The ADA Title II Deadline Has Passed. Now What?
The DOJ's April 24, 2026 compliance deadline for large government websites has come and gone. Enforcement is now active. Here is what that means for your organization, what the risks are, and what to do immediately.
Enforcement is active as of April 24, 2026
Government entities with populations of 50,000 or more that have not achieved WCAG 2.1 AA conformance are now in violation of 28 CFR Part 35. The DOJ can initiate enforcement proactively — it does not need to wait for a complaint. Individuals can also file private lawsuits immediately. If your site is non-compliant, every day without a documented remediation effort increases your exposure.
If you are a small entity (under 50,000 population), your deadline is April 24, 2027. You have time — but enforcement of the large-entity rule signals the DOJ is serious about this, and the correction costs only go up the longer you wait.
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Scan Your Site FreeTimeline: Key Dates
April 24, 2024— passed
DOJ publishes final rule
The Department of Justice publishes the final rule amending 28 CFR Part 35 to establish specific technical requirements for web and mobile accessibility under ADA Title II.
June 24, 2024— passed
Rule takes effect
The final rule became effective 60 days after publication. Government entities had two years to reach full compliance.
April 24, 2026— enforcement active
Large entity deadline — passed
State and local government entities serving populations of 50,000 or more were required to have all web content and mobile apps conforming to WCAG 2.1 Level AA. This deadline has passed. Enforcement is now active.
April 24, 2027
Small entity deadline
Government entities serving populations under 50,000 must comply. Special district governments also fall under this deadline regardless of population. This is the last remaining compliance date.
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. This is the internationally recognized standard published by the World Wide Web Consortium (W3C).
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. Password-protected content used for official business must still comply.
Who must comply?
The rule applies to all state and local government entities covered by ADA Title II. This includes:
What enforcement looks like now
DOJ enforcement actions
The Department of Justice can now investigate and bring enforcement actions against non-compliant large government entities without waiting for a complaint. Recent enforcement has targeted city, county, and state government websites with significant remediation requirements and monitoring periods lasting years.
Private lawsuits
Individuals can file private lawsuits under ADA Title II. Plaintiff law firms actively monitor government websites for non-compliance. Filing activity historically spikes after compliance deadlines as the legal standard becomes unambiguous.
Settlement costs
The average ADA web accessibility settlement exceeds $75,000 according to UsableNet's 2024 report. This does not include legal defense costs, mandatory remediation, or ongoing monitoring requirements — which settlements typically require for 2–3 years.
Federal funding risk
Non-compliance with ADA Title II can affect federal funding eligibility. Entities receiving federal financial assistance must also comply with Section 504 of the Rehabilitation Act, which carries additional enforcement mechanisms through funding agencies.
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 24, 2026 — passed, enforcement active
- Small entity deadline: April 24, 2027
- 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
- 4,600+ lawsuits filed in 2024 (UsableNet)
While the April 2026 deadline applied to Title II (government), 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.
What to do if you missed the deadline
Enforcement is active, but documented remediation effort matters. Organizations that can show active, good-faith compliance work are in a significantly better position than those with no record of action.
Audit your current state immediately
Run an automated accessibility scan to identify existing WCAG 2.1 AA violations. This gives you a baseline score, a prioritized list of issues, and — critically — a timestamped record that you began assessing your compliance status.
Prioritize critical and serious issues first
Focus on issues that completely block access: missing alt text, keyboard traps, missing form labels, and insufficient color contrast. These are the violations most likely to form the basis of complaints and are typically the fastest to remediate.
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.
Test with assistive technology
Automated tools catch ~30% of accessibility issues. Supplement with manual testing using screen readers (NVDA, VoiceOver), keyboard-only navigation, and browser zoom at 200%.
Publish an accessibility statement
Create an accessibility statement documenting your conformance level, known issues, and remediation timeline. This demonstrates good-faith effort and gives users a contact point for reporting barriers — which can head off formal complaints.
Establish ongoing monitoring
New content, redesigns, and third-party integrations can introduce regressions. Build accessibility testing into your development and content workflows so compliance is maintained, not just achieved once.
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Start Monthly Monitoring — $15/mo →Frequently Asked Questions
Has the ADA website compliance deadline passed?
Yes. The compliance deadline for large government entities (serving populations of 50,000 or more) passed on April 24, 2026. These entities are now subject to active DOJ enforcement. Small government entities (under 50,000 population) still have until April 24, 2027. This deadline was established by the DOJ's final rule published April 24, 2024 (28 CFR Part 35).
What are the new ADA requirements for websites?
The DOJ's 2024 rule requires 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, operable, understandable, and robust for users with disabilities. Specific requirements include text alternatives for images, keyboard navigability, sufficient color contrast, captions for video, and compatibility with assistive technologies like screen readers.
Does my government website need to be WCAG compliant?
If you are a state or local government entity — including cities, counties, public schools, public universities, courts, DMVs, public transit agencies, and public libraries — yes. The DOJ's rule applies to all web content and mobile apps used by these entities to provide services, programs, or activities to the public.
What happens now that my government website missed the ADA deadline?
Non-compliant government entities are now subject to active DOJ enforcement, private lawsuits under ADA Title II, and complaints filed with the Department of Health and Human Services. Enforcement does not require waiting for a complaint — the DOJ can initiate investigations proactively. The average ADA web accessibility settlement exceeds $75,000, not including legal fees, mandatory remediation costs, and monitoring periods. The strongest response is to begin remediation immediately and document your compliance effort.
Does the ADA website deadline apply to private businesses?
The April 2026 deadline specifically applied to government entities under ADA Title II. 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. Over 4,600 ADA web accessibility lawsuits were filed against private businesses in 2024.