Title II Compliance Timeline: Key Dates and Deadlines for 2026

ADA Title II compliance timelines are now set for state and local governments and their vendors.

The Department of Justice's 2024 final rule on web and mobile app accessibility is now in effect. State and local governments across the United States now face clear deadlines to make their digital services accessible to people with disabilities. Whether you're managing a city website, overseeing a school district's digital presence, or providing services to public entities, you now have firm dates and a single standard to meet.

As the ADA Title II compliance deadlines approach in 2026 and 2027, organizations—including vendors and service providers working with U.S. public entities—must ensure their digital experiences conform to WCAG 2.1 Level AA and are ready on time. 

Mark your calendar—Title II timelines:

• Large entities (≥50,000): April 24, 2026.
• Small entities (<50,000): April 26, 2027

Plan against WCAG 2.1 Level AA (and aim for 2.2 where feasible). This post covers deadlines and a practical plan to prepare. 

What the Title II Deadline Means for Digital Accessibility

The ADA Title II compliance deadline isn't just a calendar date—it represents a shift in how government digital services are designed, built, and maintained. Under the new rule, all covered public entities must conform to WCAG 2.1 Level AA standards for their websites and mobile apps.

This includes ensuring that digital services are:

• Perceivable to users with various disabilities, including offering transcripts or closed captions for those who are hard of hearing.
• Operable through different input methods like keyboard navigation.
• Understandable with clear, consistent interfaces.
• Robust and compatible with assistive technologies like screen readers.

The deadline applies to both directly operated digital services and those provided by contracted vendors, making compliance a shared effort with final accountability on the public entity.

Who Must Meet the Title II Requirements

Both state and local government entities must meet the new Title II requirements. Private vendors and digital service providers who work with these organizations, however, also need to prepare. If you build, host, or support public-sector digital services, your work must enable WCAG 2.1 AA.

State and Local Government Entities

• Cities and municipalities.
• Counties and parishes.
• School districts and educational institutions.
• Special districts (water, fire, transit authorities).
• State agencies with public-facing digital services.

Private Vendors and Service Providers

While Title II directly applies to public entities, private companies providing digital services to government agencies must also prepare. Public entities remain fully responsible for compliance, even when working with external vendors, creating a compliance ecosystem that extends beyond government walls.

This is particularly relevant for:

• Website development agencies.
• Software-as-a-Service (SaaS) providers.
• Digital consulting firms.
• Technology vendors serving the public sector.

Action to take now: update scopes, SLAs, and procurement language to require WCAG 2.1 AA and verification (testing and documentation) before launch and after updates. 

Understanding the ADA Title II Compliance Deadline

The final ruling detailed when public entities and companies that work with public entities must meet WCAG 2.1 Level AA standards. The DOJ has established staggered deadlines based on the population size of the public entity:

Large Public Entities (50,000+ Population)

Compliance Deadline: April 24, 2026

This category includes major cities, large counties, and substantial school districts. These entities have approximately 18 months from the rule's effective date to achieve full WCAG 2.1 Level AA conformance for all public-facing websites and mobile applications.

Smaller Public Entities (Under 50,000 Population) and Special Districts

Compliance Deadline: April 26, 2027

Smaller municipalities, rural counties, special districts, and smaller school systems receive an additional year to meet compliance requirements, recognizing the resource constraints these entities often face.

Scope and limited exceptions: The rule applies to web content and mobile applications, whether operated directly or through vendors. Limited exceptions include archived web content; pre-existing conventional electronic documents not in active use; third-party content not posted by or on behalf of the entity; individualized, password-protected documents (e.g., a specific bill); and preexisting social media posts. These exceptions are narrow and do not remove the obligation to provide accessible services.

Latest Updates and Legal Risks

The DOJ's final rule represents the most significant update to digital accessibility requirements for government entities in years. Key enforcement elements include:

• Clear legal standards: WCAG 2.1 Level AA is now the official benchmark, eliminating previous ambiguity about accessibility requirements.
  

• Comprehensive coverage: The rule covers websites, mobile apps, and digital tools, whether operated directly or through vendors. This means you’re still responsible even if an outside agency manages your site or app.

• Limited exceptions: Only specific content types receive exemptions, including certain archived materials or preexisting documents.

• Enforcement consequences: Non-compliance can result in DOJ investigations, legal action, and mandatory remediation under federal oversight.

Planning Your Compliance Timeline

With deadlines approaching, successful compliance requires strategic planning that starts now and runs past go-live.

Start Early: The Reality of The Two-Year Time Frame

For large entities facing the April 2026 deadline, the two-year window from the original ruling may seem generous. However, experienced accessibility professionals know that comprehensive remediation can take months (if not a year or longer) for complex government websites. Starting early provides crucial buffer time for:

• Thorough accessibility audits.
• Code-level remediation.
• Staff training and process development.
• Vendor coordination and contract updates.
• Testing and quality assurance.
  

Make it a program, not a last-minute rush. 

Phased Approach to Meet Deadlines

Rather than attempting wholesale compliance in the final months, successful organizations are implementing phased remediation strategies:

1. Priority services first: Focus on essential citizen services like payment portals, permit applications, and emergency information.
2. High-traffic areas: Address frequently used sections before lower-priority content.
3. Technical infrastructure: Resolve foundational code issues that affect multiple pages.
4. Content and media: Systematically address documents, images, and multimedia content

Avoiding Common Accessibility Compliance Mistakes

As the Title II deadlines are approaching in 2026 and 2027, it’s essential to watch for common accessibility and compliance mistakes that can derail your efforts and potentially land you in mandatory remediation territory.

 These are some of the most common mistakes. 

1. The Post-Audit Stall

Many organizations assume that completing an accessibility audit puts them on track for compliance. In reality, the audit is just the starting point. Remediation, training, and process implementation typically require significantly more time and resources than the initial assessment. Assign owners and dates the week the report lands, or time will slip. Plan time and budget for fixes, re-tests, and regression monitoring.

2. Over-Reliance on Automated Solutions

While automated accessibility tools can identify specific issues quickly, they miss many WCAG 2.1 AA requirements. Meeting the compliance deadline requires manual testing, code-level fixes, and human judgment to address complex usability and navigation issues. Automation helps; it doesn’t finish the job.

3. Last-Minute Vendor Scrambles

Organizations that wait until the final months often discover that qualified accessibility vendors are fully booked. Engage partners early and align contracts to WCAG 2.1 AA to secure capacity.

What Happens After the Deadline

ADA Title II compliance doesn't end on the deadline date. The rule establishes ongoing obligations for maintaining accessibility standards, including:

• Regular accessibility monitoring.
• Staff training on accessibility best practices.
• Vendor oversight and compliance verification.
• Public feedback mechanisms for reporting barriers.
• Continuous updates to policies and procedures.

If your website and mobile apps aren’t meeting the new required standards, you could face penalties and mandatory remediation. Build maintenance into your roadmap.

Getting Started: Essential Next Steps

With compliance deadlines approaching, organizations should prioritize these immediate actions:

1. Conduct a comprehensive audit: Assess current accessibility status across all digital properties.
2. Develop a remediation roadmap: Create phased plans that align with available resources and deadline requirements
3. Update procurement processes: Ensure all vendor contracts include WCAG 2.1 AA requirements.
4. Establish internal capabilities: Train staff on accessibility principles and testing methodologies.
5. Implement ongoing monitoring: Create systems for maintaining compliance after the deadline.

Quick win: Prioritize the templates and forms residents use most—payments, permits, applications.

Partner with Experts for Accessibility Compliance Success

Meeting ADA Title II compliance deadlines requires expertise, resources, and sustained commitment. Working with an experienced accessibility partner with knowledge of the ADA, WCAG, and current federal requirements can help.

UsableNet provides comprehensive support for government entities and their vendors, including detailed compliance guidance, thorough auditing services, and end-to-end remediation support.

Whether you're just beginning your compliance journey or need assistance with specific remediation challenges, professional guidance can help ensure you meet deadlines while building sustainable accessibility programs.

The April 2026 and 2027 deadlines are approaching. Start now to protect timelines, reduce risk, and improve the experience for everyone.

Ready to start your compliance planning? Contact UsableNet. My team and I are happy to talk through timelines and resourcing, or point you to the right starting place if you’re still scoping. Explore our ADA Title II services to learn how we can help you meet your deadline.