ADA Title II Web Rule Deadlines: 2027 vs 2028

Short answer: Under the ADA Title II web rule, state and local governments with a total population of 50,000 or more must meet WCAG 2.1 Level AA by April 26, 2027. Entities under 50,000, and every special district government, have until April 26, 2028.

The Justice Department set these dates in an Interim Final Rule published on April 20, 2026. Before that, the first deadline was 1 year earlier.

Sources: Federal Register, 91 FR 20902; ADA.gov fact sheet.

What changed in April 2026?

The Department of Justice adopted the web and mobile app rule on April 24, 2024. That rule gave large entities until April 24, 2026 and smaller entities until April 26, 2027.

On April 20, 2026, the Department published an Interim Final Rule that pushed each date back by about 1 year. The rule took effect the same day.

Entities with 50,000 or more people: moved from April 24, 2026 to April 26, 2027.
Entities under 50,000 and special district governments: moved from April 26, 2027 to April 26, 2028.

The technical standard did not change. It is still WCAG 2.1 Level A and Level AA, as written in 28 CFR 35.200.

Sources: Federal Register, Interim Final Rule abstract; 28 CFR 35.200.

Which deadline applies to which entity?

The date depends on 2 things: the entity's total population and whether it is a special district government. Use the table below to find the row that fits.

ADA Title II web rule compliance dates by entity type
Entity type	How population is counted	Compliance date
State government and its agencies	State population in the latest decennial Census	April 26, 2027
City, county or town of 50,000 or more	Its own decennial Census population	April 26, 2027
City, county or town under 50,000	Its own decennial Census population	April 26, 2028
Independent school district	Small Area Income and Poverty Estimates (SAIPE) for the district	2027 if 50,000 or more; 2028 if under
City or county school district	Population of the city or county it belongs to	2027 if 50,000 or more; 2028 if under
Agency, instrumentality or commuter authority with no Census population	Combined Census population of the governments it serves	2027 if 50,000 or more; 2028 if under
Special district government (for example, many water, fire or library districts)	Population does not matter	April 26, 2028

Sources: 28 CFR 35.104 (definitions of total population and special district government); ADA.gov fact sheet, population guidance.

How do you find your entity's population?

For most governments, the number is in the 2020 Census data. ADA.gov says to use that figure.

Look up the entity's population in the most recent decennial Census.
If it is an independent school district, use the SAIPE estimate instead.
If it is a department or agency with no Census number, use the population of the government it belongs to.
If it is a commuter authority or other instrumentality of several governments, add their Census populations together.
If it is a special district government, stop. The date is April 26, 2028.

A school district is never a special district government under the rule. ADA.gov says so directly, so school districts always use the population steps above.

Sources: ADA.gov fact sheet; 28 CFR 35.104.

Worked example: 4 public entities in 1 county

Here is how the test plays out for a made-up county. The numbers are invented to show the method, not taken from a real place.

The county, 120,000 people in the 2020 Census. It has 50,000 or more people, so its date is April 26, 2027.
A town inside the county, 8,000 people. The town uses its own Census figure, not the county's, so its date is April 26, 2028.
The county parks department. It has no Census figure of its own, so it uses the county's 120,000 and shares the April 26, 2027 date.
A fire protection district set up under state law with its own board and budget. If it meets the definition of a special district government, its date is April 26, 2028, whatever the size of the area it serves.

The fire district case is the one to check carefully. The definition turns on state law, a limited set of functions, and enough administrative and fiscal autonomy to be a separate government.

A vendor-hosted payment page for the county parks department follows the department's date, not the vendor's. The rule reaches content provided through contracts.

Sources: 28 CFR 35.104 and 35.200; ADA.gov fact sheet.

What stays the same after the extension?

Only the dates moved. The rest of the rule reads as it did in 2024.

Scope. The rule covers web content and mobile apps an entity provides directly or through contractual, licensing or other arrangements.
Standard. WCAG 2.1 Level A and AA success criteria and conformance requirements.
Exceptions. Archived web content, preexisting conventional electronic documents, some third-party content, individualized password-protected documents and preexisting social media posts.
Limits. An entity can claim fundamental alteration or undue burdens, with a written statement from the head of the entity, under 28 CFR 35.204.

The exceptions are narrow. A preexisting PDF still has to conform if people use it to apply for or take part in a service, under 28 CFR 35.201(b).

There is also a narrow defense for small gaps. Under 28 CFR 35.205, an entity that misses a criterion can still meet the rule if the gap has so little impact that people with disabilities can still get the same information, interactions and transactions.

Treat that as a fallback, not a plan. The entity has to show the impact is minimal, which means it needs test records.

Source: 28 CFR 35.200 to 35.205.

What should a web team do before the date?

Work back from the date that applies. A city of 60,000 people has until April 26, 2027, so its team should plan around that date.

Inventory every site, portal, app and document library, including ones a vendor runs.
Test the top tasks first: payments, permits, applications, meeting agendas and job listings.
Sort documents into new, preexisting and archived, using the definitions in 28 CFR 35.104.
Write WCAG 2.1 AA into every new contract, renewal and change order.
Keep a dated log of fixes and open issues.

Source for the population rule and document definitions: 28 CFR 35.104.

What this means for subcontractors

The rule covers content provided "through contractual, licensing, or other arrangements." That brings the portals, forms and apps a prime or its subcontractors build into scope for the agency.

Expect agencies and primes to ask for WCAG 2.1 AA test results at acceptance. Clients with 50,000 or more people will ask first.

Our accessibility remediation and software work and delivery model pages explain how a subcontract can be scoped. New to the market? Start with what SLED means, or see the Konnex capability statement.

Source: 28 CFR 35.200(a).

Quick answers

Did the April 2026 rule change the WCAG version?

No. The standard is still WCAG 2.1 Level AA. Only the compliance dates moved, per the Interim Final Rule in the Federal Register.

When must a county of 30,000 people comply?

By April 26, 2028, because its total population is under 50,000. The rule uses the most recent decennial Census figure.

Is a school district a special district government?

No. ADA.gov states that a school district is not a special district government, so it follows the population test.