ADA Title II Website Compliance: The Rule, Deadlines and What to Do

ADA Title II website compliance is now a fixed legal requirement for state and local governments, not just a best practice. In April 2024 the Department of Justice published a rule that, for the first time, sets a technical standard for public entities’ websites and mobile apps: WCAG 2.1 Level AA. In April 2026 it pushed the deadlines back by one year. If you run or build websites for a city, county, school district, public university, transit agency, court or special district, this guide explains what the rule requires, when it applies and how to get ready.

If you run a private business, Title II does not apply to you. See our guide to ADA Title III law for businesses instead.

Who ADA Title II Website Compliance Covers

Title II of the ADA covers state and local government entities, which the rule calls “public entities”. That includes:

• States, counties, cities, towns and their departments
• Public school districts, public colleges and universities
• Public libraries, parks and recreation departments, and public hospitals
• Transit agencies, courts and special district governments such as water or utility districts

The rule, in 28 CFR § 35.200, requires a public entity to make two things accessible:

1. Web content that it provides or makes available, directly or through contractual, licensing or other arrangements
2. Mobile apps that it provides or makes available, in the same way

The words “contractual, licensing or other arrangements” matter. A payment portal, a permit application, a class registration system or a library catalog run by a vendor is still your responsibility.

The Standard: WCAG 2.1 Level AA

The rule adopts the Web Content Accessibility Guidelines (WCAG) 2.1 at Level AA as the technical standard, according to the DOJ fact sheet on the web rule. That means meeting every Level A and Level AA success criterion in WCAG 2.1, such as text alternatives for images, captions for video, keyboard access, sufficient color contrast and labeled form fields.

WCAG 2.2 has since been published and adds criteria such as 2.5.8 Target Size (Minimum). The Title II rule names 2.1. WCAG 2.2 keeps almost every 2.1 requirement and adds new ones, so testing against 2.2 AA is a good way to meet the rule and stay ahead of it. The WCAG Library explains each criterion and how to test it.

ADA Title II Website Compliance Deadlines

The original rule gave public entities two or three years to comply. On April 20, 2026, the DOJ published an interim final rule in the Federal Register that extended both dates by one year:

The DOJ said it extended the dates so public entities have enough time to make their web content and mobile apps accessible. The underlying duty under the ADA to make services accessible to people with disabilities did not pause, so the extra year is time to finish the work, not a reason to start later.

The Five Exceptions in the Title II Rule

The rule, in 28 CFR § 35.201, lists five kinds of content that do not have to meet WCAG 2.1 AA:

1. Archived web content. Content created before the compliance date (or reproducing older paper documents), kept only for reference, research or recordkeeping, stored in a special archive area, and not changed since it was archived. All four conditions must be true.
2. Preexisting conventional electronic documents. PDFs, word processing files, presentations and spreadsheets posted before the compliance date, unless they are currently used to apply for, access or take part in a service, program or activity. A 2019 permit form people still fill out is not exempt.
3. Content posted by a third party. Such as comments from the public, unless the third party is posting on your behalf under a contract, license or other arrangement.
4. Individualized documents that are password-protected or otherwise secured. Such as a resident’s own utility bill or tax statement. The portal that delivers them still has to be accessible.
5. Preexisting social media posts. Posts made before the compliance date.

Exceptions do not remove your other ADA duties. The DOJ fact sheet is clear that public entities must still provide effective communication, reasonable modifications and an equal opportunity to participate. If a blind resident asks for their password-protected water bill, for example, you still have to give it to them in a form they can use, such as large print or an accessible version.

Other Parts of the Rule Worth Knowing

The rule has three more provisions that come up in practice:

• Conforming alternate versions (§ 35.202). A separate accessible version of content is allowed only where making the original accessible is not possible because of technical or legal limits. It is not a shortcut for content that is simply hard to fix.
• Fundamental alteration and undue burdens (§ 35.204). If full compliance would fundamentally change a service or cause undue financial and administrative burdens, you must still comply as far as possible. The head of the entity, or their designee, must make that decision in writing after considering all available resources.
• Noncompliance with minimal impact (§ 35.205). An entity that is not fully compliant can still be treated as meeting the rule if it can show the gaps are so minor that people with disabilities can still access the same information, interactions and transactions as everyone else. This is a narrow defense, not a plan.

Common ADA Title II Website Compliance Problems

Government websites tend to fail in the same places. When you start testing, look at these first:

• PDF forms and notices. Applications, permits, meeting agendas and budget documents are often scanned images or untagged PDFs that a screen reader cannot read. Anything posted after your compliance date, and any older document people still use to get a service, must meet WCAG 2.1 AA.
• Meeting and event videos. Recorded council or board meetings need accurate captions under 1.2.2 Captions (Prerecorded). Live streams need live captions at Level AA.
• Third-party systems. Payment portals, utility billing, parks reservations and job application systems are often run by vendors and are often where people with disabilities get stuck.
• Forms without labels. Contact, request and complaint forms that rely on placeholder text instead of labels fail 3.3.2 Labels or Instructions.
• Maps and images of text. Flyers posted as images and maps with no text alternative leave out anyone who cannot see them. Provide the same information as text.
• Keyboard traps and menus. Mega menus, date pickers and pop-ups that only work with a mouse fail 2.1.1 Keyboard.

How to Prepare for ADA Title II Website Compliance

The DOJ’s own first steps for state and local governments start with knowing what you have. A practical plan looks like this:

1. Inventory your web content and apps. List every website, subdomain, mobile app and vendor system that the public uses, including payment, permit, booking and registration systems.
2. Test the most-used pages and services first. Run an automated scan with the free WCAG 2.1 AA Checker, then do manual checks with a keyboard, zoom and a screen reader. Our guide on how to check if your website is ADA compliant walks through the manual steps.
3. Check every PDF and document that people use to get a service. These are not covered by the preexisting-document exception. The free PDF Accessibility Checker checks tags, titles, language, alt text and form labels in your browser.
4. Ask vendors for accessibility evidence. Request an Accessibility Conformance Report (ACR) for each third-party system, and put WCAG 2.1 AA requirements into new contracts and renewals.
5. Set up an archive area for old content you want to keep under the archived-content exception, and stop editing anything you move there.
6. Fix, then keep monitoring. New pages, PDFs and posts are published every week. Each one added after your compliance date has to meet the standard.
7. Document your work. Keep a dated record of testing, fixes and decisions, including any written undue-burden determinations.

How AccessBell Helps With Title II Website Compliance

AccessBell helps public entities spot accessibility issues and fix them. It scans up to 500 URLs per domain against WCAG 2.1 or 2.2 AA, rescans on a schedule with continuous monitoring, shows the failing code with a fix for each issue, and finds and checks the PDFs linked from your pages. The Compliance Vault keeps a dated record of every scan and fix that you can export for your ADA coordinator, auditor or attorney.

No tool can make a website 100% compliant on its own, because some WCAG requirements need a person to check them. See how the government accessibility checker is set up for public entities, or run a free scan of your home page to see where you stand today.

Frequently Asked Questions

What is the ADA Title II website compliance deadline?

After the April 2026 interim final rule, state and local governments with a total population of 50,000 or more must comply by April 26, 2027. Entities with a population under 50,000, and all special district governments, must comply by April 26, 2028.

What standard does the Title II rule require?

WCAG 2.1 Level AA, for both web content and mobile apps that a public entity provides or makes available, including through contractors and vendors.

Does the Title II rule apply to private businesses?

No. Title II covers state and local governments. Private businesses open to the public fall under Title III, which has no website regulation that names a technical standard, although WCAG 2.1 AA is the benchmark used in practice.

Do old PDFs on a government website have to be made accessible?

Not always. PDFs and other documents posted before the compliance date are exempt unless they are currently used to apply for, access or take part in a service, program or activity. Documents posted after the compliance date must meet WCAG 2.1 AA.

Does a vendor-hosted payment or booking system count?

Yes. The rule covers web content and mobile apps a public entity provides directly or through contractual, licensing or other arrangements, so a third-party system you pay for is part of your responsibility.