ADA Title II web accessibility deadline 2027: 26 April plan for governments

Summary. The US Department of Justice's interim final rule of 20 April 2026 (91 FR 20902), effective the same day, moved the ADA Title II web and mobile app compliance date for state and local governments with a total population of 50,000 or more from 24 April 2026 to 26 April 2027. Governments under 50,000 and every special district government now have until 26 April 2028. Nothing else changed: the standard is still WCAG 2.1 Level A and AA, the five exceptions still apply, and content and apps provided through contracts or licences are covered, so vendor-run payment, permit and parking tools are in scope. Counting from 13 November 2026, 164 days remain, and 26 April 2027 is a Monday. Two things could still move the date: DOJ's August 2026 regulatory agenda lists a possible proposal to make parts of the rule less burdensome, with no date set, and the National Federation of the Blind is asking a federal court in Maryland to set the extension aside, with its summary judgment motion still undecided. DOJ's 2024 analysis put the average first-round cost for a large county at $699,055 in 2022 dollars.

About this article. For ADA coordinators, digital and IT leads in US state and local governments, and the gov-tech suppliers and agencies that build for them. We checked every date, section and figure against the Federal Register texts, ADA.gov guidance, DOJ's impact analysis, W3C, WebAIM, ITI and the court docket on 13 November 2026. This is general information, not legal advice; confirm your obligations with counsel. No vendor paid for inclusion. Researched with AI assistance and reviewed by our editorial team.

The dates and numbers that matter

The rule as amended in April 2026, with the pending next steps:

Why DOJ moved the dates, and what did not change

DOJ gave three reasons for the delay: the resource and staffing limits governments reported, slower than expected progress in technology for making content accessible, and the litigation risk entities would face once the dates passed. It said it had overestimated what covered entities could do in the time allowed. It priced the one-year shift at $2.775 billion in present-value savings over 10 years at a 7% discount rate, or $395 million annualised, against a $24.7 billion 10-year cost estimate of which small entities carry about 53%.

Read the change as a delay, not a rewrite. The interim rule says it leaves the 2024 rule's substantive requirements, including the scope of coverage, untouched and only extends the dates. It also repeats that the general Title II duty to make online services accessible continues, so effective communication and reasonable modifications on request apply today.

HHS made the same one-year move for Section 504 in an interim rule published on 11 May 2026: recipients of HHS funding with 15 or more employees now comply from 11 May 2027, and those with fewer than 15 from 10 May 2028. For a small government with an HHS-funded hospital, clinic or health department and 15 or more employees, that date arrives almost a year before its own Title II date. Our guide to the HHS Section 504 deadline of 11 May 2027 covers that rule.

Who must comply by 26 April 2027

Title II applies to every state and local government, its departments and agencies, special purpose districts, Amtrak and other commuter authorities. ADA.gov's examples include benefits offices, public schools and universities, police, courts, elections offices, public hospitals, parks, libraries and transit agencies.

The date depends on the government's population, not the size of its IT team. The rule defines total population, and the fact sheet explains how to apply it:

Two traps catch planners. A school district is not a special district government, so a large urban district does not get 2028. And a small department inside a large county inherits the county's 2027 date even if it serves a few thousand people.

What WCAG 2.1 AA means for your sites and apps

The rule incorporates the June 2018 version of WCAG 2.1. WCAG 2.1 added 17 success criteria to WCAG 2.0, and 12 of them sit at Level A or AA, so they are in scope. Several target mobile use: content must work in portrait and landscape (1.3.4), reflow at 320 CSS pixels without two-way scrolling (1.4.10), keep interface boundaries and icons at 3:1 contrast (1.4.11), offer single-pointer alternatives to multi-finger and path gestures (2.5.1), and not depend on shaking or tilting (2.5.4). Fields collecting a user's details must expose their purpose for autofill (1.3.5), and status messages such as a payment confirmation must reach a screen reader without moving focus (4.1.3).

WCAG 2.2 became a W3C Recommendation on 5 October 2023. It adds 9 success criteria and removes 4.1.1 Parsing as obsolete. The rule still names 2.1; DOJ's interim rule even complains that W3C's supporting links now lead to WCAG 2.2 pages. The rule's equivalent facilitation clause allows designs giving substantially equivalent or greater accessibility. So most teams build to WCAG 2.2 AA, gaining extras such as the 24 by 24 CSS pixel minimum target size, and report against WCAG 2.1 AA. Keep 4.1.1 Parsing in that 2.1 report, because a 2.2 checklist will not list it.

Where will the defects be? WebAIM's February 2026 scan of one million home pages found an average of 56.1 detected errors per page, up 10.1% on 2025, and six error types made up 96% of them:

Government sites start ahead, but less than the headline suggests: the 1,987 .gov home pages averaged 18.5 detected errors, while pages WebAIM classed as government averaged 42.4, and many cities and counties use .us, .org or .com domains. Automated tools also miss failures, and DOJ's first-steps guide says to pair them with manual testing. Home pages are the easy part; residents get stuck in the permit wizard, the payment flow and the agenda PDF.

The five exceptions, and what they do not cover

The exceptions are in 28 CFR 35.201, and the fact sheet gives the examples summarised here.

Three limits sit around the exceptions. First, if a resident with a disability asks for exempt content, you still owe effective communication, for example captioning one archived video on request. Second, the undue burden and fundamental alteration defences need the head of the entity or a designee to weigh all available resources and record the reasons in writing, and you must still do whatever falls short of that burden. Third, a separate accessible version of an inaccessible page is allowed only where a technical or legal limitation prevents fixing the original.

The exceptions shape the work plan. Moving historical material created before your date into a marked archive area, then leaving it unchanged, shrinks the scope. Every document posted after the date must conform, so authoring has to change too.

Vendors and contractors: what agencies will ask suppliers for

The scope clause reaches private software. DOJ's own examples are a county parks page built and updated by a local web design firm, and a city parking app run by a private company. The fact sheet adds that calendars, scheduling tools, maps, reservation systems and payment systems built by outside technology companies are not third-party content when the government posts them. For gov-tech SaaS firms, payment processors, permitting platforms and the agencies that build public sites, the government's legal duty becomes a contract term.

DOJ's first-steps guide (dated 8 January 2025 and revised after the April 2026 extension) lists practices that public entities reported working during the rulemaking:

1. Detailed accessibility information about a product before signing.

1. A warranty of compliance with technical standards and federal and state accessibility laws.

1. No vendor disclaimers of accessibility warranties.

1. Indemnification for any breach of those warranties.

1. Testing vendor products and publishing results so others can find accessible ones.

Expect the paperwork to start with an Accessibility Conformance Report (ACR), the completed form of ITI's Voluntary Product Accessibility Template. The current template is VPAT 2.5Rev, dated April 2025, in four editions, and the edition matters. The Section 508 edition carries WCAG 2.0, the EU edition WCAG 2.1, and the WCAG and international editions WCAG 2.2. A 508-only report therefore does not show the 12 WCAG 2.1 criteria at A and AA. ITI also says there is no VPAT certification and it does not review reports, so an ACR is the vendor's own claim. Suppliers also selling into Europe should read our note on the EU Accessibility Act and WCAG 2.2.

Use this table to decide what to do with each supplier:

Suppliers selling to both large and small governments face two deadlines a year apart, but most ship one product, so 26 April 2027 is their real date.

A 23-week testing and remediation plan

From Monday 16 November 2026 there are exactly 23 calendar weeks to the deadline, holiday weeks included. The plan assumes a large county or city with several sites, one resident app and four or five vendor platforms. A single-site government can shorten each phase but should skip none.

How to test the key journeys. For each one (pay a bill, apply for a permit, find a meeting agenda, report a pothole, request records) run five passes: keyboard only, a desktop screen reader such as NVDA or JAWS, a mobile screen reader, 400% zoom with text spacing overrides, and contrast checks at 4.5:1 for text and 3:1 for interface parts. Log each failure against its WCAG 2.1 criterion, journey and owner.

Why components first. The six common failure types above mostly live in shared code: colour tokens, buttons, links, form inputs and the page template. One fixed input component can clear label failures on every site.

Mobile timing. Web fixes go live when you deploy; app fixes reach residents only after store review and updates. Submit the final fix release by mid-March and prompt older versions to update. If your Android app will also need the Google Play target API 37 update, which Google says applies to new apps and updates from August 2027, you can fold that work into the same release cycle. After 26 April, keep the tests in your release pipeline, because new content gets no exception.

Worked cost example: a county of 300,000

Start with DOJ's benchmark. Its 2024 final regulatory impact analysis tested sampled government sites automatically and manually and estimated average first-round costs per entity, in 2022 dollars:

For a large county, about 74% of that average is website remediation, 15% testing, 8% PDFs and 3% captioning. DOJ valued staff time at a loaded $109.80 an hour (the 2022 median wage of $54.90 for software and web developers, programmers and testers, doubled for benefits and overhead) and used $15 a minute as an upper bound for captioning. It notes the costs are right-skewed, so a median may describe a typical entity better.

Now an illustrative budget for a county of 300,000 with 6 websites, one iOS and Android app, 150 PDF forms still in use and 900 minutes of current video. The hours are our assumptions, not quotes; the rates are DOJ's.

The arithmetic: 2,958 hours at $109.80 is $324,788, plus $13,500 of captioning, gives $338,288. That is about 48% of DOJ's $699,055 county average, for three reasons: it assumes vendors fix their platforms at their own cost under contract, that historical PDFs move to a compliant archive instead of being remediated, and that shared-component fixes clear errors across pages. Drop any of those assumptions and the number climbs towards DOJ's figure. Swap $109.80 for your own 2026 rate; the hours carry over.

What could still change before 26 April 2027

DOJ's regulatory agenda, published on 14 August 2026, says the department is considering extending the deadlines and then proposing changes to make some 2024 provisions less burdensome, with the proposal's date to be determined. A Federal Register search on 13 November 2026 found no such proposal under RIN 1190-AA82. The interim rule says that, absent a proposal or new reasons for delay, DOJ expects to apply the rule at the new dates. A proposal would need comments and a final rule before it changed anything.

The court case runs the other way. The National Federation of the Blind sued DOJ and HHS on 21 May 2026 in the District of Maryland (case 1:26-cv-02007). The docket shows the federation's motion for summary judgment filed on 28 September 2026 and, on 12 November 2026, a government motion for more time to respond; no ruling has been entered. As reported by Seyfarth Shaw's ADA Title III blog, the federation argues the agencies skipped notice and comment without good cause and asks the court to vacate both interim rules and enforce the original dates. If that succeeded, the 2024 dates would in principle return, and the large-government date of 24 April 2026 has passed. Plan to 26 April 2027, but do not count on needing all of it. Accessible components, captioned meetings and fillable HTML forms keep their value whatever a court or a revised rule says.

How eCorpIT can help

eCorpIT is a Gurugram-based technology organisation, founded in 2021, assessed at CMMI Level 5 and MSME certified, with senior-led engineering teams working across AWS, Microsoft and Google platforms. Our application development services team audits and fixes public websites, resident portals and iOS and Android apps against WCAG 2.1 AA, starting with shared components, and helps gov-tech suppliers prepare test evidence and remediation roadmaps for their government customers. Talk to us at /contact-us/.

Last updated: 13 November 2026.

References

1. Extension of Compliance Dates for Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities, 91 FR 20902, 20 April 2026 — Department of Justice, Federal Register (GovInfo)

1. Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities, 89 FR 31320, 24 April 2024 — Department of Justice, Federal Register (GovInfo)

1. Department of Justice Regulatory Agenda, 91 FR 53016, 14 August 2026 — Federal Register (GovInfo)

1. National Federation of the Blind v. Department of Justice et al, 1:26-cv-02007, District of Maryland, docket — PacerMonitor

1. Final Regulatory Impact Analysis, Title II web and mobile app accessibility rule — US Department of Justice, ADA.gov

1. Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments — US Department of Justice, ADA.gov

1. Extension of Compliance Dates for Nondiscrimination on the Basis of Disability; Accessibility of Web Content and Mobile Applications of Recipients of Departmental Financial Assistance, 91 FR 25496, 11 May 2026 — HHS, Federal Register (GovInfo)

1. What's New in WCAG 2.1 — W3C Web Accessibility Initiative

1. What's New in WCAG 2.2 — W3C Web Accessibility Initiative

1. The WebAIM Million: the 2026 report on the accessibility of the top 1,000,000 home pages — WebAIM

1. First Steps Toward Complying with the ADA Title II Web and Mobile Application Accessibility Rule — US Department of Justice, ADA.gov

1. VPAT 2.5Rev templates and frequently asked questions — Information Technology Industry Council

1. Prepare your app for the resizability and orientation changes in Android 17, 13 February 2026 — Android Developers Blog, Google

1. Federal Register document search for RIN 1190-AA82, checked 13 November 2026 — Office of the Federal Register

1. National Federation of the Blind Challenges Last-Minute Deadline Extensions for Website and Mobile App Accessibility, 1 June 2026 — Seyfarth Shaw, ADA Title III blog