ADA Title II Website Compliance for Government

Yes. Title II of the Americans with Disabilities Act applies to all state and local government entities — states, counties, cities, towns, villages, special districts, public school districts, public colleges, libraries, and transit authorities. In April 2024 the U.S. Department of Justice published a final rule making explicit that Title II covers these entities' websites and mobile apps, and setting a specific technical standard and compliance deadlines.

The DOJ rule adopts WCAG 2.1 Level AA (Web Content Accessibility Guidelines) as the technical standard. WCAG 2.1 AA covers requirements like sufficient color contrast, keyboard operability, text alternatives for images, captions for video, clear labels and headings, and content that works with screen readers. It applies to web pages, web applications, mobile apps, and the documents a government publishes online.

The deadline depends on population. Public entities with a total population of 50,000 or more must comply by April 26, 2027. Public entities with a population under 50,000, along with special district governments of any size, must comply by April 26, 2028. (In April 2026 the DOJ extended both original deadlines by one year; these are the current dates.)

Every state and local government entity: state agencies, counties, cities and towns, villages, townships, special districts (such as rural water, fire protection, hospital, and utility districts), public school districts, public universities and community colleges, public libraries, and public transit authorities. It also reaches the online content those entities post through third parties on their behalf.

It covers both. The rule applies to the content a government publishes online, which includes PDFs and other documents — agendas, meeting minutes, budgets, permit and license forms, public notices, and maps. Inaccessible PDFs are one of the most common and most overlooked compliance failures for government websites.

Non-compliant entities can face U.S. Department of Justice investigations and enforcement, complaints filed by members of the public, and private lawsuits under the ADA. Non-compliance can also put federal funding at risk. Beyond the legal exposure, an inaccessible website excludes residents with disabilities from public information and services they are legally entitled to access.

The rule includes limited exceptions, such as certain archived web content, pre-existing conventional electronic documents (unless used to apply for or access a service), content posted by third parties where the entity does not control it, individualized password-protected documents, and pre-existing social media posts. These exceptions are narrow — the safest assumption is that your public-facing website and the documents residents use must meet WCAG 2.1 AA.

Section 508 applies to federal agencies and their technology; ADA Title II applies to state and local governments. Both point to WCAG as the practical standard (Section 508 references WCAG 2.0 AA; the Title II rule adopts WCAG 2.1 AA). If you run a city, county, or special district, ADA Title II — and WCAG 2.1 AA — is the standard that governs your website.

Start with an accessibility audit against WCAG 2.1 AA. Automated scans catch a portion of issues (contrast, missing alt text, form labels), but full conformance requires manual testing — keyboard-only navigation, screen-reader review, and checking that PDFs and embedded third-party tools are accessible. A proper audit produces a plain-English report of what is failing, how serious each issue is, and what remediation requires.

Four steps: (1) audit the current site and documents against WCAG 2.1 AA; (2) remediate the existing site or rebuild it to the standard, including accessible PDFs; (3) publish a public accessibility statement documenting conformance; and (4) monitor continuously, since every new agenda, notice, and document must stay accessible. My Media Matters builds every site to WCAG 2.1 AA by default and can audit, remediate, or rebuild for public entities.