The DOJ's Title II web accessibility rule

  • accessibility
  • ada
  • title-ii
  • wcag
  • government
  • higher-education

Updated

Under a Department of Justice rule published on April 24, 2024, state and local governments must make their websites and mobile apps meet WCAG 2.1 Level AA. That covers cities, counties, school districts, public colleges and universities, public libraries and hospitals, and special districts. In April 2026 the DOJ extended the deadlines by a year: April 26, 2027 for entities serving 50,000 people or more, and April 26, 2028 for smaller ones and special district governments. This isn't legal advice; check ADA.gov for the current rule.

Who it covers

The rule applies to public entities under Title II of the ADA. The DOJ's guidance names state and local governments, counties and municipalities, school districts, special district governments (such as utility, transit, and water districts), public schools and universities, public hospitals, county libraries, and police departments. Content that their contractors and vendors post for them usually has to meet the standard too.

Private businesses and private colleges fall under Title III instead, which has no equivalent technical rule. See ADA website compliance checklist.

The standard: WCAG 2.1 AA

WCAG (Web Content Accessibility Guidelines) 2.1 Level AA is a published set of testable requirements: text alternatives for images, captions for video, enough color contrast, full keyboard access, labeled form fields, clear headings, and more. It applies to web pages, documents posted on them, and mobile apps.

Compliance dates

Size of the public entity Compliance date
Total population of 50,000 or more April 26, 2027
Total population under 50,000 April 26, 2028
Special district governments April 26, 2028

These dates come from the DOJ's Interim Final Rule published on April 20, 2026, which moved each deadline back one year from the original April 24, 2026 and April 26, 2027. The DOJ also notes that, whatever the compliance dates, public entities already have an ongoing obligation to make their online services accessible.

Sources: ADA.gov, Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps, Federal Register, Extension of Compliance Dates (April 20, 2026).

Exceptions

The rule has five exceptions, each with conditions:

  • Archived web content: created before the compliance date (or copied from older paper or media), kept only for reference, research, or recordkeeping, kept in a special archive area, and not changed since.
  • Preexisting conventional electronic documents: PDFs, word processing files, presentations, and spreadsheets posted before the compliance date. ADA.gov says these "usually" don't need to meet WCAG 2.1 AA, "except in some situations".
  • Content posted by third parties, such as public comments. Content posted by your own contractors or vendors isn't covered by this exception.
  • Individualized, password-protected documents about a specific person, property, or account, such as a utility bill.
  • Social media posts made before the compliance date.

Read the conditions on ADA.gov before relying on any of them, especially for documents people still use, such as application forms.

Where to start

The DOJ's own first steps, in short:

  1. Find your compliance date from your population.
  2. Name who's responsible, and train the people who publish content.
  3. List all your web content, documents, and apps, including what vendors run for you.
  4. Test against WCAG 2.1 AA, and fix the most-used and highest-impact pages first.
  5. Check vendor contracts so new purchases meet the standard.
  6. Write an accessibility policy and a way for people to report problems.

Source: ADA.gov, First Steps Toward Complying with the Title II Web and Mobile Application Accessibility Rule.

If your site runs on Dirigible

Accessibility audit, in Dirigible → Tools & Maintenance, checks your pages against WCAG, including at phone width, and lists what to fix. Automated checks are a first pass, not proof of compliance. See Content gardening tools. For a page-by-page checklist, see ADA website compliance checklist.

With a deadline in 2027 or 2028, a large site, or many PDFs, it's worth bringing in an accessibility specialist early to audit the site and plan the fixes, since remediating documents and rebuilding templates takes longer than most teams expect. This isn't legal advice.