Government &
Public-Sector Accessibility
The DOJ's 2024 ADA Title II final rule formally requires WCAG 2.1 AA for state and local government websites and apps, with hard, population-based deadlines. Federal agencies and their contractors have their own separate requirement under Section 508.
Larger state and local governments (extended from April 24, 2026 by the DOJ's April 2026 interim final rule)
Smaller governments and special district governments (extended from April 26, 2027)
Set by the DOJ's Title II final rule, published April 24, 2024 and effective June 24, 2024
Section 508 vs. ADA Title II
Two different laws cover two different parts of government. Knowing which applies to your organization tells you which deadline and technical bar you're working against.
Federal Agencies & Contractors
Requires all U.S. federal agencies to make electronic and information technology accessible. The level required is WCAG 2.0 AA plus additional technical requirements, documented via VPAT for procurement.
State & Local Governments
The DOJ's 2024 final rule requires WCAG 2.1 AA for state and local government websites and apps, on a population-based deadline schedule.
How We Got Here
Americans with Disabilities Act signed into law. Covers physical places of public accommodation.
A DOJ letter to Senator Tom Harkin says Titles II and III of the ADA cover web communications. First signal of digital scope.
DOJ issues web accessibility guidance pointing to WCAG and Section 508 as helpful references, without setting a mandatory standard.
Final rule requires WCAG 2.1 AA for state and local government websites and apps (effective June 24, 2024; compliance dates now 2027-2028).
Common WCAG Failures on Government Sites
The same failure types that dominate ADA Title III litigation show up constantly in government digital services, often in forms citizens have no alternative but to use.
Missing form labels on permit & benefits applications
1.3.1 / 4.1.2 · AMissing alternative text on maps, forms, and public notices
1.1.1 · AKeyboard-inaccessible online portals and payment systems
2.1.1 · AUntagged PDF agendas, minutes, and public records
Frequently Asked Questions
What is the DOJ ADA Title II final rule?
Published April 24, 2024 and effective June 24, 2024, the rule formally requires WCAG 2.1 AA for state and local government digital content. A DOJ interim final rule published April 20, 2026 extended the compliance dates: governments serving a population of 50,000 or more now have until April 26, 2027, and smaller governments and special district governments until April 26, 2028. Only the dates changed, not the WCAG 2.1 AA standard. An inaccessible site can still draw ADA complaints or lawsuits before those dates.
Does Section 508 or ADA Title II apply to my agency?
Section 508 of the Rehabilitation Act applies to U.S. federal agencies and the technology they build or buy (which is why contractors are asked for VPATs), requiring WCAG 2.0 AA plus additional technical requirements, documented through a VPAT for procurement. ADA Title II applies to state and local governments (a broader population than federal agencies alone) and now requires WCAG 2.1 AA under the DOJ's 2024 final rule.
What's the deadline for small vs. large local governments?
Under the DOJ's Title II rule, as amended by an interim final rule published April 20, 2026, government entities serving a population of 50,000 or more must comply by April 26, 2027. Smaller governments (population under 50,000) and special district governments have until April 26, 2028. The original dates were April 24, 2026 and April 26, 2027.
Do government PDFs and online forms need to be accessible?
Yes. Permit applications, benefits forms, public notices, and agendas distributed as PDFs are in scope under both Section 508 and the ADA Title II final rule. An inaccessible PDF is treated like an inaccessible web page, subject to the Title II rule's limited exceptions (such as archived content and some documents posted before the compliance date that are no longer used).
We already meet WCAG 2.0 AA under Section 508. Is that enough for Title II?
Not on its own. The 2024 Title II final rule specifically requires WCAG 2.1 AA, which is a superset of 2.0 AA: it adds newer success criteria covering mobile, orientation, and additional input methods. Meeting only the older 2.0 AA baseline will leave real gaps against the current rule.
Not legal advice. This guide is educational and does not constitute legal advice. Consult your agency's counsel to confirm which deadline and standard applies to your specific entity.
Check Your Title II Readiness
AccessiSight scans your public-facing sites against WCAG 2.1 AA, tracks progress toward your population's deadline, and generates a Section 508 or ADA Title II VPAT.