resources.

Deadlines

The dates and the standard.

  • April 26, 2027

    Public entities, other than special district governments, with a total population of 50,000 or more

  • April 26, 2028

    Public entities with a total population of less than 50,000, and any special district government

  • WCAG 2.1 Level AA

    The technical standard both deadlines are measured against

The rule

The interim final rule moved the dates. It did not change the obligation.

The Department of Justice interim final rule of April 20, 2026 revised the compliance dates for the Title II web and mobile accessibility requirements. The substance of the obligation — conformance with WCAG 2.1 Level AA — is unchanged, and the period before the deadline is the period in which the work has to be done.

What the rule covers

  • Web pages and web applications operated by or on behalf of the entity
  • Mobile applications offered to the public
  • Electronic documents, including PDFs, forms, spreadsheets, and presentations, where the rule's exceptions do not apply
  • Multimedia, including captions and audio description

The rule's exceptions are limited. They cover a narrow set of items such as archived content, certain pre-existing electronic documents, third-party content not posted by or for the entity, individualised password-protected documents, and some pre-existing social media posts. They do not cover the active content a resident uses to pay a bill, apply for a permit, read a board packet, or contact a department. The rule also recognises limits such as fundamental alteration and undue burdens, and permits conforming alternate versions only in limited circumstances. An audit shows where an entity stands against the standard; it does not by itself satisfy the rule, and it is not legal advice.

Which law

Which rule applies to you?

  • ADA Title II covers state and local governments, including their websites, mobile apps and electronic documents.
  • Section 508 covers the technology that federal agencies develop, buy and use.
  • Section 504 of the Rehabilitation Act covers organizations that receive federal financial assistance.
  • Documents count. PDFs, Word files and other conventional electronic documents that a public entity posts are covered by the Title II rule.

The package

What a Title II package includes

  • An audit and a prioritized remediation plan
  • An accessibility statement
  • An interim plan for providing equally effective alternative access while fixes are made
  • Staff training
  • A re-testing schedule

What it takes

What a small agency actually has to do.

  1. Baseline audit

    Manual WCAG 2.1 AA evaluation of a representative set of page templates and workflows, with assistive technology and screen reader testing.

    Conformance Audit scope and deliverables
  2. Prioritized defect register

    Every finding recorded against a success criterion, with the affected template, the evidence, and a severity ranking your team can work through in order.

    What the Conformance Audit produces
  3. Remediation

    Code and content fixes for the website, and remediation of the PDFs, forms, and presentations that automated tooling does not touch.

    Document Remediation scope
  4. Verification

    A re-test of the corrected items against the same criteria, so a closed defect is closed on evidence rather than on assertion.

    How verification rounds work
  5. Conformance report

    A conformance report with an evidence log that lets a buyer or auditor trace any claim back to a tested artifact. Evaluator and sign-off responsibilities are defined in the statement of work.

    Conformance reporting and ACRs
  6. Ongoing maintenance

    Quarterly re-test and report refresh across the defined scope, with defect register upkeep, so conformance does not lapse between releases.

    Ongoing Accessibility Maintenance

Work out where your agency stands before the deadline, not after it.

A short consultation covers your property inventory, your document volume, and the order the work should be done in.