The 2024 ADA Title II web accessibility rule
The DOJ's April 2024 final rule adopted WCAG 2.1 Level AA as the technical standard for web content and mobile apps of state and local government entities. The underlying nondiscrimination obligation it implements has existed in statute since 1990.
What the rule is
On April 24, 2024, the U.S. Department of Justice published a final rule amending its ADA Title II regulations to address web and mobile app accessibility. The rule added Subpart H to 28 CFR Part 35 and formally adopted the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA as the technical standard for digital content of state and local government entities (Source: 28 CFR Part 35, Subpart H ) .
Before this rule, ADA Title II's nondiscrimination obligation applied to digital content (DOJ had enforced it through settlements since the 2010s), but no codified technical standard existed in regulation. The 2024 rule replaces case-by-case enforcement with a written standard.
See What changed in 2024 for the pre-rule vs. post-rule comparison.
What it requires
The core requirement: web content and mobile apps that a public entity provides or makes available must conform to WCAG 2.1 Level AA by the applicable compliance deadline (28 CFR § 35.200).
"WCAG 2.1 Level AA" is a specific technical standard published by the World Wide Web Consortium (W3C). It defines 50 success criteria across four principles (Perceivable, Operable, Understandable, Robust) at three conformance levels (A, AA, AAA). Level AA is the regulatory choice; AAA is aspirational, A is insufficient.
The rule includes two narrow exceptions (archived web content and preexisting electronic documents); see Exceptions. It does not require perfection: 28 CFR § 35.203 allows for minor nonconformance that does not substantially affect a user's ability to use the content.
What it covers
The rule applies to "web content and mobile apps" the public entity "provides or makes available, directly or through contractual, licensing, or other arrangements." That language reaches:
- Public-facing websites and microsites
- Password-protected portals (student, employee, applicant, parent, constituent)
- Learning management systems (Canvas, Blackboard, Moodle)
- Document management and records platforms
- Email and email-based communications
- Conventional electronic documents (PDF, Word, Excel, PowerPoint) the entity provides through these channels
- Mobile apps the entity provides
- Social media content the entity posts
- Third-party content the entity provides under contractual or licensing arrangements
See Scope for the detailed treatment. See Documents for the specific question of PDFs and other electronic documents.
Who is covered
All "public entities" under ADA Title II are covered: state and local government entities and their instrumentalities. This includes:
- State agencies, boards, and commissions
- City, county, and township governments
- Public school districts and community college districts
- Public universities and colleges
- Special districts (water, fire, transit, library, irrigation, sanitation, others)
- Public hospitals, courts, and libraries
The rule does not cover private businesses (Title III applies), federal agencies (Section 508 applies), or private schools and universities. See Who must comply.
Deadlines
Two deadlines, set by population served:
| Deadline | Applies to | Status |
|---|---|---|
| April 24, 2026 | Public entities serving 50,000 or more people | Passed |
| April 26, 2027 | Public entities serving fewer than 50,000 people | In effect |
| April 26, 2027 | All special district governments, regardless of population | In effect |
Detailed treatment, including population-threshold mechanics and common edge cases, is at Deadlines.
Where things stand now
The rule has been adopted. The first deadline has passed. The second deadline is in effect for most state and local entities.
A DOJ Interim Final Rule was submitted to the Office of Information and Regulatory Affairs (OIRA) on February 13, 2026 under Regulatory Identifier Number 1190-AA82. The text of the IFR is not public until OIRA concludes review and the rule is published. The IFR could modify, delay, or rescind elements of the 2024 rule.
Regardless of the IFR's outcome:
- The underlying ADA Title II nondiscrimination obligation continues (42 U.S.C. § 12131 et seq.)
- Pre-2024 DOJ settlements remain valid law-of-the-case
- State accessibility laws apply independently (CA Gov Code §§ 11135 and 7405, Colorado HB21-1110, others)
- Private litigation under the statute continues (8,667 federal ADA accessibility suits filed in 2025 per Seyfarth Shaw)
The full treatment of current regulatory status and what entities should do regardless of the IFR's outcome is at Current rule status.