Every state and local government website has one of two ADA compliance dates. Public entities with a total population of 50,000 or more, plus state agencies and public universities, must meet WCAG 2.1 Level AA by April 26, 2027. Entities under 50,000 and every special district government have until April 26, 2028. Both dates are one year later than the original 2024 rule set, because the Department of Justice extended them in April 2026, and there is no reason to plan for a second extension.
The two dates, and how DOJ got here
The Department of Justice published its Title II web accessibility rule in the Federal Register on April 24, 2024. It named WCAG 2.1 Level AA as the standard for the web content and mobile apps of state and local governments and set two compliance dates two and three years out: April 24, 2026 for public entities with a population of 50,000 or more, and April 26, 2027 for smaller entities and special districts.
In April 2026, days before the first date, DOJ issued an interim final rule that extended both dates by one year. The new dates are April 26, 2027 and April 26, 2028. The interim rule took public comment through June 22, 2026. Nothing else in subpart H changed: the same standard, the same definition of who is covered, the same five exceptions. DOJ's own rule page on ada.gov carries the current dates.
Two things follow from that history. The rule survived a change of administration and a comment period that included requests to withdraw it, so it is not going away. And an entity that was planning against April 2026 and stopped when the extension came has spent five months of a twelve-month gift. The rule's requirements are unchanged; the only thing that moved is the day someone can measure you against them.
Find your date in five minutes
The rule sorts public entities by "total population," and the method depends on what kind of entity you are. DOJ's first-steps guide walks through each case.
| Kind of entity | Where the number comes from | Date |
|---|---|---|
| City, town, village, township, county | 2020 decennial Census, total population | 2027 at 50,000 or more, otherwise 2028 |
| Department of a larger government (library, clerk, police) | The population of the government it belongs to | Same as that government |
| Independent school district | The most recent Small Area Income and Poverty Estimates for the district | 2027 at 50,000 or more, otherwise 2028 |
| State agency, state court, state university | The state's 2020 Census population | April 26, 2027 |
| Special district government (library, water, fire, park, transit, hospital) | No Census population is calculated | April 26, 2028 |
For a city or county, search the Census Bureau's QuickFacts for your name and read the 2020 population line. For a school district, the SAIPE school district estimates are published as a downloadable table; the figure counts residents within the district's boundaries, not enrolled students, which is why most districts land under 50,000 and large urban districts land over it.
The special district definition catches people out in both directions. A special district is a public entity, other than a county, municipality, township or independent school district, that state law allows to provide one or a limited number of functions with enough independence to be its own government. A library district with its own board and levy is one. A library that is a department of the city is not, and it takes the city's date. Our pages for cities and counties, school districts and special districts go through each case.
Write the date down and put it on the plan. Everything that follows is measured from it.
What compliance means on the date
The rule says that on and after the compliance date, the web content and mobile apps a public entity provides or makes available must conform to WCAG 2.1 Level AA. Conformance is a property of the content as delivered to the visitor: the HTML, the images and their text alternatives, the documents, the video. It is not a certificate, a badge, a policy or a purchase.
That has three practical consequences. There is no grace period: the day after the date, a page that fails is a page that fails. There is no partial credit for a plan: an entity that has fixed the homepage and scheduled the rest has met the standard on the homepage. And the exceptions are the only content that does not have to conform, and each of them carries a condition. The pre-existing document exception ends the moment a resident needs the document to get a service. Content from a vendor is not third-party content; it is yours.
The rule also states what happens when full conformance is not possible. If an entity can show that conformance would fundamentally alter a service or impose undue financial and administrative burdens, it still has to comply to the maximum extent possible. The undue-burden determination has to be made by the head of the public entity or a designee, after considering all of the entity's resources, and it has to be accompanied by a written statement of the reasons. That is a high bar by design, and a budget line item is not a burden.
Working backward from April 26, 2027
Plans that start at the date and count backward hold up better than plans that start now and hope. The table uses months before your date so it works for both 2027 and 2028.
| Months before your date | What should be done |
|---|---|
| 18 or more | Date confirmed. Inventory of every site, subdomain, app, vendor portal and the PDF count. A WCAG 2.1 AA review with a ranked findings list. Accessibility clause drafted for every vendor renewal. |
| 12 to 18 | Theme and template fixes shipped: contrast, focus, menus, sliders, heading structure, forms. This is the smallest pile of work and repairs the most pages, so it goes first. |
| 9 to 12 | Document process changed: Word templates, export settings, agenda vendor output. From here every new PDF arrives tagged. Forms residents use moved to a form plugin or remediated. |
| 6 to 9 | Vendor portals tested with a keyboard and a screen reader, findings sent to vendors with the renewal date attached. Caption workflow running for recorded and live meetings. |
| 3 to 6 | Content backlog: alt text on meaningful images, image flyers converted to pages, current documents remediated, old ones moved to a labelled archive. Accessibility statement published. |
| 0 to 3 | Re-review of the whole site. Fix what drifted. Staff trained on the three habits that undo the work: flyers as images, placeholder text as labels, untagged exports. |
For an entity on the 2027 date, "18 or more" is now. For an entity on the 2028 date it is next spring, which is a comfortable place to be and a bad reason to wait, because the vendor renewals and the document process take calendar time no matter how much developer time you buy.
What most entities underestimate
Four items blow up plans, and none of them is the theme.
The PDF library is nearly always larger than anyone thought. A mid-sized city posts an agenda, a packet and minutes for every meeting of every body, plus codes, budgets, plans and forms. Five years is a few thousand files, and the fix is a process change first and remediation second, which is why it sits in the middle of the timeline and not at the end.
Vendor portals move on the vendor's schedule. The bill-pay system, the records-request system, the agenda platform and the meeting-video host are all covered as your content, and the lever you have is the contract. If a renewal falls after your date, the accessibility clause needs to go in now, with a remedy.
Department and school sites multiply the content work. A district with twenty school sites shares one theme, so the theme fixes apply to all of them at once, but every site has its own flyers, images and PDFs.
Captions on meeting video are a recurring cost, not a one-time fix. Automatic captions corrected by a person before the recording is linked, and a captioning service for live streams, is the workable shape for most entities. It needs to be somebody's job.
If you will miss the date
Some entities will reach April 2027 with the theme fixed, the forms fixed, and a document backlog still in progress. The rule does not offer an extension for that, but it does say what a responsible position looks like.
Put the services residents depend on first: forms, payments, alerts, current codes and fee schedules. Those are what a complaint is about. Publish an accessibility statement that says what conforms, what is in progress, and how a resident can get any content in another format or report a barrier, with a named contact and a response commitment. Keep the findings list and the fix log; an investigator asks for exactly that. If a specific item is beyond the entity's resources, the head of the entity signs the written undue-burden statement the rule requires, and the entity provides the information another way in the meantime.
None of that is legal advice, and your attorney should read the rule with you. It is what a developer sees work when the calendar wins.
Where TopSyde fits
We host and maintain WordPress sites for public entities and for the agencies that build them. The review is free: a senior developer scans every page, works the pages residents use with a keyboard and a screen reader, counts the documents, and sends a written list ranked by what to fix first, with the vendor items separated out so they can go into renewals. The findings are yours whether or not you hire us.
Fixes are quoted from that list at our published development rate. Afterwards, hosting and maintenance is $89/mo per site with no contract, and every update is tested on staging before it goes live, so the site you had on your compliance date is the site you still have a year later. The request form is on the ADA compliance page; the free site audit is the instant version if you want a number today.
Frequently Asked Questions
Will DOJ extend the ADA website deadline again?
Nobody outside DOJ knows, and the April 2026 extension was announced days before the original date, which is not a schedule anyone can plan around. The rule was kept in force through a comment period that included requests to withdraw it. Treat April 26, 2027 and April 26, 2028 as firm; a second extension, if one came, would be a bonus rather than a plan.
Does the 2027 date apply to a state university with 8,000 students?
Yes. A public entity that is part of a state government uses the state's population, and every state is over 50,000. Enrollment, staff count and budget do not enter into it. Community colleges that are part of a state system are on the same date; a college district that is a separate local government uses its own population.
Is there a grace period after the compliance date?
No. The rule states that content must conform on and after the date. The only content that does not have to conform is what the five exceptions cover, and each carries a condition. An entity that cannot fully conform still has to provide access to the maximum extent possible.
Our vendor says they cannot meet WCAG 2.1 AA by our date. What are our options?
The rule makes the public entity responsible for what its contractors provide, so the vendor's timeline is your problem. Get the commitment and a date in writing, add an accessibility clause and a remedy at renewal, and test the flow yourself rather than relying on their conformance report. If the vendor cannot get there, the alternatives are a different vendor, an accessible path to the same service on your own site, or a documented undue-burden determination with the information provided another way in the meantime.
Topics
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.
