If you run or build websites for a US state, a county, a city, a public school district or a public university, there is a federal rule with your name on it. This post summarises what it says as of 1 October 2026. It is not legal advice, and the rule's own text and the DOJ's guidance are the authority, so we link to both.
The rule in one sentence
The Department of Justice's final rule under Title II of the Americans with Disabilities Act says, in the DOJ's words: "WCAG 2.1, Level AA is the technical standard for state and local governments' web content and mobile apps."
It was published in the Federal Register on 24 April 2024 (89 FR 31320) and took effect on 24 June 2024.
The deadlines moved in April 2026
The original compliance dates were 24 April 2026 for larger entities and 26 April 2027 for smaller ones. On 20 April 2026, the Federal Register published an interim final rule extending them. The current dates, as listed by the DOJ at ada.gov:
- Population of 50,000 or more: 26 April 2027
- Population of 0 to 49,999: 26 April 2028
- Special district governments: 26 April 2028
Population means the total population of the state or local government entity. Many articles written before April 2026 still quote the old dates; if you see "April 2026", the source is out of date.
Who is covered
Title II covers state and local governments and their departments, agencies and other instrumentalities. That reaches further than many people expect: public schools and universities, courts, transit authorities, public hospitals and libraries all fall under it. Content that a government provides through a contractor, such as a payments portal or a booking system, counts as the government's content.
The five exceptions
The rule lists five kinds of content that don't have to meet WCAG 2.1 AA, each with conditions:
- Archived web content
- Preexisting conventional electronic documents
- Content posted by a third party (unless it is posted through a contractual or other arrangement with the government)
- Individualised documents that are password-protected
- Preexisting social media posts
Each exception has limits. For example, archived content has to meet specific conditions, such as being kept only for reference and not changed since it was archived, and a preexisting document stops being exempt if people need it to apply for or use a current service. Read the DOJ's fact sheet before relying on any of them.
What to do between now and the deadline
- Inventory first. List the sites, subdomains, apps and document libraries you're responsible for, including third-party systems you pay for.
- Test against WCAG 2.1 AA, not 2.2 and not "best effort". Automated scans find a useful share of the failures quickly; the rest needs manual testing.
- Fix templates before pages. One fix to a site header or a form component often clears hundreds of findings.
- Put accessibility into procurement. Ask vendors for an Accessibility Conformance Report (a filled-in VPAT) and contract terms that require fixes.
- Publish a way to report barriers, and answer those reports.
AccessiSight has a Title II profile that filters reports to WCAG 2.1 AA and generates a Title II VPAT edition. It can show you where you stand; it can't tell you whether an exception applies to a particular document. That's a legal question.
Sources: ADA.gov: fact sheet on the web accessibility rule and the Federal Register notice of the final rule.