ADA Title II: What the 2026 Deadline Means for Your Organization

On April 24, 2024, the Department of Justice published its final rule under Title II of the Americans with Disabilities Act, establishing specific technical standards for state and local government web content and mobile applications.

What the rule requires

All state and local government entities must ensure their websites and mobile apps conform to **WCAG 2.1 Level AA** by **April 24, 2026** (for entities serving populations of 50,000+) or **April 24, 2027** (for smaller entities).

This includes:

• •- Official government websites
• •- Online services and portals
• •- Mobile applications
• •- Web-based documents (PDFs, forms)
• •- Third-party content hosted on government platforms

Who is affected

Title II covers **all state and local government entities**, including:

• •- City and county websites
• •- State agency portals
• •- Public school district websites
• •- Public university systems
• •- Public libraries
• •- Courts and judicial systems
• •- Public transit authorities
• •- Parks and recreation departments

Key requirements

**WCAG 2.1 Level AA** includes 50 success criteria across four principles:

1. **Perceivable** — Content must be presentable in ways all users can perceive (alt text, captions, contrast, resizable text)
2. **Operable** — Interface must be operable by all users (keyboard accessible, no seizure-inducing content, navigable)
3. **Understandable** — Content and interface must be understandable (readable, predictable, input assistance)
4. **Robust** — Content must be robust enough to work with current and future assistive technologies

Limited exceptions

The rule provides narrow exceptions for:

• •- Archived web content not updated after the compliance date
• •- Pre-existing conventional electronic documents (unless they relate to accessing government services)
• •- Third-party content not under the entity's control
• •- Password-protected course content at postsecondary institutions (with accommodations)

Enforcement

Non-compliance can result in:

• •- DOJ enforcement actions and consent decrees
• •- Private lawsuits under Title II
• •- Loss of federal funding
• •- Complaints filed with the Office of Civil Rights

How to prepare

1. **Audit your current state** — Run a comprehensive WCAG 2.1 AA audit across all web properties
2. **Prioritize critical services** — Focus first on high-traffic pages and essential government services
3. **Remediate systematically** — Address critical and high-severity violations first
4. **Document your efforts** — Maintain audit trails, VPATs, and remediation records
5. **Monitor continuously** — Set up recurring scans to catch regressions
6. **Train your team** — Ensure content creators and developers understand accessibility requirements

Access Audit provides all of these capabilities in a single platform — from automated scanning to manual testing workflows to compliance documentation.