Title II ADA Web Accessibility: The New 2027 and 2028 Dates

State and local government entities now have later deadlines to make their web content and mobile apps meet WCAG 2.1 Level A and Level AA under the Title II ADA rule. As of a 2026 interim final rule, public entities with a population of 50,000 or more (other than special district governments) must comply beginning April 26, 2027, and public entities with a population under 50,000 or any special district government must comply beginning April 26, 2028 (eCFR, current text).

These dates replace the rule’s original text, which had set the deadlines about one year earlier — April 24, 2026 and April 26, 2027, respectively (eCFR, April 1, 2026 version).

This original record-reading guide is a general reading aid, not cited evidence. It does not depict a source record; the article text and source links provide the facts.

Key points

• The current compliance date for larger public entities (population 50,000+, excluding special district governments) is April 26, 2027 (eCFR, current text).
• The current compliance date for smaller public entities (population under 50,000) and for special district governments of any size is April 26, 2028 (eCFR, current text).
• Both dates are about one year later than the dates originally published in the 2024 rule (eCFR, April 1, 2026 version).
• The date change came through an interim final rule that took effect April 20, 2026 and is open for public comment (Federal Register, 2026-07663).
• This article covers only the compliance dates themselves, not whether any specific website or app currently meets them.

Rule requirements by population size

The current text of 28 CFR 35.200(b) sets two compliance dates based on an entity’s population size. For larger entities:

“Beginning April 26, 2027, a public entity, other than a special district government, with a total population of 50,000 or more shall ensure that the web content and mobile apps that the public entity provides or makes available, directly or through contractual, licensing, or other arrangements, comply with Level A and Level AA success criteria and conformance requirements specified in WCAG 2.1” (eCFR, current text)

For smaller entities and special district governments:

“Beginning April 26, 2028, a public entity with a total population of less than 50,000 or any public entity that is a special district government shall ensure that the web content and mobile apps that the public entity provides or makes available, directly or through contractual, licensing, or other arrangements, comply with Level A and Level AA success criteria and conformance requirements specified in WCAG 2.1” (eCFR, current text)

The regulation’s own authority note ties these dates to two Federal Register actions: the original 2024 rule and the 2026 amendment that changed the dates:

“[AG Order No. 5919-2024, 89 FR 31337, Apr. 24, 2024, as amended by AG Order No. 6742-2026, 91 FR 20912, Apr. 20, 2026]” (eCFR, current text)

Together, the two population-based deadlines above and this authority note are what fix April 26, 2027 and April 26, 2028 as the compliance dates currently in force.

Dates before the 2026 amendment

Before the amendment, the same section of the eCFR — captured in a version dated April 1, 2026 — set both compliance dates one year earlier. For larger entities:

“Beginning April 24, 2026, a public entity, other than a special district government, with a total population of 50,000 or more shall ensure that the web content and mobile apps that the public entity provides or makes available, directly or through contractual, licensing, or other arrangements, comply with Level A and Level AA success criteria and conformance requirements specified in WCAG 2.1” (eCFR, April 1, 2026 version)

For smaller entities and special district governments:

“Beginning April 26, 2027, a public entity with a total population of less than 50,000 or any public entity that is a special district government shall ensure that the web content and mobile apps that the public entity provides or makes available, directly or through contractual, licensing, or other arrangements, comply with Level A and Level AA success criteria and conformance requirements specified in WCAG 2.1” (eCFR, April 1, 2026 version)

In other words, the amendment moved each population tier’s deadline back by about one year — larger entities from April 24, 2026 to April 26, 2027, and smaller entities and special district governments from April 26, 2027 to April 26, 2028.

How the deadline changed

The Department of Justice issued the date change as an interim final rule rather than a standard final rule, meaning it took legal effect immediately while still accepting public input:

“Interim final rule; request for comments.” (Federal Register, 2026-07663)

“This IFR is effective April 20, 2026.” (Federal Register, 2026-07663)

The Department of Justice’s own compliance guidance points readers to the official Federal Register citations for both the original rule and the amendment:

“The official version of the rule is published in the Federal Register at 89 FR 31320 (April 24, 2024).” (ADA.gov, Small Entity Compliance Guide)

“The official version of the IFR is published in the Federal Register at 91 FR 20902 (April 20, 2026).” (ADA.gov, Small Entity Compliance Guide)

This article covers only which compliance dates currently govern Title II web and mobile-app accessibility, and what the dates were before the April 2026 amendment. It does not address whether any particular state or local government website or mobile app currently conforms to WCAG 2.1 — that depends on each entity’s own implementation and is outside the scope of the regulatory text covered here. It also does not explain how a reader would determine which population-size class a given public entity falls into; that determination depends on population data and entity classification questions the cited rule text does not itself resolve. Finally, because the April 2026 rule is an interim final rule issued with an open comment period, it does not address whether these dates will be revised again before or after the 2027 and 2028 deadlines arrive.

Source links

• eCFR — 28 CFR § 35.200 (Current)
• eCFR — 28 CFR § 35.200 (April 1, 2026 Version)
• Federal Register — Extension of ADA Title II Web Accessibility Compliance Dates
• ADA.gov — Small Entity Compliance Guide