April Deadline Approaching to Implement Mandatory ADA Standards for Local Government Websites and Apps

Editor’s note: On April 20, 2026, the Justice Department extended the deadline for local government websites to comply with federal ADA accessibility guidelines. Cities, counties, and school districts with a population of 50,000 or more must now comply by April 26, 2027, while all other local governments must comply by April 26, 2028. See 91 FR 20902 for more information.

In today’s day and age, local governments primarily rely on their public-facing agency websites to relay information about government services, council/commission/board meetings, projects, and activities.

Local governments may also rely on mobile applications (apps)—see, for example the City of Bellevue’s My Bellevue Customer Assistance, the Spokane Public Library’s Spokane Library App, and the Pierce County Sheriff’s Department via the SheriffApp.com— to advertise their services and otherwise share their messaging.

Due to this heavy reliance on websites and apps to deliver critical information to the public, in 2024 the federal Department of Justice (DOJ) adopted mandatory compliance rules that state and local governments must follow to make their websites and apps accessible to people with disabilities.

The first compliance deadline for local governments is approaching on April 24, 2026. By this date, cities and counties with a population of 50,000 or more must ensure their web content and mobile apps meet the requirements of the rules. Special districts must comply by April 26, 2027, as well as cities and counties with a population of 49,999 or less.

Title II of the ADA: In General

Title II of the Americans with Disabilities Act (ADA) requires state and local governments to provide individuals with disabilities equal opportunity to benefit from government programs, services, and activities. Specifically, the ADA requires government agencies:

• Communicate with people with disabilities as effectively as the government communicates with others,
• Provide reasonable modifications to government policies to ensure a person with a disability can access programs and services,
• Follow standards for physical accessibility when constructing or altering government facilities,
• Provide program access to existing facilities, and
• Allow service animals even if there is a 'no pets' policy.

The DOJ’s webpage on applicability of the ADA for state and local governments provides detailed information and suggestions on how to comply with general Title II requirements.

Title II of the ADA: Website and Mobile App Accessibility

As noted by the DOJ on its website,

The ADA has always required state and local governments to provide individuals with disabilities with effective communication, reasonable modifications, and an equal opportunity to participate in or benefit from government services, programs, and activities.

According to the DOJ’s Summary of its Final Rule, while this requirement has always applied (in theory) to the services, programs, and activities local governments provide online and via mobile apps, equal access for individuals with disabilities is still not a reality: Hence, the new DOJ rule in 28 CFR Part 35, Subpart H, which adopts specific technical standards for making web content and mobile apps accessible.

These accessibility standards are detailed in Web Content Accessibility Guidelines (WCAG) 2.1. Level AA While a newer WCAG version 2.2. exists, the current DOJ requirement is to comply with version 2.1. This blog cannot detail all of the new standards required of government agency websites and apps, but it can offer a brief primer.

The WCAG 2.1. Level AA accessibility standards are based on four broad principles: Information and user interface components must be perceivable, operable, understandable, and robust. These concepts are explored in greater detail below. 

Perceivable

Information and user interface components must be presented to users in ways that they can perceive. Examples of perceivable standards include providing captions for audio content, and/or not using color as the only visual means of conveying information to accommodate those who have trouble with color perception.

Operable

User interface components and navigation must be functional for users in ways they can operate. For example, users must be allowed to turn off any time limits and must be able to control certain web content that moves, blinks, or scrolls. 

Understandable

Information and user interface operation must be easy for a user to grasp. An example of this is to provide a mechanism for identifying specific definitions of words or phrases used in an unusual or restricted way, including idioms and jargon.

Robust

Content must be robust enough so that it can be interpreted reliably by a wide variety of users, including those employing assistive technologies. 

Local governments should refer to the WCAG Quick Reference Guide to familiarize themselves with the new standards. The DOJ also has a list of practical suggestions for successfully implementing these standards, including: 

• Adopting local policies on web and app accessibility,
• Creating processes for people to make an accessibility request and report issues, and
• Training staff on how to make online content accessible. 

It will be difficult for agencies to comply with the WCAG standards without conducting an accessibility audit (ideally by a third-party expert) and implementing automated tools. Automated remediation tools—as opposed to manual testing and remediation—can provide rapid and recurring scanning of websites to check for accessibility issues. However, agencies cannot rely on automated tools alone; manual testing is also needed because automated tools cannot yet detect all compliance issues.

For more information on automated remediation tools, see the following articles:

• Automated Remediations: Accelerating Digital Accessibility
• Route Fifty: State and local governments must automate digital accessibility processes

Applicability to Third Parties

The new accessibility standards do not apply to content posted by members of the public at their own behest—for example, a community member commenting on a local government’s Facebook page.

New accessibility standards do apply to content developed by a third party and posted by a local government (e.g., content developed by an outside technology company and posted by a local government to its website) and to content posted by a government vendor or contractor (e.g., agency website designed, managed, or updated by an outside company). A local government should consider adding language to contracts requiring that content developed for the agency be in compliance with WCAG 2.1. Level AA standards.

If a contractor is unable to meet the new standards for apps or websites, public entities do have the option to rely on the ‘undue burden’ provision under the ADA. This provision recognizes that some accessibility requirements place an undue financial or administrative burden on local governments, and allow a municipality to look for alternatives.

The undue burden provision is explored in further detail in the State and Local Government Primer on the ADA (2020).

Exceptions

Notably, certain online content does not need to comply with the new accessibility standards, including archived web content, preexisting conventional electronic documents, third-party content not directly provided by the government or its contractors, individualized password-protected documents, and preexisting social media posts.

Each exception has specific criteria that must be met in order for it to apply. For example, for archived web content to be exempt, it must meet all of the following criteria:

• It was created or reproduced before the compliance date;
• It was kept only for reference, research, or recordkeeping;
• It was kept in a special area for archived content; and
• It has not been changed since it was archived.

An example of archived web content that would meet this exception is a water quality report from 2022 that is kept in the archive section of the local government's website purely for research purposes and has not been updated since 2022.

Compliance Deadlines

States and local governments with a population of less than 50,000 and all special purpose districts (regardless of size) must comply with the new accessibility guidelines by April 26, 2027. All others (i.e., larger jurisdictions) must comply by April 26, 2026. Failure to comply could subject local agencies to DOJ enforcement actions under the ADA.

Concluding Thoughts

The following provide clarity about the new requirements for website and app accessibility:

• DOJ Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments
• DOJ’s Final Rule: Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities
• Web Content Accessibility Guidelines 2.1.
  • Quick Reference Guide
• Accessibility of Web Content and Mobile Apps Provided by State and Local Government Entities: A Small Entity Compliance Guide