ADA Title II web accessibility rule: what state and local governments need by April 2027

Who does the ADA Title II web rule cover?

The rule covers all state and local governments, their agencies and departments, special purpose districts, Amtrak and commuter authorities. It applies to the web content and mobile apps they provide directly, and to those they provide through contracts, licences or other arrangements with third parties. A county's permit portal run by a software vendor is the county's responsibility under the rule, and in practice a requirement in the vendor's contract.

The rule doesn't cover private businesses. Businesses open to the public fall under Title III, which has no regulatory technical standard for websites; see our ADA website compliance checklist for that side.

This post is not legal advice. Whether and how the rule applies to a specific entity or contract is a question for a US lawyer.

Source: US Department of Justice (DOJ), ADA.gov, Federal Register

When are the ADA Title II web accessibility deadlines?

The deadlines are 26 April 2027 for public entities with a total population of 50,000 or more, and 26 April 2028 for entities with fewer than 50,000 people and for special district governments. Both dates come from the DOJ's interim final rule of 20 April 2026, which moved each original date by a year.

The new dates don't pause the existing duty. As the Pacific ADA Center summarises it, covered entities "have an ongoing obligation to ensure that their services, programs, and activities offered using web content and mobile apps are accessible to individuals with disabilities."

Source: Pacific ADA Center, US Department of Justice (DOJ), ADA.gov

What does WCAG 2.1 AA mean in practice?

WCAG 2.1 Level AA is 50 success criteria: 30 at Level A and 20 at Level AA. They cover text alternatives for images, captions, contrast of at least 4.5:1 for normal text, full keyboard operation, visible focus, form labels and error messages, and correct names and roles for controls. The rule applies the same standard to native mobile apps.

Most real failures are the common ones. In WebAIM's February 2026 scan of one million home pages, 83.9% had low contrast text and 53.1% had images without alt text. Both can be found automatically. Keyboard traps, focus order and unclear error messages can't: no axe-core rule tests them. Our EAA checker post lists which of the 50 criteria have an automated rule (20) and which don't (30); the same count applies here, since the EU's web standard also uses WCAG 2.1 AA. By volume, automated testing still finds about 57% of issues, according to Deque's 2021 study of more than 2,000 audits.

Source: W3C, WebAIM, Deque Systems, GitHub, Deque Systems

What are the five exceptions in the Title II rule?

The rule has five exceptions. Each is narrow, and content that is still used to deliver a service usually falls outside it.

In practice, the exceptions don't remove the work on the documents people use most: application forms, permit guides, current fee schedules and meeting agendas.

Source: US Department of Justice (DOJ), ADA.gov

What usually fails on government websites?

We don't have sourced failure rates for US government sites specifically, so the list below is a working list, not data. It names the areas where WCAG 2.1 AA problems tend to block a service:

• PDF forms and notices: scanned images without text fail 1.1.1; untagged PDFs lose their structure for screen readers (1.3.1).
• Online payments and permits: unlabelled fields (4.1.2, axe rule label) and errors shown only in colour (3.3.1).
• CAPTCHAs: an image-only CAPTCHA with no alternative method blocks blind users (1.1.1).
• Meeting videos: missing or auto-generated captions (1.2.2) and no captions on live streams (1.2.4).
• Maps and calendars: custom widgets that only work with a mouse (2.1.1).

Source: W3C, Deque Systems, GitHub

How do you prepare for the April 2027 deadline?

1. Inventory: list every site, subdomain, mobile app, online service and third-party portal, plus the documents people use to apply for services.
2. Scan: run an automated scan on one page of each template and on every step of your top five services.
3. Test by hand: complete those services with a keyboard and a screen reader, following our 6-step test method.
4. Fix at the source: fix templates and components, not page by page; put WCAG 2.1 AA and a test report in vendor contracts.
5. Replace documents: publish new forms and guides as accessible HTML pages or tagged PDFs.
6. Publish and monitor: publish an accessibility statement with a feedback route, and re-scan after every release; weekly monitoring automates the scan.

Avoid shortcuts that only change the surface. On 22 April 2025 the FTC finalised an order requiring accessiBe, an overlay vendor, to pay $1 million and barring it from claiming without evidence that its product makes websites WCAG-compliant. Private-sector data shows why: UsableNet counted more than 5,000 ADA digital accessibility lawsuits in 2025, and lawsuits against companies using widgets continued all year.

Source: US Federal Trade Commission (FTC), UsableNet

How does Title II compare with public-sector rules in the EU and Türkiye?

If you build software for public bodies in more than one of these markets, WCAG 2.2 AA is the simplest common target. For Türkiye, see who the Circular covers.

Source: Pacific ADA Center, EUR-Lex, Lexpera