The DOJ Title II deadline for small governments, explained

In 2024, the Department of Justice finalized a rule under Title II of the ADA requiring state and local government websites and mobile apps to meet WCAG 2.1 Level AA — a specific, testable web accessibility standard, not a vague good-faith requirement.

The actual dates

In April 2026, DOJ extended the original compliance dates by a year. As it stands now:

• Entities serving a population of 50,000 or more must comply by April 26, 2027.
• Smaller entities and special districts — the water, fire, library, and transit districts most likely to be reading this — have until April 26, 2028.

The technical requirement itself didn't change. WCAG 2.1 AA is still the bar, for everyone.

Why the deadline isn't the whole story

Two things matter more than the calendar date. First, litigation doesn't wait for a compliance deadline — website accessibility lawsuits have been rising every year regardless, and plaintiff's firms are already expanding into public entities. Second, if you're a K-12 school district, you're already covered today under Section 504 of the Rehabilitation Act, and the Department of Education's Office for Civil Rights actively investigates website accessibility complaints against districts — 2028 has no bearing on that.

What actually counts as compliant

Not an overlay widget. The FTC fined accessiBe $1 million in 2025 specifically for claiming its widget made sites compliant when it didn't, and a similar case against UserWay is moving through the courts. Real compliance means the underlying site and its documents — including the PDFs, which are usually the biggest gap — actually meet the standard.

Where to start

The honest first step is knowing where you actually stand. A scan won't tell you everything, but it will tell you enough to prioritize — and it takes a few minutes, not a procurement cycle.