Reviewed September 30, 2026
DOJ Title II, updated April 20, 2026
Title II website and app deadlines
State and local government websites and mobile apps have to meet WCAG 2.1 Level AA. On April 20, 2026 the Department of Justice extended the compliance dates. Governments with a total population of 50,000 or more have until April 26, 2027. Governments under 50,000, and any special district, have until April 26, 2028.
Who do the dates apply to?
Title II covers states, counties, cities, towns, public schools and universities, courts, elections offices, public hospitals, libraries, transit agencies, and special districts. A contractor that provides the service for the government has to meet the same standard. A county parks page written by an outside firm is still the county’s web content.
Private stores, hotels, and clinics are Title III. This rule does not set their technical standard. The fact sheet is on ADA.gov.
What does “meet WCAG 2.1 Level AA” mean?
The rule names WCAG 2.1 Level AA, not a scanner score. A government may use a newer standard, including WCAG 2.2, when it provides at least the same access. That is the rule’s equivalent-facilitation provision. The differences are on the WCAG 2.1 versus 2.2 page. Level AA includes the Level A criteria. Contrast, captions, keyboard access, labels, and names are all in scope. A passing automated score that never checked the keyboard path is not conformance.
What should be fixed before the date?
- Pages people use now: benefits, courts, schools, payments, and meetings.
- PDFs and images that carry the information, not only the HTML around them.
- Mobile apps the government provides, including apps a vendor runs for parking or payments.
- Templates first. A fixed template covers every page built from it.
- Third-party content the public must use to complete the service, such as a payment or permit widget.
How should a government sequence the work?
Start with the templates and the tasks people cannot complete any other way: apply, pay, register, read a notice, attend a meeting. Document the success criterion for each failure so a later vendor can see what changed. Recheck after a redesign. The population threshold is the government’s total population, not the number of people who use one department’s site. Special districts use the later date regardless of size.
Questions and answers
When do state and local government websites have to meet WCAG 2.1 Level AA?
The DOJ fact sheet updated April 2026 says governments with a total population of 50,000 or more have until April 26, 2027. Public entities under 50,000, and any special district government, have until April 26, 2028. Source: https://www.ada.gov/resources/2024-03-08-web-rule/
Does the Title II web rule apply to private businesses?
No. Title II covers state and local governments, their departments, and special purpose districts. Private businesses open to the public are covered by Title III, which does not set WCAG 2.1 Level AA in a regulation the way this rule does.
Does the rule cover mobile apps and PDFs?
The rule covers web content and mobile apps the government provides, including apps a vendor runs for the government. Documents that carry the information, including PDFs, are web content when they are posted as the way to get the service.
Can a government use WCAG 2.2 instead of 2.1?
The rule names WCAG 2.1 Level AA. It allows a newer standard when that standard provides at least the same access. WCAG 2.2 Level AA includes every 2.1 Level AA criterion and adds more, so it satisfies that provision. Differences are at https://www.adasupport.org/wcag-2-1-vs-2-2
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