State and local governments — including public universities, school districts, courts, transit authorities, and special districts — now have specific federal compliance deadlines for web and mobile app accessibility. The Department of Justice published the final rule in April 2024, and compliance dates were extended by one year in April 2026. Here is exactly what the rule requires, who it covers, and when you need to be ready.
On April 24, 2024, the Department of Justice published a final rule under Title II of the ADA requiring state and local government entities to make their websites and mobile applications accessible to people with disabilities. The technical standard the rule mandates is WCAG 2.1 Level AA — the Web Content Accessibility Guidelines developed by the W3C.
The rule applies to essentially all digital content a public entity provides or makes available, including websites, mobile apps, digital documents, and online services. That scope extends to content provided through third parties — if a county website is built and maintained by a private web developer, that content still has to meet WCAG 2.1 AA after the compliance date.
On April 20, 2026, the DOJ published an Interim Final Rule extending the original compliance dates by one year. The extension took effect immediately.
State and local government entities with a total population of 50,000 or more. This includes most cities, counties, public universities, and public school districts serving larger populations.
Public entities with a total population of less than 50,000, and any special district government. Special districts include water authorities, fire protection districts, transit authorities, and similar single-function entities regardless of population size.
These dates apply to the WCAG 2.1 Level AA technical requirements introduced by the 2024 rule. The DOJ has stated clearly that it fully anticipates implementing the regulation at the new deadline. The extension is not a relaxation of requirements — it is additional time to achieve the same outcome.
One important note: the extension of the DOJ’s Title II rule did not affect the Department of Health and Human Services’ parallel Section 504 rule. That rule applies to healthcare and social services organizations receiving HHS funding, and its compliance deadline has been separately extended to May 2027.
The scope of the rule is broad. Public entities must ensure that the following meet WCAG 2.1 AA after their compliance date:
The rule includes a limited set of exceptions. The following categories of content may be exempt from the WCAG 2.1 AA requirements:
Web content that was created before the compliance date, has not been changed since that date, and is kept only for reference or historical purposes.
Documents in formats like PDF, Word, or PowerPoint that were posted before the compliance date — but only if they are not currently being used to apply for, access, or participate in government services. Documents currently in active use are not exempt.
Content posted by a third party that does not have a contractual, licensing, or other arrangement with the public entity.
Documents shared with specific individuals that are not publicly accessible.
Social media content posted before the compliance date.
WCAG 2.1 Level AA has 50 success criteria across four principles. For public entities just getting started, the most commonly cited failures that the rule is designed to address include: images without descriptive alt text; videos without captions; forms that cannot be completed by keyboard alone; insufficient color contrast between text and backgrounds; and content that screen readers cannot interpret correctly due to missing ARIA labels or broken heading structure.
WCAG 2.2 was published by W3C in 2023 and became an ISO standard in 2025. While the DOJ's current rule mandates 2.1 Level AA as the baseline, the W3C recommends that organizations adopt WCAG 2.2 as their conformance target. Meeting WCAG 2.2 AA automatically satisfies WCAG 2.1 AA requirements, since 2.2 is backward compatible. For a plain-language breakdown of what WCAG 2.2 adds and why it matters, see our guide to WCAG 2.2 AA explained for non-technical teams.
The extension gives covered entities more time — but not indefinitely. The DOJ’s language in the Interim Final Rule makes clear that enforcement at the new deadline is the plan.
01
Start with a WCAG 2.1 AA audit of your primary web properties. Inventory any third-party content and review vendor contracts to confirm accessibility requirements are included.
02
Train staff who create or post digital content.
03
Address the highest-frequency failures first: contrast, alt text, form labels, and document accessibility.
