In April 2024 the U.S. Department of Justice published a final rule under Title II of the Americans with Disabilities Act. For the first time it sets a technical standard for the websites and mobile apps of state and local governments: WCAG 2.1 Level AA.
The rule originally set compliance dates in 2026 and 2027. In April 2026 the Department issued an interim final rule extending them by a year:
| Who | Compliance date |
|---|---|
| Public entities with a total population of 50,000 or more | April 26, 2027 |
| Public entities under 50,000, and all special district governments | April 26, 2028 |
School districts use the population of the jurisdiction around them. The standard itself, WCAG 2.1 AA, did not change. The Department has said more rulemaking is planned and the extension is being challenged, so treat these dates as subject to change and check the ADA.gov small entity compliance guide for the current version. The original ADA.gov fact sheet explains what the rule covers.
The extra year is time to fix things properly — not a reason to wait. Residents with disabilities need the site to work today, and the fixes take longer than most teams expect.
What the rule covers
The rule applies to web content and mobile apps that a public entity provides or makes available, directly or through contractors. In practice that includes:
- Your main website and any department or program sites
- Documents you post, such as PDFs, Word files and spreadsheets
- Online forms, payment pages and sign-ups you link residents to
- Video and audio you publish, including meeting recordings
- Mobile apps you offer to the public
The standard, WCAG 2.1 AA, is published by the World Wide Web Consortium. The W3C’s WCAG overview is the best plain-language starting point.
The exceptions — and their limits
The rule lists a handful of exceptions. Read them carefully: each has conditions.
- Archived web content — content created before the compliance date, kept only for reference, research or recordkeeping, not changed since, and kept in an area clearly marked as archived.
- Preexisting conventional electronic documents — PDFs and similar files posted before the compliance date, unless people still use them to apply for, access or take part in your services. An old permit application that residents still download is not exempt.
- Content posted by third parties, such as public comments, when the government isn’t contracting for it.
- Individualized, password-protected documents about a specific person, such as a utility bill.
- Preexisting social media posts made before the compliance date.
Your attorney should confirm how these apply to you. The safe working assumption: anything residents use today must meet the standard.
A plan that fits a small staff
- Measure where you are. Run an automated scan of your pages and PDFs. Automated tools find many problems, not all of them, so plan a manual keyboard and screen reader check of your top pages too.
- Fix the templates first. Header, menus, footer and color contrast appear on every page; one fix there repairs hundreds of pages.
- Triage documents. Archive what nobody uses, convert busy PDFs (rate schedules, notices) to web pages, and remediate the rest.
- Caption video. Meeting recordings need captions; live meetings benefit from live captions too.
- Fix forms. Every field needs a visible label, errors must be described in text, and there should be no time limits or puzzle CAPTCHAs.
- Skip the overlay. Overlay widgets that promise instant compliance don’t fix the underlying content. In 2025 the Federal Trade Commission ordered one overlay vendor, accessiBe, to stop claiming its tool could make websites WCAG-compliant (summary by Adrian Roselli). Fix problems at the source.
- Stop new problems. Most sites that get fixed slip back within months, because every new upload is a new chance for missing alt text or an untagged PDF. Put a check in front of the publish button.
- Publish an accessibility statement with a way for residents to report barriers and request alternate formats.
How Sentra CMS helps
Sentra CMS checks every page, document, form and widget against WCAG 2.1 AA before it can be published, holds inaccessible PDFs until they’re fixed, and gives you a nightly scan and a compliance report for your council. See how enforcement works or run a free scan of your current site.
This post is general information, not legal advice.