Title II website accessibility deadlines: a public-entity planning guide

Current dates in DOJ guidance

The DOJ guidance states April 26, 2027 for state and local government entities with a total population of 50,000 or more. It states April 26, 2028 for entities with a population below 50,000 and for special district governments. These are the extended dates, not the original 2026/2027 schedule. For school districts, total population does not mean student enrollment: city districts use city population, county districts use county population, and independent districts use the most recent Census SAIPE population estimate.

The applicable technical standard is WCAG 2.1 Level AA for covered web content and mobile apps. Existing obligations concerning access to services remain relevant before these dates. This is not a grace period to ignore a known barrier or an accommodation request.

Determine which population applies

A department generally uses the population of the government it belongs to, not its employee count, page views, or number of service users. DOJ’s guide identifies Census sources and treatment for different entities. Document that source in your planning record.

A school district is not a special district government under this definition. A city district uses city population, a county district uses county population, and an independent district uses the applicable Census Small Area Income and Poverty Estimates population. Student enrollment is not the substitute. A special district classification should be confirmed from the actual definition, not the organization’s name.

Treat exceptions as a scope decision, not a scan filter

The rule describes limited exceptions for categories including archived content and certain preexisting conventional electronic documents. Exceptions have conditions and do not necessarily eliminate other obligations. A current form used to apply for a service deserves attention even if the file itself is old.

Have the responsible official or legal adviser decide whether a specific exception applies. Keep the document or URL, the factual reason, the owner, and the alternative access process in the record. Automatically excluding all PDFs before a cutoff date is not a defensible substitute for this work.

Build a schedule that ends with tested services

Work backward from the verified date: inventory services and vendors, evaluate a representative set of tasks, repair shared templates and essential content, then retest with keyboard and assistive technology. Reserve time for procurement, source-document repairs, and coordination with third-party service owners.

• Record entity category, population source, applicable date, and official source-review date.
• Assign every public service an owner, including external forms and mobile apps.
• Separate automated findings, manual checks, unavailable content, and potential exceptions.
• Use task-based acceptance criteria, not only a target number of closed scan findings.
• Review the official guidance periodically and after any regulatory update.