Questions · Deadlines and legal requirements
Was the ADA Title II web accessibility deadline delayed, and what are the new dates?
Yes. A Department of Justice interim final rule published April 20, 2026 moved each date back one year. Public entities with a total population of 50,000 or more must meet WCAG 2.1 Level AA by April 26, 2027; smaller entities and special district governments by April 26, 2028. The standard itself did not change.
The dates, before and after the extension
The 2024 rule gave state and local governments two or three years to make their web content and mobile apps meet WCAG 2.1 Level A and AA. The interim final rule of April 20, 2026 (91 FR 20902) took effect the day it was published and moved both dates back one year. Its comment period closed on June 22, 2026.
| Public entity | Original date | Current date |
|---|---|---|
| Total population of 50,000 or more | April 24, 2026 | April 26, 2027 |
| Total population under 50,000 | April 26, 2027 | April 26, 2028 |
| Special district governments | April 26, 2027 | April 26, 2028 |
Population decides the date, not size
The population is the census population of the government an entity belongs to, not the number of people it serves. DOJ’s own examples: a state university with 40,000 students in a state of 6,000,000 people must comply by April 2027; a police department in a city of 25,000 has until April 2028.
Status on September 30, 2026
The eCFR text of 28 CFR 35.200, up to date as of September 28, 2026, carries the 2027 and 2028 dates. DOJ wrote that it would consider proposing changes to the substance of the rule during the extension; no such proposal had appeared in the Federal Register as of September 30, 2026. Without one, and absent circumstances suggesting further delay, DOJ “fully anticipates implementing the regulation at the new deadline.” It added that covered entities have an “ongoing obligation” under Title II, whatever the dates.
The rule covers content a public entity provides “directly or through contractual, licensing, or other arrangements,” so the dates apply to the software it licenses too.
How ACR Desk handles this
We evaluate web products against WCAG 2.1 Level A and AA, the standard in the rule, and write the ACR on ITI’s VPAT® 2.5Rev WCAG edition: $1,490 fixed, in five business days, with a fix list and one retest. We don’t advise on whether or when the rule applies to a particular buyer.
Last reviewed: September 30, 2026. Not legal advice: rules change, and your buyer’s solicitation or contract governs what they require.
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.
- 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.
- 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).
- First Steps Toward Complying with the ADA Title II Web and Mobile Application Accessibility Rule — ADA.gov, Department of Justice (updated after the April 2026 extension).