The deadlines for cities and towns
The Department of Justice's Title II web rule (28 CFR Part 35, Subpart H) requires state and local government web content and mobile apps to conform to WCAG 2.1 Level AA. An interim final rule effective April 20, 2026 extended the compliance dates by one year.
| Government | Compliance date |
|---|---|
| Total population of 50,000 or more | April 26, 2027 |
| Population under 50,000 | April 26, 2028 |
| Special district governments, any size | April 26, 2028 |
Confirm which row applies to you with your city attorney or counsel.
What a city website must get right
The rule covers web content a city makes available directly or through vendors. In practice that means more than the main site. Think about every place a resident meets your government online:
- The main website and any microsites for parks, libraries, police, or economic development
- Online utility billing, permit, license, and court payment portals
- Council and commission meeting agendas, packets, minutes, and video
- Municipal code libraries and ordinance search tools
- Forms, applications, and public records request pages
- Mobile apps and text alert sign ups
- Interactive maps and GIS tools
Common problems we see
Large municipal sites have a different problem than small ones: scale. A site with thousands of pages and documents cannot be fixed by hand in one pass. Teams run into inconsistent templates between departments, maps and dashboards built with tools that do not work with a keyboard, live meeting video without captions, and portals from third party vendors that the city does not control. Each department adds content without a shared review process.
A realistic compliance plan
- Inventory. List sites, portals, apps, and document sources, and who owns each.
- Prioritize. Start with what residents rely on: payments, meeting information, emergency notices, and forms.
- Fix templates and components so every department benefits.
- Set a document standard and train staff to publish accessible files.
- Hold vendors to it. Add WCAG 2.1 AA expectations to contracts and ask for testing evidence.
- Test and monitor. Combine regular scans with manual checks. See ongoing maintenance.
Our municipal website development service covers design, document libraries, and online payments, and our testing service can baseline what you have today.
General information, not legal advice. Automated testing cannot establish full ADA compliance or guarantee protection from lawsuits. It finds some kinds of barriers quickly. A person still has to test the rest. Ask a qualified attorney how the law applies to you.
Frequently asked questions
Does the rule apply to a city of 20,000?
Yes, with a later date. Governments with a population under 50,000 have until April 26, 2028. A city of 50,000 or more has until April 26, 2027.
Does it cover vendor portals such as utility billing?
The rule applies to web content made available through contractual or other arrangements, so vendor tools are part of your responsibility. Check your contracts.
Do council meeting videos need captions?
The rule requires live audio content in synchronized media to have captions, and prerecorded content too, subject to the rule's terms and exceptions. Confirm details with counsel.
Where is the rule published?
The rule is in 28 CFR Part 35, Subpart H, and the April 2026 date change was published in the Federal Register. Links are in the sources below.