Plain-English guide
The DOJ Web Accessibility Deadline, in Plain English
What the Title II rule requires, when it applies to you, and what "conformance" actually means.
What the rule is
Title II of the Americans with Disabilities Act has applied to state and local governments since 1990, and the Department of Justice has long taken the position that it covers websites. What changed is specificity: in 2024, DOJ published a formal rule that names an exact technical standard and exact compliance dates for web content and mobile apps. Before this rule, "accessible" was open to interpretation. Now it is defined.
The rule covers public entities: school districts, cities, counties, townships, public colleges and universities, public libraries, courts, transit agencies, and other state and local government bodies. It applies to the web content those entities make available to the public, whether the entity built the website itself or pays an outside vendor to build and host it.
One note on dates: DOJ has updated the rule's compliance timeline since the rule first published, so older articles may cite earlier dates. The dates below reflect the current timeline.
The two deadlines
Population 50,000 or more
April 26, 2027
Larger cities, counties, and school districts serving a population of 50,000 or more must conform to WCAG 2.1 AA by this date.
Under 50,000, and special districts
April 26, 2028
Smaller entities (population under 50,000) and all special district governments, regardless of size, must conform by this date.
Which deadline applies to you
The dividing line is population, based on the most recent decennial Census:
- A city, county, or town uses its own Census population.
- A public school district uses the population of the area it serves, not its enrollment. A district with 4,000 students can still serve a community of 60,000 people and fall under the earlier 2027 date.
- Special district governments (for example park districts, library districts, water and sanitation districts, and transit authorities) get the 2028 date regardless of population.
Two practical cautions. First, enrollment is not the test for schools, so do not assume a small student body means the later date. Second, edge cases exist (joint agencies, regional service centers, entities whose service area is hard to define), and the determination has legal weight. If your entity is anywhere near the line, this is a question for your counsel, not a guess.
The standard is WCAG 2.1, Level AA
The rule's technical standard is the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA. WCAG is the internationally recognized standard for accessible web content, written by the W3C, the body that maintains web standards. "Level AA" means the rule requires everything in Level A (the baseline) plus everything in Level AA (the widely adopted mid tier). In practice that covers things like:
- text alternatives for images, so screen reader users know what a picture shows;
- sufficient color contrast between text and its background;
- pages that work with a keyboard alone, without a mouse;
- captions for videos;
- headings, labels, and link text that make sense and are announced correctly; and
- forms a screen reader user can understand and complete.
A newer version, WCAG 2.2, exists, and testing against it is reasonable and forward-looking. But the rule's legal benchmark is 2.1 AA, so that is the version to cite in planning documents and vendor contracts.
What "conformance" actually means
Conformance means the web content your entity makes available to the public meets WCAG 2.1 AA. A few points that surprise people:
- It covers more than your homepage. The rule reaches your whole public site, plus mobile apps, plus documents you post, including PDFs. A newsletter PDF or board packet uploaded to the site is web content.
- It is ongoing, not one-time. The deadline is when conformance begins, not when it ends. School and government sites change constantly, and a page that was fine in April can pick up new issues in May. Whatever process you build has to keep working after the deadline passes.
- Vendor-built does not mean vendor-responsible. Under Title II, responsibility for a public entity's website stays with the entity, even when an outside vendor builds and hosts it. Your vendor may be contractually obligated to help, and a good one will, but the legal obligation to the public is yours.
The rule does contain a small set of exceptions, for things like archived web content, certain preexisting documents, and certain third-party content. They are written narrowly and each has conditions attached. Whether any exception actually applies to specific content on your site is exactly the kind of question to put to your counsel rather than answer from a summary, including this one.
What happens after the deadline
After your compliance date, web content that does not conform to WCAG 2.1 AA can be the basis of an ADA Title II complaint or enforcement action. For schools, complaints commonly go to the U.S. Department of Education's Office for Civil Rights (OCR); complaints can also go to DOJ, and individuals can bring lawsuits under Title II. Anyone can file a complaint, including a parent, a resident, or an advocacy group, and there is no requirement that they warn you first.
None of that is a reason to panic, and this page is not going to quote you scary numbers. It is a reason to start early, because the entities that struggle are usually the ones that discovered the problem with months left instead of years.
A sensible way to start
You do not need to commit to anything to find out where you stand. A reasonable first sequence looks like:
- Confirm your date. Establish with your counsel whether you are a 2027 or a 2028 entity.
- Get a factual baseline. Run an automated scan to see what is actually on your site today: missing alt text, low-contrast text, unlabeled forms, inaccessible PDFs. Automated testing cannot find every barrier, but it finds the most common ones fast and gives you a concrete list.
- Sort the list by who fixes it. Some issues live in content your staff posts and can be fixed in your CMS today. Others live in the template and belong with your website vendor.
- Plan for after the deadline. Decide how new content will be checked on an ongoing basis, since the obligation does not end in 2027 or 2028.
If you want that baseline without installing anything or talking to a salesperson, we offer a free accessibility audit of your site: real pages, real findings, each with a screenshot, in plain English. It is a factual snapshot of where your site stands today, and it is yours whether or not you ever pay us anything.