Guide · ADA Title II

ADA Title II web rule deadline: April 2027 and April 2028

Updated · Rotomal

State and local governments with a total population of 50,000 or more must make their web content and mobile apps meet WCAG 2.1 Level AA by April 26, 2027; those under 50,000 and all special district governments by April 26, 2028. DOJ set these dates in an interim final rule effective April 20, 2026, a one-year extension. HHS moved its parallel Section 504 dates to May 11, 2027 for recipients with 15 or more employees and May 10, 2028 for the rest.

The dates

WhoOriginal dateCurrent date
State and local governments, total population 50,000 or moreApril 24, 2026April 26, 2027
State and local governments under 50,000April 26, 2027April 26, 2028
Special district governmentsApril 26, 2027April 26, 2028
HHS funding recipients with 15 or more employees (Section 504)May 11, 2026May 11, 2027
HHS funding recipients with fewer than 15 employees (Section 504)May 10, 2027May 10, 2028

Who is covered

  • All state and local governments and their agencies and departments, including independent school districts.
  • Special purpose districts, Amtrak and other commuter authorities.
  • Contractors that provide services on a government's behalf: the government must make sure their content meets the rule.
  • Under the HHS Section 504 rule: recipients of HHS financial assistance, which HHS says range from large hospital systems to small local clinics, as well as social service providers and colleges.

How population is worked out

ADA.gov tells most entities to use their 2020 Census population. An independent school district uses the most recent Small Area Income and Poverty Estimates figure, and a city or county school district uses its city's or county's population. A department or agency without its own count uses the population of the government it belongs to. Population is not the number of people you serve or the number of staff.

What did not change

  • The technical standard: WCAG 2.1 Level AA.
  • The exceptions: archived content, preexisting conventional electronic documents, some third-party content, individualized password-protected documents and preexisting social media posts.
  • The existing duty: DOJ says covered entities have an ongoing obligation to make services offered through web content and apps accessible, regardless of the compliance dates.

Could it move again?

Both DOJ and HHS said they plan future rulemaking on the substance of their rules and will consider a notice of proposed rulemaking. Both also said that if they do not issue one, and no circumstances suggest further delay, they fully anticipate implementing the rules at the new dates. We found no published proposal when we checked on 3 November 2026.

What to do first

ADA.gov's first steps include identifying all the web content and apps your entity has, then reviewing the exceptions to decide what must meet WCAG 2.1 AA. For most entities the largest item is posted documents. Title II Document Triage inventories every document on your site and sorts each one against the exceptions, from a $49 count and $290 for up to 500 documents.

Questions

Is the April 2026 deadline still in force?

No. DOJ's interim final rule, effective April 20, 2026, moved it to April 26, 2027 for entities of 50,000 or more.

Does the rule apply to private businesses?

The Title II rule covers state and local governments and their contractors' content; it does not set web rules for private businesses. Private providers that receive HHS financial assistance are covered by the HHS Section 504 rule.

Which standard do we have to meet?

WCAG 2.1 Level AA, for both web content and mobile apps, subject to the rule's exceptions.

Do school districts get the later date?

It depends on population. An independent school district uses its population in the most recent Small Area Income and Poverty Estimates; a city or county school district uses its city's or county's. 50,000 or more means April 26, 2027.

Did the comment period on the extension close?

Yes. Comments on DOJ's interim final rule were due by June 22, 2026, and on HHS's by July 6, 2026.

Sources

Guides and answers