When state & local government websites must meet WCAG 2.1 AA, and what to fix first.

The Justice Department's ADA Title II rule requires state and local government websites to meet WCAG 2.1 AA. An interim rule moved the deadlines to April 2027 and April 2028. Who it covers, what it leaves out and where to start.

The Justice Department's rule under Title II of the Americans with Disabilities Act requires state and local governments to make their websites and mobile apps meet WCAG 2.1 Level AA. The first deadlines were in 2026 and 2027. An interim final rule published in the Federal Register on April 20, 2026 moved each of them back a year.

This guide covers who the rule applies to, what counts, what doesn't and the order we would fix things in. We checked the dates and exceptions against ada.gov in October 2026. It's a summary, not legal advice. The rule and the Justice Department's guidance at ada.gov are the source to check.

The deadlines.

• April 26, 2027 for state and local governments serving 50,000 people or more.
• April 26, 2028 for those serving fewer than 50,000 people, and for special district governments such as water and transit districts.

The standard.

WCAG 2.1 Level AA, the Web Content Accessibility Guidelines published by the W3C. It covers text alternatives for images, captions for video, enough color contrast, a site you can use with a keyboard alone, forms that say what went wrong and pages that make sense to a screen reader.

What it covers.

Web content and mobile apps that a state or local government provides or makes available, directly or through a contract, a license or another arrangement. That last part matters. A payment portal, a permit system or an agenda tool run by a vendor still counts as yours.

What the rule leaves out.

There are five exceptions, and each one is narrower than it sounds.

1. Archived content made before the deadline, kept only for reference or research and not changed since.
2. Documents posted before the deadline, such as PDFs, word processing files and spreadsheets, unless people still use them to apply for or take part in a service. A form people download today is not exempt.
3. Content posted by third parties who are not acting for the government, such as comments from the public.
4. Password-protected documents about one person, property or account, such as a tax bill.
5. Social media posts made before the deadline.

None of them removes the duty to communicate effectively with disabled people, or to make reasonable changes when someone asks.

What we would fix first.

1. The things people come to do

Paying a bill, applying for a permit, registering for a program, finding a meeting. Test each one from start to finish with a keyboard and a screen reader. These are what people complain about, and documents tied to them don't get the exception.

2. The templates

The header, the menu, the footer and the form styles appear on every page. Fixing a template fixes hundreds of pages at once, which is why it comes before page-by-page work.

3. The documents people still use

Forms and guides that people download today. Turning the most used ones into web pages is usually cheaper than making every PDF accessible, and easier to keep right.

4. The vendors

Ask every vendor whose tool sits on your site for an Accessibility Conformance Report, the document often called a VPAT. If they can't produce one, put WCAG 2.1 AA into the contract at renewal.

5. Video & audio

Captions for video, recorded meetings included. Transcripts for audio.

6. A way to keep it right

New content breaks accessibility every week. Automated checks catch some problems on every page. A person testing with a keyboard and a screen reader catches the rest. Put both on a schedule.

Two things that won't get you there.

• Overlay widgets. A script that claims to fix a site with one line of code doesn't make it meet WCAG 2.1 AA.
• A one-time audit. It's a picture of one day. The rule applies to every page you publish after the deadline too.

If you're commissioning a new site to meet the rule, our guide to writing a website RFP covers the questions to ask about accessibility. And if you're a contractor selling to state and local governments, expect this standard in your contracts. Your own site is the first sample of your work they'll look at.