Who has the 2028 date
In April 2024 the Department of Justice published a rule under Title II of the Americans with Disabilities Act that sets a technical standard for the websites and mobile apps state and local governments provide: the Web Content Accessibility Guidelines version 2.1, Level AA. On April 20, 2026, the Department moved the compliance dates back by one year.
According to the Department's fact sheet, these governments now have until April 26, 2028:
- Governments with a total population under 50,000.
- All special district governments, whatever their size.
Governments of 50,000 or more have a year less, until April 26, 2027. We cover that group in our guide to the 2027 deadline.
Are you a special district?
The rule's definition describes a special district government as a public entity, other than a county, city, township or independent school district, that state law authorizes to provide one function or a few set functions, with enough administrative and fiscal independence to count as a separate government, and whose population the Census Bureau does not calculate.
School districts are not special districts. The fact sheet says a city school district uses the city's population, a county school district uses the county's, and an independent school district uses its estimate in the Census Bureau's Small Area Income and Poverty Estimates. A department inside a larger government, such as a town library or police department, uses the population of the town it belongs to.
What the extra year does not change
The extension moved the dates. In the same document, the Department wrote that covered governments have "an ongoing obligation" under Title II to make the services they offer online accessible to people with disabilities, whatever the compliance dates. If a resident asks for a form or a meeting video in a format they can use, you still need to help them now.
The Department also wrote that, unless it proposes changes or something suggests more delays, it "fully anticipates implementing the regulation at the new deadline." Plan for April 26, 2028.
The first six months: find out what you have
Through spring 2027, the work is mostly listing and deciding. Very little of it needs a developer.
- Confirm your date. Look up your population in the 2020 Census data, as the fact sheet suggests, or confirm that you are a special district.
- List everything residents use online: your main site, any department sites, mobile apps, and outside tools such as bill pay, permit portals, agenda software, calendars and meeting video.
- Name one person who keeps that list and owns the plan. In a small office it is usually someone already doing the website.
- Ask each vendor for accessibility documentation for its product and when its next update ships. The rule covers tools a contractor runs for you, so their answers shape your timeline.
The middle six months: fix what people use most
The fact sheet says the rule's exceptions exist so governments can make "current or commonly used information" accessible first. Use the same order.
- Start with the home page, contact and hours pages, and the forms where residents get something done: paying a bill, applying for a permit, requesting records, signing up for a program.
- Fix documents people still fill out. A permit application posted years ago does not get the older document exception if residents still use it.
- Delete pages that are finished or repeated elsewhere. Every page you remove is one less page to fix.
- Put the Level AA requirement in new contracts and renewals so each vendor's responsibility is written down.
The final six months: build habits and check your work
From late 2027 to April 2028, shift from fixing to keeping things fixed.
- Give the staff who post agendas, flyers and news a short routine: real headings, text descriptions for images, readable PDFs and captions on video. After your date, new documents and meeting packets have to meet the standard from the start.
- Move true records into a clearly marked archive and leave them unchanged. Archived content created before your date can qualify for an exception only if it is kept for reference or recordkeeping and has not been changed since.
- Test your key pages and forms with a keyboard alone and with a screen reader. Then ask your vendors to show you the same.
- Tell residents how to reach you if something on the site does not work for them.
Quick questions and answers
What standard do we have to meet?
The Web Content Accessibility Guidelines version 2.1, Level AA, for web content and mobile apps.
Does the rule cover sites our vendors run for us?
Yes. The fact sheet says content and apps a government provides through a contractor or other arrangement are covered.
Do we have to fix every old PDF?
Usually not, if it was posted before your date and nobody uses it to apply for or take part in a service. Documents still in use have to be accessible.
Where can we ask the Justice Department a question?
The ADA Information Line is 800-514-0301 (voice) and 1-833-610-1264 (TTY).
A place to start
Want a quick look at your own site? The free Awesome Audit check looks at your home page and up to 25 more pages. In about 10 minutes you get a letter grade and the biggest problems in plain language, with what to fix first. No account, no password.
