Title II website accessibility for local governments: the rule and a working plan

This page is for the people who run a city, county, town or special district website: web managers, clerks, IT staff and the department heads who publish to the site. It covers what the rule asks of a local government in practice. For how and why the deadline moved in April 2026, read our ADA Title II deadline guide; for every US rule side by side, see US web accessibility laws.

The rule in brief

Title II of the ADA covers "all services, programs, or activities of state and local governments, from adoption services to zoning regulation", including what they offer online and through apps. In 2024 the Department of Justice set a technical standard for that online part: WCAG 2.1 Level AA for web content and mobile apps (ADA.gov fact sheet). By our count from the WCAG 2.1 specification, that is 50 success criteria (30 at Level A, 20 at AA). An interim final rule published April 20, 2026 (91 FR 20902) set the current dates.

Working out your population

ADA.gov says that for most governments the population is "a number you can find in the 2020 data from the U.S. Census Bureau". A department without its own figure, such as a city police department or library, uses the population of the government it belongs to. A school district is not a special district government: a city school district uses the city's population, a county school district the county's, and an independent school district the estimate in the most recent Small Area Income and Poverty Estimates (ADA.gov).

What counts as your content

The rule reaches content you provide or make available, and that "includes when a state or local government has an arrangement with someone else who provides or makes available web content for them." ADA.gov gives two examples: a county parks page must meet WCAG 2.1 AA "even if a local web design company made the web page and updates it for the county", and a city's parking payment app must meet it "even if the app is run by a private company" (ADA.gov fact sheet).

This matters most for the tools that local governments rarely build themselves. ADA.gov names "calendars, scheduling tools, maps, reservations systems, and payment systems" developed by outside technology companies, and says that when the government posts them they "would usually need to meet WCAG 2.1, Level AA". The same applies to content a contractor posts for you and to platforms you add to your site, such as a message board. Governments that contract with others to provide public services "also have to make sure that their contractors follow Title II."

The five exceptions, and what still has to conform

The rule has five exceptions. Each has conditions that must all be met, and ADA.gov's examples show how quickly content falls outside them.

An exception does not end the obligation to the person in front of you. ADA.gov says that even when content falls under one, the government "would likely still need to provide the content to a person with a disability who needs it in a format that is accessible to them". Its examples include captioning an archived video on request and offering a large print version of a water bill.

Other parts of the rule a web team should know

• Separate "accessible versions" are limited. A conforming alternate version may stand in for inaccessible content only "when there is a technical or legal limitation that prevents inaccessible web content or mobile apps from being made accessible." A text-only copy of the site is not a general workaround.
• Minor shortfalls. A government that can show a failure is so minor it would not change a person's access is not violating the rule. ADA.gov's example is text at a contrast ratio of 4.45:1 against the required 4.5:1. It also warns that governments "cannot use this part of the rule to avoid trying to meet WCAG 2.1, Level AA." See WCAG 1.4.3 Contrast (Minimum) for how the ratio works.
• Undue burden and fundamental alteration. As elsewhere in the ADA, a government does not have to take actions that would cause either, and ADA.gov notes the answer can differ "from one year to the next".
• Meeting WCAG does not settle every request. If a person still cannot use content that meets WCAG 2.1 AA, the government must find another way on a case-by-case basis. ADA.gov's example is a county that must offer another way to buy fair tickets when its conforming app does not work for someone.
• Private lawsuits. The interim final rule notes that "Congress created a private right of action in title II" (91 FR 20902), so people with disabilities can sue, not only DOJ.

What could still change

Two things are worth watching, and our law updates log records changes as we verify them.

• DOJ's own plans. The interim final rule says DOJ "plans to engage in future rulemaking processes related to the substantive requirements of the 2024 final rule" and "will consider issuing an NPRM", a proposed rule. It also says that if it does not, and no circumstances suggest further delay, "the Department fully anticipates implementing the regulation at the new deadline" (91 FR 20902). A Federal Register search on October 11, 2026 found no later document changing the rule.
• A court challenge. On May 21, 2026 the National Federation of the Blind sued DOJ and HHS in federal court in Maryland over the extensions (No. 1:26-cv-02007). Its announcement says it is asking the court "to block the delays and restore the original accessibility compliance deadlines". As of October 11, 2026 we found no ruling; the free public copy of the docket (last updated August 13, 2026) showed a briefing schedule ordered on June 29, 2026. The original dates were April 24, 2026 and April 26, 2027, so restoring them would leave governments of 50,000 or more past their date at once.

Until DOJ or a court changes them, the dates in the table above are the ones in effect. The rule's own description of itself is also worth remembering: it sets the technical standard governments "must follow to meet their existing obligations under Title II" (ADA.gov).

A working plan for a city or county web team

1. Confirm your date and name an owner

   Look up your population in the 2020 Census data and write down your compliance date. Make a named office responsible for the program, because the work spans every department that publishes.

2. Write a policy and train everyone who publishes

   DOJ's Small Entity Compliance Guide suggests policies on how you will make content accessible, a staff member to "coordinate your government's efforts to comply with this rule", regular testing that "may include working with people with disabilities", and "thorough and ongoing staff training", including for procurement staff. Train the clerks and department staff who post agendas, notices and PDFs, not only the web team.

3. Inventory everything you publish

   List the main site and every subdomain or department site, then the vendor-hosted services linked from them: payments, permits, reservations, agendas and minutes, maps, calendars and job applications. Add mobile apps, document libraries and social media accounts. For each item, record whether it is covered, which exception might apply, and who controls the code.

4. Triage documents before you fix them

   Sort PDFs and other files into three groups. Documents people use to apply for or access a service must conform whatever their age, so fix those first. Anything new or updated after your compliance date must conform. Old reference material can move to a labeled archive only if it meets all four archive conditions. Our PDF accessibility checker runs a structural first pass in your browser and never uploads the file, and our accessible PDF guide covers the fixes.

5. Fix templates and shared components first

   A barrier in the site template, a navigation menu or a form component appears on every page that uses it, so one fix there clears it everywhere. Check the basics with the heading checker, link text checker and contrast checker (and the alt text checker for images), and test each template with a keyboard alone using our keyboard accessibility test. Do not rely on an overlay widget: DOJ's interim final rule observes that "Advanced technology, such as generative AI, does not yet reliably automate the remediation of inaccessible content at scale", and the FTC's $1,000,000 order against accessiBe concerned claims of automatic WCAG conformance.

6. Put the standard into procurement

   Because vendor tools you post are covered, write WCAG 2.1 Level AA into new contracts and renewals, ask vendors for an Accessibility Conformance Report (see our VPAT and ACR guide), and test the parts residents actually use before you sign. An ACR is the vendor's own account of its product, not proof.

7. Give residents a way to report barriers

   The ADA.gov fact sheet does not list an accessibility statement among the rule's requirements, but DOJ's Small Entity Compliance Guide suggests "Letting members of the public know, in prominent places on your website, how they can ask your government to make content accessible when the content falls within an exception to this rule." A statement with a contact route does that, and helps you meet the duty to provide content in an accessible format when someone asks. Our accessibility statement guide and statement generator give you a structured first draft.

8. Monitor and keep records

   Agendas, notices and news are posted every week, and each new item is new content under the rule. Re-test regularly, keep dated records of what you tested and fixed, and write down every archive or undue burden decision and the reasons for it.

Where GotAlt fits, and where it does not

GotAlt checks published web pages. It fits the inventory, template and monitoring steps above:

• The free scan runs 16 rule checks on up to three pages, each mapped to a WCAG success criterion, with no signup.
• The accessibility bookmarklet runs in your own browser on any page, including a staging site or a page behind a login. It reads the page as rendered, so it also sees content that scripts add after the page loads, and it checks the contrast of the text on screen.
• Paid plans watch pages every week. Professional starts at $69 a month for one site and 50 monitored pages, with regression alerts when a change breaks something that used to pass, issue history and an evidence log per issue. The Agency plan, from $229 a month, pools pages across multiple sites, for a government that runs separate department sites. Setup can read your sitemap so you pick pages rather than typing them.
• The deep audit opens up to six images per page and checks whether their alt text describes what the image shows, which a rule check cannot judge.

What it does not cover: mobile apps, which the rule also reaches; keyboard traps, focus order and screen reader behavior, which need a person; and color contrast in the scan and weekly monitoring, which read HTML without rendering it (the bookmarklet and contrast checker cover contrast separately). Our methodology lists every check and every gap. A full accessibility audit by people remains part of a complete program.