The ADA Title II deadline moved. A lot of guides online still don't know that.

What actually happened

On 20 April 2026, the DOJ published an interim final rule that extended the compliance dates for its own Title II web accessibility rule. The substantive requirement didn't change: public entities still have to bring their websites and mobile apps up to WCAG 2.1 Level AA. What changed is only the date by which they have to do it.

The rule is published in the Federal Register: Extension of Compliance Dates for Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities. DOJ's own explanation of the underlying 2024 rule (who it covers, what it requires, and the exceptions it carries) is on ADA.gov's fact sheet.

The two deadlines now

Both dates moved back by exactly one year. Nothing about who counts as "50,000 or more" changed, and nothing about the standard changed: it's WCAG 2.1 AA either way.

Who Title II actually covers

Title II applies to state and local government: city and county government sites, public school and public university sites, state agencies, public transit authorities, courts, and special purpose districts. It also reaches contractors delivering services on the government's behalf: a vendor running a benefits portal or a booking system for a public transit agency is in scope even though it isn't itself a government body.

It does not cover the federal government's own sites (that's Section 508) and it does not cover private businesses (that's Title III, covered below). If you run a city website, a public university course platform, or a contractor building software for either, this rule is about you.

What WCAG 2.1 AA requires in practice

WCAG 2.1 AA is a broad set of success criteria, not a single checkbox. In practice it means things like: every image that conveys information has accurate text alternatives, every form field has a label, colour isn't the only way information is conveyed, keyboard users can reach and operate everything a mouse user can, video has captions, and pages have a logical heading structure a screen reader user can navigate by. It covers a lot of the same ground as our own WCAG 2.2 checklist. WCAG 2.2 is a superset of 2.1, so building to the newer standard satisfies the older one too, and DOJ's rule explicitly allows that under its "equivalent facilitation" provision if the alternative approach is as accessible as WCAG 2.1 AA or better.

Exceptions in the rule

The underlying 2024 rule carries five exceptions, and the April 2026 change didn't touch them. In summary, per ADA.gov's fact sheet:

• Archived web content: old material kept only for reference in a clearly labelled archive, unmodified since it was archived, and created before the compliance date.
• Preexisting conventional electronic documents: word processing, PDF, presentation and spreadsheet files that were already on the site before the compliance date, unless they're currently needed to access a government service.
• Third-party content posted by the public: content members of the public post themselves, where the government has no contract with them, such as public forum comments.
• Individualized, password-protected documents: a document specific to a particular person, property or account, and secured behind a password.
• Preexisting social media posts: posts made before the compliance date.

These are narrow. Content the government currently uses to deliver a service, or that it posts itself, doesn't get to hide behind them just because it's old.

What to do now

1. Work out your deadline

   Check your entity's population against the 50,000 threshold. That decides whether you're working to 26 April 2027 or 26 April 2028.

2. Don't read the extra year as room to wait

   WCAG 2.1 AA touches templates, document workflows, forms and video captioning across an entire site. That's a programme of work, not a sprint before the deadline.

3. Find out what's actually broken

   Run a free scan first. It's a reasonable place to start, though no automated tool, ours included, catches everything WCAG 2.1 AA requires (see "What we don't claim" below).

4. Fix, re-check, and keep evidence

   Regulators and litigants both look for a documented, ongoing process, not a one-off fix. Keep records of what you found and what you changed.

How this differs from Title III

If you run a private business, there's no compliance date to circle on a calendar. The pressure is a rising rate of litigation rather than a regulatory deadline. If you're a public entity, you now have both: a fixed date under Title II, and the same litigation exposure private businesses face.