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ADA Website Compliance Deadline: April 24, 2026

The Department of Justice's final rule requires state and local government websites to conform to WCAG 2.1 Level AA. Here is what the rule says, who it applies to, and what happens if you are not ready.

Timeline: Key Dates

April 24, 2024

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

Rule takes effect

The final rule becomes effective 60 days after publication. Government entities should begin planning compliance efforts.

April 24, 2026

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.

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.

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:

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

What happens if you do not comply?

DOJ enforcement actions

The Department of Justice actively investigates and brings enforcement actions against non-compliant government entities. Recent enforcement has targeted city, county, and state government websites with significant remediation requirements and monitoring periods.

Private lawsuits

Individuals can file private lawsuits under ADA Title II. Plaintiff law firms increasingly target government websites, especially around compliance deadlines. ADA web accessibility lawsuit filings have increased year over year.

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 that settlements typically include.

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.

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
  • Hard deadline: April 24, 2026 (large) / 2027 (small)
  • 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 specifically applies to Title II (government), private businesses should not wait. 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 you need to do now

1

Audit your current state

Run an automated accessibility scan to identify existing WCAG 2.1 AA violations. This gives you a baseline score and a prioritized list of issues to fix.

2

Prioritize critical and serious issues

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 trigger complaints.

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 ~30% of accessibility issues. Supplement with manual testing using screen readers (NVDA, VoiceOver), keyboard-only navigation, and browser zoom at 200%.

5

Document your conformance

Create a VPAT (Voluntary Product Accessibility Template) or accessibility statement documenting your conformance level, known issues, and remediation timeline.

6

Establish ongoing monitoring

Accessibility is not one-and-done. New content, redesigns, and third-party integrations can introduce regressions. Build accessibility testing into your development and content workflows.

Start with a free compliance scan

Get your WCAG 2.1 AA compliance score in under 30 seconds. See how many critical, serious, moderate, and minor issues your website has — no account required.

Scan Your Website Free

Frequently Asked Questions

When is the ADA website compliance deadline?

State and local government entities serving populations of 50,000 or more must make their websites and mobile apps conform to WCAG 2.1 Level AA by April 24, 2026. Smaller entities (under 50,000 population) have until April 24, 2027. This deadline was set 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 if my website isn't ADA compliant by 2026?

Non-compliant government entities face DOJ enforcement actions, private lawsuits under ADA Title II, complaints filed with the Department of Health and Human Services, and settlement demands. The average ADA web accessibility settlement exceeds $75,000, not including legal fees and remediation costs. The DOJ has increasingly pursued web accessibility enforcement, with landmark settlements against major government entities.

Does the ADA website deadline apply to private businesses?

The April 2026 deadline specifically applies 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.

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