Who must comply with the Title II web rule?
Source-backed explanations and practical guidance. Educational information, not a legal determination.
Start with the responsible public entity
Americans with Disabilities Act (ADA) Title II applies to state and local government entities. The Department of Justice (DOJ) gives examples including public schools, public colleges, public libraries, and state and local agencies. The web rule concerns what the public entity provides or makes available, including through arrangements with other parties. Read the DOJ fact sheet.
Classify the entity, not the website audience
Public entities other than special district governments with a total population of at least 50,000 have an April 26, 2027 compliance date. Smaller public entities and special district governments have an April 26, 2028 date. The April 2026 extension changed the dates, not all other rule provisions.
Use the regulatory definition of total population. A college’s enrollment or an agency’s employee count is not a substitute. DOJ’s first-steps guide explains population and entity categories.
Contracting does not transfer the public entity’s responsibility
A private or religious organization does not automatically become a public entity merely because it supplies a government service. However, covered content delivered through contractual, licensing, or other arrangements remains part of the public entity’s responsibility under § 35.200. Evaluate the entity, relationship, content, and applicable legal framework separately. Read the rule.
Do not apply Title II to every organization by analogy
Private organizations and federal agencies require separate analysis; this state/local-government rule is not a universal rule for every business or federal website. Section 508 is one separate federal accessibility framework. Read the Access Board’s federal ICT standards.
Employee-only systems may involve employment and other requirements. Read the scope guide instead of assuming all digital systems have identical coverage.