Free tool · ADA Title II
ADA Title II deadline finder: April 2027 or April 2028?
Under the ADA Title II web rule as extended in April 2026, a state or local government with a total population of 50,000 or more must meet WCAG 2.1 Level AA by April 26, 2027. Smaller governments and special district governments have until April 26, 2028. The Census population of the government decides, not the number of people served. These dates come from DOJ’s April 2026 interim final rule, which a lawsuit filed May 21, 2026 challenges; as of November 3, 2026, no ruling had been reported and the dates remain in the rule text.
Find your buyer’s date
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The rules behind the answer
28 CFR 35.200(b) sets two dates. A public entity, other than a special district government, with a total population of 50,000 or more must comply by April 26, 2027. A public entity with a total population under 50,000, or any special district government, must comply by April 26, 2028. In both cases the standard is WCAG 2.1 Level A and AA, and it covers web content and mobile apps the entity provides “directly or through contractual, licensing, or other arrangements.”
“Total population” is defined in 28 CFR 35.104: the entity’s own decennial Census population; for an independent school district, its most recent SAIPE estimate; and for a body with no Census population of its own that is an instrumentality or commuter authority of one or more governments, the combined Census population of those governments. The Department of Justice adds that a city school district uses the city’s population, a county school district the county’s, and a department of a larger government — a city police department or library — the population of the government it belongs to.
| Buyer | Population that counts | Compliance date |
|---|---|---|
| A State, or one of its agencies, departments or public universities | The State’s 2020 Census population. All 50 States, the District of Columbia and Puerto Rico are above 50,000 (the smallest, Wyoming: 576,851). | April 26, 2027 |
| Guam, the U.S. Virgin Islands, American Samoa or the Northern Mariana Islands | The territory’s population in the most recent decennial Census | April 26, 2027 if 50,000 or more; otherwise April 26, 2028 |
| A county, city, town, township or village | Its 2020 Census population | April 26, 2027 if 50,000 or more; otherwise April 26, 2028 |
| A department of a larger government (police, library, parks…) | The population of the government it belongs to — for example the city that runs it | April 26, 2027 if 50,000 or more; otherwise April 26, 2028 |
| A city or county school district | The population of the city, or of the county | April 26, 2027 if 50,000 or more; otherwise April 26, 2028 |
| An independent school district | Its estimate in the most recent Small Area Income and Poverty Estimates (SAIPE) | April 26, 2027 if 50,000 or more; otherwise April 26, 2028 |
| A body of one or more governments with no Census population of its own (joint agency, commuter authority…) | The combined 2020 Census population of the governments behind it | April 26, 2027 if 50,000 or more; otherwise April 26, 2028 |
| A special district government (for example a water, fire, park or library district the Census gives no population) | Not needed | April 26, 2028 |
Private businesses, nonprofits and private colleges are not public entities: this rule, under Title II of the ADA, does not apply to them. The rule lets a public entity show that compliance would cause a fundamental alteration or undue financial and administrative burdens; that is a defense, not a later date.
Selling software to one of these buyers?
Because the rule reaches content provided through licensing arrangements, a covered buyer has its own reason to check your product against WCAG 2.1 AA before that date. We evaluate web products against WCAG 2.1 Level A and AA and write the ACR on ITI’s VPAT® 2.5Rev template: $1,490 fixed, in five business days, with a fix list and one retest.
Does the rule apply to software vendors? Free accessibility snapshot
Last reviewed: September 30, 2026. Not legal advice: the buyer’s solicitation or contract governs what it requires from you.
Sources
Primary sources only. Each was read on September 30, 2026.
- 28 CFR 35.200 — Requirements for web and mobile accessibility (ADA Title II) — eCFR, current text.
- 28 CFR 35.104 — Definitions (“public entity,” “total population,” “special district government”) — eCFR, current text.
- Extension of Compliance Dates … Accessibility of Web Information and Services of State and Local Government Entities — interim final rule, 91 FR 20902 (FR Doc. 2026-07663) — Department of Justice, Federal Register, April 20, 2026.
- National Federation of the Blind Challenges Last-Minute Deadline Extensions for Website and Mobile App Accessibility (lawsuit filed May 21, 2026) — Seyfarth Shaw, ADA Title III blog, June 2026.
- Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments — ADA.gov, Department of Justice (updated for the April 2026 extension).
- 2020 Census apportionment data — resident population of the 50 States, the District of Columbia and Puerto Rico (CSV) — U.S. Census Bureau.
- 2020 Census — data and results — U.S. Census Bureau.
- Small Area Income and Poverty Estimates (SAIPE), including school district population estimates — U.S. Census Bureau.