April 24, 2026:
Is Your Government Website Compliant?

ADA Title II prohibits discrimination by state and local government entities. On April 24, 2024, the DOJ published a final rule (28 CFR Part 35) requiring that all web content and mobile apps of state and local governments conform to WCAG 2.1 Level AA. This rule applies to every government entity that receives federal funding or operates as a public entity, including cities, counties, school districts, public universities, courts, and special districts.

Yes. The rule applies to all state and local government entities regardless of size. Entities serving populations of 50,000 or more must comply by April 24, 2026. Entities serving populations under 50,000 must comply by April 26, 2027. Special districts (water, fire, transit, etc.) follow the same timeline based on the population they serve.

The DOJ can pursue enforcement actions with civil penalties up to $75,000 for a first violation and $150,000 for subsequent violations under the ADA. Additionally, private plaintiffs can file lawsuits seeking injunctive relief. Plaintiff attorneys are already organizing to file suits beginning May 2026 against non-compliant government websites. Unlike private businesses, government entities cannot claim undue burden as easily because they have a constitutional obligation to provide equal access.

WCAG (Web Content Accessibility Guidelines) 2.1 Level AA is the specific standard referenced in the DOJ's Title II rule. It includes 50 success criteria covering perceivable content (alt text, captions, color contrast), operable interfaces (keyboard navigation, timing), understandable content (readable text, predictable behavior), and robust markup (valid HTML, name/role/value). The rule requires conformance with all Level A and Level AA criteria.

For a typical municipal website, remediation takes 3 to 6 months depending on the size and complexity of the site. A city website with 500+ pages, embedded PDFs, video content, and third-party widgets will take longer than a small township site with 50 pages. Starting with a compliance audit identifies the scope of work and lets you prioritize the highest-risk violations first. The longer you wait, the less time your team has to fix issues before the deadline.

Yes. The rule covers web content, which includes PDFs, Word documents, spreadsheets, and other files published on government websites. Meeting agendas, budget documents, permit applications, and public notices all need to be accessible. PDF remediation is often the most time-consuming part of compliance because many government sites have hundreds or thousands of legacy PDFs.

Government entities are responsible for ensuring third-party content and widgets on their websites are accessible. This includes embedded maps, payment portals, meeting management systems, permitting software, and social media feeds. If a third-party tool on your site is not accessible, your entity is still liable. Audit your site to identify which third-party components need attention.