The ADA Title II deadline. April 26, 2027. April 26, 2028.

Both dates moved back a year in April 2026, and most published guidance has not caught up. Here is which cohort you are in, what WCAG 2.1 AA actually requires of a public-sector site, and what a remediation project looks like if you start now.

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What the rule says

WCAG 2.1 AA, for web content and mobile apps

In April 2024 the Justice Department published a final rule under Title II of the ADA setting a technical standard for the web content and mobile applications of state and local government entities. That standard is WCAG 2.1 Level AA. It is not a recommendation, a target or a best practice — it is the conformance level the rule names.

On April 20, 2026 the Department published an interim final rule extending both compliance dates by one year. The substantive requirements did not change; only the dates did. The Department cited resource and staffing constraints, slower-than-expected remediation technology — including the limits of generative AI for this work — and litigation risk.

The practical consequence is that a large amount of published guidance, vendor marketing and internal planning documentation is now wrong by twelve months in both directions. Some agencies believe a deadline has already passed. Others have quietly relaxed. Both are working from the same stale dates. If you are a California agency, we have written this up for cities and counties and for special districts and JPAs, including what a district should budget.

Which cohort

Two dates, decided by what kind of entity you are

The split is by entity type and population, not by how large your website is or how much budget you have.

April 26, 2027

State and local government entities with a total population of 50,000 or more. Previously April 24, 2026. This is most cities of any size, most counties, and state agencies.

🏘️

April 26, 2028

Smaller public entities — under 50,000 — and special district governments of any size. Previously April 26, 2027. Districts are named in the rule and are in this cohort regardless of the population they serve.

What is covered

Web content and mobile apps a public entity provides or makes available to the public. That includes third-party systems you embed — agenda management, payment and permit portals, job boards, reservation systems, video.

⚖️

What did not change

The standard, the scope and the exceptions are all as published in 2024. An extension of time is not a relaxation of the requirement, and it does not affect existing obligations under Title II generally.

In practice

Where public-sector sites actually fail

Almost none of the real gap is in the visual design. It is in the documents. Agendas, minutes, board packets, budgets, notices and staff reports are published as PDFs, frequently scanned, frequently with no text layer at all — unreadable to a screen reader and unsearchable to everybody. On most public sites this is the single largest body of non-conforming content, and it is the part a redesign does not touch.

The second cluster is the systems you did not build. Agenda management, permitting, utility payment, job application and reservation platforms are embedded into the site and inherit none of its accessibility work. They are your obligation because you make them available to the public, but the fix is a vendor conversation rather than a code change, and those conversations take months. Starting them late is the most common reason an otherwise well-run remediation misses. It is also why a joint powers authority, whose budget has to come from member agencies, needs to begin earlier than its members do.

Third is video. Automatic captions are not captions for compliance purposes. Meeting recordings, public-service announcements and training material need corrected captions, and live-streamed meetings raise their own questions worth resolving early rather than at the deadline.

Fourth, and least discussed: everything published after remediation. A site brought to conformance in 2027 is non-conforming again within a month if the people posting agendas were never given accessible templates and thirty minutes of training. Remediation without a publishing process is a one-time expense that buys a temporary result.

The path

What a remediation project looks like

Long enough to need starting, short enough to be finishable. The constraint is rarely the technical work — it is procurement and third-party vendors.

1

Audit against WCAG 2.1 AA

Automated coverage plus keyboard and screen-reader passes on the templates and journeys that matter, with the document library and embedded systems inventoried separately.

2

Triage into a defensible plan

Sorted by public impact and legal exposure rather than by what is easiest to fix, with what is being deferred and why written down. Documented reasoning is worth having if a complaint arrives.

3

Open the vendor conversations

Request current conformance reports from every third-party system embedded in the site. This is the long pole and it should be started first, not last.

4

Fix templates, then content

Template-level fixes clear whole classes of failure at once. Document remediation and replacement follow, prioritized by the triage.

5

Change how you publish

Accessible templates for agendas and notices, a short checklist for the people who post them, and training. This is what keeps the result after the project ends.

6

Verify and document

Re-test, record what conforms and what does not, and keep the evidence. Being able to show your work matters.

Questions

Straight answers

Has the deadline passed?
No. If you are working from an April 2026 date, that is the original date from the 2024 final rule and it was extended. Public entities serving 50,000 or more now have until April 26, 2027; smaller entities and special districts until April 26, 2028.
Is WCAG 2.2 AA required?
The rule names WCAG 2.1 Level AA. We generally build to 2.2 AA because it is a superset in practice, it is where the standard is heading, and the additional criteria are not expensive to meet in a new build. If you are remediating an existing site on a budget, conforming to 2.1 AA is what the rule asks for.
Does an accessibility overlay satisfy this?
No. Overlay and widget products do not bring a site into conformance, they do not remediate documents, and they do not address embedded third-party systems. We do not sell them and we would advise against buying one.
What about our archived documents?
The rule includes limited exceptions, one of which covers certain archived content. It is narrower than most agencies assume and it depends on specifics — where the content lives, whether it has been changed, and whether it is still operative. It should be applied deliberately and documented, not treated as a blanket exemption for anything old.
Can we do this in-house?
Template and process work, often yes, and it is the highest-value thing an in-house team can own. Document remediation at volume and screen-reader testing usually need outside help. We are happy to do the audit and hand it to your own team.
Where do these dates come from?
The Justice Department's interim final rule published in the Federal Register on April 20, 2026, extending the compliance dates in the April 2024 web accessibility rule. We check both against the primary documents rather than a summary, because summaries of this rule have been wrong repeatedly.

Project Managers who will work with you on your project!

David Geder
David Geder
Irina Shvaya
Irina Shvaya
Benjamin Gunther
Benjamin Gunther
Jeanette Mordvinov
Jeanette Mordvinov
Mark Shvaya
Mark Shvaya

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