ADA Title II web accessibility deadlines

The two deadlines

The Department of Justice (DOJ) rule sets two compliance dates. The applicable date depends on the public entity’s total population and whether it is a special district government (Source: 28 CFR § 35.200(b) ) . In April 2026, DOJ extended both dates by one year. These are the current dates:

The 2026 one-year extension

The original dates were April 24, 2026 (50,000 or more) and April 26, 2027 (fewer than 50,000 and special district governments). On April 20, 2026, DOJ published an interim final rule that extended both by one year (Source: DOJ interim final rule, April 20, 2026 ) . The interim final rule amended the compliance dates in 28 CFR § 35.200(b); consult the cited rule and current eCFR text for the operative language.

April 26, 2027 (entities other than special district governments, total population 50,000 or more)

The April 26, 2027 date applies to a public entity, other than a special district government, with a total population of 50,000 or more (Source: 28 CFR § 35.200(b)(1) ) .

The rule specifies a technical standard for web content and mobile apps. It does not prescribe a particular project plan, vendor, testing method, budget, or procurement process.

April 26, 2028 (entities with a total population of fewer than 50,000)

The April 26, 2028 date applies to a public entity with a total population of fewer than 50,000 and to any public entity that is a special district government (Source: 28 CFR § 35.200(b)(2) ) .

An entity should assess its own content, operations, and legal obligations when deciding how to prepare.

Special districts

A special district government has the April 26, 2028 compliance date regardless of population. The regulatory definition, rather than a label an entity uses for itself, controls (Source: 28 CFR § 35.104 (definition of special district government) ) .

Whether a particular public entity fits that definition can require a fact-specific legal analysis.

Population thresholds

“Total population” is defined in 28 CFR § 35.104. The definition uses Census Bureau figures and distinguishes among types of public entities. It is not based on an entity’s employee count or budget (Source: 28 CFR § 35.104 (definition of total population) ) .

If classification is uncertain, read the definition and seek advice specific to the entity rather than relying on a simplified example.

Common edge cases

Joint entities, entities sharing infrastructure, consolidated governments, and education systems can raise classification questions. This page does not make a determination for an individual entity. Use the regulatory definitions and obtain advice appropriate to the facts.

What “compliance” means

The rule requires compliance with the incorporated Web Content Accessibility Guidelines (WCAG) 2.1 Level A and Level AA success criteria and conformance requirements, subject to its listed exceptions and defenses (Source: 28 CFR §§ 35.200-35.205 ) . Section 35.205 contains a narrow provision for noncompliance that has a minimal impact on access; it is not a general safe harbor.

The Department of Justice explains that a public entity whose web content does not fully meet WCAG 2.1 must be able to demonstrate why it has not violated the rule. Read DOJ’s explanation and the regulation itself before drawing conclusions about a particular barrier or document (Source: DOJ fact sheet ) .

This reference does not offer a compliance determination. A qualified assessment should consider the applicable regulation, content, context, and any relevant exceptions or defenses.