The Department of Justice's rule under Title II of the ADA requires every state and local government website, and every mobile app one provides, to meet WCAG 2.1 Level AA. Public entities with a population of 50,000 or more have until April 26, 2027. Everyone under that, and every special district, has until April 26, 2028. The rule reaches the PDFs, the meeting video and the vendor portals, and the exceptions are smaller than they look.
Who the ADA web rule applies to
Title II of the ADA has covered the services of state and local governments since 1990. What the 2024 rule adds is a technical standard and a date. If you are a city, town, township, county, school district, public college, library, court, police department, transit authority, or a water, fire, park or hospital district, the rule applies to your web content and your mobile apps.
It also applies to the parts of your online presence you did not build. The rule covers content a public entity "provides or makes available," and DOJ's own guidance is blunt about contractors: if you have a contract, license or other arrangement with another entity to provide public services, those services still have to comply. The bill-pay portal, the records-request system, the agenda management vendor, the streaming platform that hosts your council meetings. If a resident reaches it through you to deal with you, it is yours under the rule.
The one group the rule does not reach is the federal government, which has its own standard under Section 508, and private businesses, which fall under Title III and have no fixed technical standard yet. Our post on ADA website lawsuits against small businesses covers that side.
Which deadline is yours: April 2027 or April 2028
The rule sorts public entities by "total population," and the method depends on what kind of entity you are.
| Kind of entity | How population is counted | Compliance date |
|---|---|---|
| City, town, township, county | 2020 decennial Census, 50,000 or more | April 26, 2027 |
| City, town, township, county | 2020 decennial Census, under 50,000 | April 26, 2028 |
| Department of a larger government (city library, county clerk) | The population of the government it belongs to | Follows that government |
| Independent school district | Small Area Income and Poverty Estimates for the district | 2027 at 50,000 or more, otherwise 2028 |
| State agency, state university | The state's population | April 26, 2027 |
| Special district government (library, water, fire, park, transit, hospital) | No Census population | April 26, 2028 |
A special district government is a public entity other than a county, municipality, township or independent school district that provides one or a few designated functions with enough independence to be its own government. The Census Bureau does not calculate a population for it, so the rule gives every special district the later date. A library that is a department of the city is not a special district; it uses the city's population. We have separate pages for cities and counties, school districts and special districts because the date logic and the content the rule reaches differ for each.
The original 2024 rule had these dates one year earlier. In April 2026 DOJ published an interim final rule that pushed both out by twelve months. The standard, the coverage and the exceptions did not change, and the rule was not withdrawn. Plan for the dates above and do not wait for a second extension; our post on finding your date and working backward from it has a month-by-month timeline.
What WCAG 2.1 AA means for a city website
WCAG 2.1 has 78 success criteria across three levels. Level AA, the one the rule names, is 50 of them. On a WordPress site the failures concentrate in a handful of places, and most are set once in the theme rather than page by page.
Text needs 4.5:1 contrast against its background, and large text, icons and form borders need 3:1. Every menu, form, slider and modal has to work with the Tab key alone, with a visible focus ring, so a resident who cannot use a mouse can still pay a bill or find the agenda. Every meaningful image needs alt text, and a flyer posted as a JPEG needs its full text somewhere a screen reader can read it. Forms need a real label on each field, instructions before the mistake, and error messages that get announced. Recorded video needs accurate captions and live streams need live captions. Headings have to be in order, tables need headers, and the page's language has to be declared.
Then there are the PDFs. A PDF is web content under the rule. A scanned agenda has no text a screen reader can read at all, and a packet exported from Word without tags has text but no structure. Every packet, form, rate schedule and annual report posted after your compliance date has to be a tagged, readable document. Our WordPress accessibility guide walks through the criteria in detail, and the testing tools post covers how to check a page yourself.
One question comes up every time: WCAG 2.1 or 2.2? The rule names 2.1. Version 2.2 adds nine criteria and drops one, so a site that meets 2.2 AA meets the rule. Review against 2.1 because that is what will be measured, and pick up the 2.2 items while the theme is open.
The five exceptions and what they leave out
The rule lists five kinds of content that do not have to conform. Each has a condition, and the conditions put most of what a city posts back inside the rule.
Archived web content is exempt only if it was created before the compliance date, is kept for reference or record-keeping, sits in a clearly labelled archive, and has not been changed since it went there. Last month's agenda on the main news page is not an archive.
Pre-existing conventional electronic documents (Word, PDF, spreadsheets, slides) posted before the compliance date are exempt until the moment a resident needs one to apply for, access or take part in a service. The permit form from 2019 is covered. The 2019 newsletter is not.
Content posted by third parties, like public comments, is exempt. Content from a vendor or contractor you have an arrangement with is not third-party content.
Individualized, password-protected documents about a specific person, like one resident's utility bill, are exempt. The portal that serves them is not.
Social media posts made before the compliance date are exempt. Everything after it, including posts you embed on your own site, has to conform.
Read the list as a set of edges, not as a set of doors. A city that leans on the exceptions to skip the agenda packets will find that the packets are exactly what the rule was written for.
Vendor portals count as your content
This is where most public entities have the least control and the most exposure. A city might run its own WordPress site and hand off payments, permits, records requests, agenda management and video streaming to five vendors. Every one of those is covered.
The practical steps are the same for each. Ask the vendor for a current accessibility conformance report (often called a VPAT) and the date it was tested. Put WCAG 2.1 AA in the contract at renewal, with a remedy if they miss it. Then have someone try the flow a resident uses, with a keyboard and a screen reader, because the report describes the product and the resident uses your configuration of it. A vendor's claim is a starting point, not a finish line, and the rule holds the public entity responsible either way.
What to do in the next 90 days
Confirm your date. Look up your 2020 Census population, or your SAIPE figure if you are a school district, and write the date on the project plan.
Inventory what you have. The main site, every department site, every subdomain, every mobile app, every vendor portal residents reach through you, and the count of PDFs posted in the last two years. Most cities are surprised by the last number.
Get the site reviewed against WCAG 2.1 AA. An automated scanner catches the mechanical failures. A person with a keyboard and a screen reader catches the rest. The output should be a ranked list you can hand to a developer and to the board.
Fix the theme first. Contrast, focus styles, menu keyboard access and heading structure are set once and repair every page at the same time. Then the templates: forms, calendars, sliders. Then content: alt text, image flyers, captions.
Change how documents get made so new PDFs arrive tagged, and triage the old ones by whether a resident still needs them. We have a separate post coming on that, because on most city sites the documents are the largest single piece of work.
Publish an accessibility statement with a way to report a problem and a way to get content in another format. It is not required by the rule, but it is what a resident and an investigator both look for first.
Where TopSyde fits
We host and maintain WordPress sites for public entities and for the agencies that build them, and we review sites against WCAG 2.1 AA for free. A senior developer scans every page, works the pages residents use most with a keyboard and a screen reader, and sends a written list in plain language: what fails, where, why it matters to a resident, and what to fix first. The findings are yours whether or not you hire us.
Fixes are quoted from the findings at our published development rate. Afterwards, most public entities keep the site on a plan at $89/mo per site, month to month, which covers hosting, updates tested on staging before they touch the live site, daily backups, security and the developer who did the work. That last part matters more than it sounds: a theme update can undo a contrast fix in one click, and a tested update cannot.
If you would rather start with something instant, the free site audit runs in about a minute and includes basic accessibility checks. The full review is on the ADA compliance page.
Frequently Asked Questions
Does the ADA web rule apply to a town with 3,000 residents?
Yes. Every state and local government is covered by Title II. Population only sets the date. A town under 50,000 in the 2020 Census has until April 26, 2028, and the standard is the same WCAG 2.1 Level AA that a city of a million has to meet by April 26, 2027.
Do we have to fix every old PDF on the site?
No. Documents posted before your compliance date are exempt unless residents still use them to apply for, access or take part in a service. Forms, applications and anything still in use need to be fixed. Old newsletters and past-year reports can stay as they are, ideally in a labelled archive. Everything you post after the date has to be accessible from the start.
Does an accessibility overlay widget satisfy the rule?
No. An overlay changes how a page is presented for some visitors. It does not change the HTML, the PDFs or the video the standard measures, and the rule measures the content itself. In 2025 the FTC ordered one overlay vendor to pay $1 million over claims that its widget could make any website WCAG compliant.
What happens if we miss the date?
The rule does not add a new penalty schedule. Enforcement is the same as the rest of Title II: complaints to DOJ, DOJ investigations, and private lawsuits, which have been filed over government websites for years. What changes on the compliance date is that WCAG 2.1 AA becomes the measure, so there is no longer an argument about what accessible means. Ask your attorney about your own exposure; this is a developer's summary, not legal advice.
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Founder & Lead Developer
20+ years full-stack development, WordPress, AI tools & agents
Colton is the founder of TopSyde with 20+ years of full-stack development experience spanning WordPress, cloud infrastructure, and AI-powered tooling. He specializes in performance optimization, server architecture, and building AI agents for automated site management.
