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Updated — IFR effective April 20, 2026

The ADA 2026 Deadline Was Extended. New Dates: 2027 and 2028.

A DOJ Interim Final Rule effective April 20, 2026 extended both ADA Title II web accessibility compliance deadlines by one year. The original April 2026 date is no longer operative. Large government entities now have until April 26, 2027. Small entities and special districts have until April 26, 2028.

What changed: original vs. current deadlines

Entity tierOriginal deadlineCurrent deadline (post-IFR)
Large entities (≥50,000 population)April 24, 2026April 26, 2027
Small entities (<50,000) + special districtsApril 26, 2027April 26, 2028

Source: DOJ Interim Final Rule, Federal Register doc 2026-07663, effective April 20, 2026. Both deadlines require full conformance with WCAG 2.1 Level AA (June 2018 version).

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Timeline: Key Dates

April 24, 2024— passed

DOJ publishes final rule

The Department of Justice publishes the final rule amending 28 CFR Part 35, establishing WCAG 2.1 AA as the required standard for state and local government web content and mobile apps.

June 24, 2024— passed

Rule takes effect

The final rule became effective 60 days after publication, starting the compliance clock for covered entities.

April 20, 2026— IFR published

DOJ Interim Final Rule — deadlines extended one year

A DOJ Interim Final Rule (Federal Register doc 2026-07663) extended both compliance deadlines by one year. The IFR supersedes the original April 2026 and April 2027 dates.

April 26, 2027

Large entity deadline

State and local government entities serving populations of 50,000 or more must have all web content and mobile apps conforming to WCAG 2.1 Level AA. This is the operative deadline for large entities.

April 26, 2028

Small entity and special district deadline

Government entities serving populations under 50,000, and all special district governments, must comply. Special districts are in this tier regardless of population because the U.S. Census Bureau does not calculate population figures for them.

What does the rule require?

The DOJ's final rule (28 CFR Part 35) requires all web content and mobile apps of state and local government entities to conform to WCAG 2.1 Level AA (the June 2018 version). This is the internationally recognized standard published by the World Wide Web Consortium (W3C). The IFR did not change the technical standard — only the compliance dates.

WCAG 2.1 AA includes 50 success criteria organized under four principles: content must be Perceivable (text alternatives, captions, contrast), Operable (keyboard accessible, no seizure triggers), Understandable (readable, predictable), and Robust (works with assistive technology).

Limited exceptions

The rule includes narrow exceptions for: archived web content (not updated after the compliance date and stored for reference only), content posted by third parties (comments, user-generated content) that the entity does not control, and pre-existing conventional documents (PDFs, Word docs) unless they are currently used to access government services.

Who must comply?

The rule applies to all state and local government entities covered by ADA Title II. This includes:

City and county government websites
State agency websites and portals
Public university and college websites
Public school district websites
Court system websites and e-filing portals
DMV and motor vehicle services
Public transit agency websites and apps
Public library websites and catalogs
Public utility websites and payment portals
Law enforcement and emergency services sites
Parks and recreation department websites
Public health department websites

Title II vs Title III: Government vs Private Business

ADA Title II — Government

  • Applies to state and local government entities
  • Specific standard: WCAG 2.1 Level AA
  • Large entity deadline: April 26, 2027
  • Small entity + special district deadline: April 26, 2028
  • DOJ enforcement + private lawsuits
  • Federal funding implications

ADA Title III — Private Business

  • Applies to "places of public accommodation"
  • No specific technical standard mandated by DOJ
  • No specific deadline — ongoing obligation
  • WCAG 2.1 AA is the de facto benchmark in settlements
  • 3,117 federal filings in 2025, up 27% YoY (Seyfarth Shaw)

The Title II deadlines apply specifically to government entities. Private businesses should not treat this as someone else's problem — courts have increasingly ruled that websites are "places of public accommodation" under Title III, and WCAG 2.1 AA is the standard referenced in virtually all ADA web accessibility settlements.

How to use the extended deadline time wisely

The extension gives government entities more time to remediate, but the requirements have not changed. Typical remediation timelines for government sites run three to twelve months depending on complexity. Entities that begin now can verify compliance, test with assistive technology, and document their process before the new deadline.

1

Run a baseline accessibility scan

An automated WCAG 2.1 AA scan gives you a compliance score, a prioritized list of violations, and a timestamped record that you began assessing your status. This documentation matters if a complaint is ever filed.

2

Prioritize critical and serious issues first

Focus on violations that completely block access: missing alt text on key images, keyboard traps, unlabeled form fields, and color contrast failures. These are the most common complaint triggers and are typically the fastest to remediate.

3

Remediate systematically

Work through violations by WCAG principle, starting with Perceivable and Operable criteria. Use a compliance checklist to track progress across all 50 Level AA criteria.

4

Test with assistive technology

Automated tools catch many common failures but cannot catch everything. Supplement with manual testing using screen readers (NVDA, VoiceOver, JAWS), keyboard-only navigation, and browser zoom at 200%.

5

Publish an accessibility statement

Document your conformance level, any known limitations, your remediation timeline, and a contact point for users reporting barriers. An accessibility statement demonstrates good-faith effort and can reduce complaint escalations.

6

Establish ongoing monitoring

New content, redesigns, and third-party integrations can introduce regressions. Monthly monitoring keeps you from slipping back below compliance as your site evolves — a critical concern for government sites that change frequently.

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Frequently Asked Questions

Was the ADA 2026 website compliance deadline extended?

Yes. A DOJ Interim Final Rule (Federal Register doc 2026-07663, effective April 20, 2026) extended both ADA Title II web accessibility deadlines by one year. The original April 24, 2026 deadline for large government entities (serving populations of 50,000 or more) became April 26, 2027. The original April 26, 2027 deadline for small entities and special districts became April 26, 2028.

What are the current ADA Title II compliance deadlines?

Under the DOJ Interim Final Rule effective April 20, 2026: large government entities (serving populations of 50,000 or more) must comply by April 26, 2027; small government entities (under 50,000 population) and all special district governments must comply by April 26, 2028. Both deadlines require full conformance with WCAG 2.1 Level AA (June 2018 version).

What does the rule require?

The DOJ's final rule (28 CFR Part 35) requires all state and local government web content and mobile apps to conform to WCAG 2.1 Level AA. This means all web content must be Perceivable (text alternatives for images, captions for video, sufficient color contrast), Operable (keyboard navigable, no seizure triggers), Understandable (readable, predictable), and Robust (compatible with assistive technology including screen readers).

Why were the deadlines extended?

The DOJ published an Interim Final Rule (effective April 20, 2026) extending both compliance deadlines by one year. The IFR was published in the Federal Register under document number 2026-07663. The extension pushed the large-entity deadline from April 24, 2026 to April 26, 2027, and the small-entity/special-district deadline from April 26, 2027 to April 26, 2028.

Does the ADA deadline apply to private businesses?

The Title II deadlines specifically apply to government entities. However, private businesses are covered under ADA Title III, which courts have increasingly interpreted to include websites. While Title III has no specific technical standard or deadline, WCAG 2.1 AA is referenced in virtually all ADA web accessibility settlements and consent decrees. Federal web-accessibility filings reached 3,117 in 2025, up 27% year-over-year (Seyfarth Shaw).

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