In April 2026, four days before the first compliance deadline was due to take effect, the U.S. Department of Justice issued an Interim Final Rule extending the ADA Title II website accessibility deadlines by one year. If your city paused its accessibility work in response, that was the wrong read. The extension moved one date and nothing else.
Here is what actually changed, what did not, and what a city should be doing between now and the new deadline.
The Current Deadlines
| Entity type | Original deadline | Current Deadline |
|---|---|---|
| State and local governments with population 50,000 or more | April 24, 2026 | April 26, 2027 |
| State and local governments with population under 50,000 and special district governments | April 24, 2027 | April 26, 2028 |
Population is based on the most recent decennial census. Cities near the 50,000 line should confirm their official count rather than estimate; the difference is a full year of runway. Special district governments (water, library, transit, fire) fall in the 2028 group regardless of the population they serve.
One point worth flagging for anyone reading the extension as a reprieve: in the Interim Final Rule, the DOJ stated that it fully anticipates implementing the regulation at the new deadline. Legal commentators have read that as a deliberate signal that enforcement is coming, not receding. The public comment period on the interim rule closed on June 22, 2026.
The standard is WCAG 2.1 Level AA
The DOJ published its Title II final rule on April 24, 2024, adopting Web Content Accessibility Guidelines 2.1 Level AA as the technical standard for web content and mobile applications. The rule took effect in June 2024. The 2026 extension changed only the compliance dates. The technical standard, the scope of covered content, and the substantive obligations remain unchanged.
This distinction matters when you are evaluating vendors. WCAG 2.1 AA is the floor the regulation sets. Some platforms build to WCAG 2.2 AA, which is a later version of the same guidelines and a superset of most 2.1 criteria. Building to 2.2 is defensible and forward-looking, but a vendor who tells you the DOJ requires 2.2 has misread the rule. Ask which version they conform to and ask them to name the standard the regulation actually cites.
WCAG 2.1 AA covers text alternatives for images, captions for multimedia, keyboard operability, color contrast ratios, content that reflows in both portrait and landscape orientation, and compatibility with assistive technology such as screen readers.
What is expected
The rule does not require you to retroactively remediate everything your city has ever published. The exceptions are narrow but real:
- Archived web content
- Pre-existing conventional electronic documents not currently used to apply for or access a service
- Content posted by a third party, where that third party is not posting under a contractual, licensing, or other arrangement with the public entity
- Individualized, password-protected documents
- Pre-existing social media posts
Anything actively used to deliver a service: permit applications, tax payments, council agendas, emergency notifications, job postings must conform.
Where municipal websites actually stand
The scale of the gap is documented. AudioEye’s 2025 Digital Accessibility Index scanned nearly 35,000 pages across almost 800 government websites and found an average of 307 accessibility violations per page. Government sites performed worse on keyboard accessibility than any other industry measured, with 51% of pages containing keyboard navigation failures, a direct barrier for residents who cannot use a mouse or touchscreen.
Breaking that average down, the same index found government pages carried a mean of 75.4 color contrast violations, 15.3 images missing proper text descriptions, and 6.8 forms without clear labels. Route Fifty covered the findings when they were released.
A separate survey conducted by CivicPlus with the research organization CivicPulse, covering more than 1,000 local government officials, identified the practical obstacle: not awareness, but staff time, training, and budget. Most officials understand the requirement. Few have the capacity to meet it manually.
Litigation risk exists during the extension
This is the part most cities get wrong about the delay. What the Interim Final Rule postponed is narrow, the date on which conformance to WCAG 2.1 Level AA becomes specifically required by regulation. Title II’s underlying prohibition on disability discrimination has been in force for decades, and courts have supported web accessibility claims under it since long before any technical standard was codified.
In practical terms: a resident can bring a claim over an inaccessible city website today. They do not have to wait for April 2027. The extension bought planning time, not immunity.
A realistic sequence for cities
- Audit before you budget. You cannot scope remediation you have not measured. Run automated scanning across your site, mobile apps, and public-facing documents, then supplement with manual testing. Automated tools reliably catch contrast and alt-text issues but miss things like whether a keyboard user can actually complete a form.
- Triage by barrier severity, not by violation count. A single keyboard trap on your utility payment page matters more than two hundred contrast warnings in a footer. Sort by whether a resident can complete the task.
- Deal with your PDFs deliberately. For most cities this is the largest single body of non-conforming content: budget documents, agendas, minutes, permit forms. Decide which fall under the archived-content exception and which are actively used for services, because the second group needs remediation or replacement with accessible HTML.
- Publish an accessibility statement and a complaint process. Documented good-faith effort is meaningful both to regulators and to residents, and it gives people a route to report problems you missed.
- Make it continuous. Accessibility regresses. Every new page, plugin update, and third-party embed can reintroduce violations. A one-time remediation project that ends at launch will be out of conformance within a year.
- Check your state’s rules. Several states impose requirements beyond the federal floor, sometimes with earlier dates and broader document scope. Confirm with your state before assuming the DOJ timeline is the only one that applies.
Frequently Asked Questions
What is the ADA Title II compliance deadline for city websites?
April 26, 2027 for state and local governments with a population of 50,000 or more, and April 26, 2028 for those under 50,000 and for special district governments. Both dates reflect the one-year extension the DOJ issued by Interim Final Rule in April 2026.
Which accessibility standard does the rule require?
WCAG 2.1 Level AA. The DOJ incorporated it by reference in the final rule published April 24, 2024, and the 2026 extension did not change it. WCAG 2.2 AA is a later version that exceeds the requirement; it is not itself the requirement.
Does the extension mean we can pause accessibility work?
No. Title II’s general prohibition on disability discrimination is already in force and independent of the rule’s compliance dates. Claims can be brought during the extension period. The DOJ has also stated it fully anticipates implementing the regulation at the new deadline.
Does every document on our website have to be remediated?
No. The rule excepts archived content, pre-existing conventional electronic documents not used for current services, third-party content posted outside a contractual arrangement, individualized password-protected documents, and pre-existing social media posts. Content actively used to deliver services must conform.
Do special districts have to comply?
Yes. Special district governments — water, library, transit, fire — fall under the April 26, 2028 deadline regardless of the population they serve.
We can help you with your city’s compliance before the deadline. Reach out to our agency so we can create a plan together.
This article is general information, not legal advice. Confirm your city’s obligations with your attorney and your state’s accessibility office.
