ADA Title II compliance dates: April 2027 and 2028

In brief

In April 2026 the Department of Justice extended the compliance dates of the Title II web rule by one year. Public entities with a total population of 50,000 or more must comply by 26 April 2027. Public entities with a population under 50,000, and all special district governments, must comply by 26 April 2028.

The technical standard did not change. It is still WCAG 2.1 Level AA.

The dates

• 50,000 or more people: moved from 24 April 2026 to 26 April 2027.
• Fewer than 50,000 people, and special district governments: moved from 26 April 2027 to 26 April 2028.

How the change was made

DOJ issued an interim final rule, published on 20 April 2026 (91 FR 20902) and effective that day. It amends only the two compliance dates in 28 CFR 35.200(b). It does not change the WCAG 2.1 Level AA standard, the exceptions or any other requirement.

DOJ gave reasons including limited staff and resources, especially for small governments, and said the original dates were infeasible and unfair to covered entities. It also said it plans future rulemaking on the 2024 rule, which may include a proposed rule during the extension period. Check ADA.gov for later changes.

How population is counted

• Use the population from the most recent decennial Census where the entity has one.
• Independent school districts use the Small Area Income and Poverty Estimates.
• Entities without their own Census population use the population of the state or local government they belong to. Entities of several states use the combined population.
• Special districts are defined by state law and have a limited function. They fall under the 2028 date.
• Student counts, patron counts and employee numbers do not decide the population.

What to do

• Work out your total population under the rules above, and whether you are a special district.
• Write your date into your project plan and work backwards.
• Do not wait for the date to start. An audit and a remediation plan take time.

Common mistakes

• Using the original 2026 and 2027 dates. They were extended.
• Counting students, visitors or employees instead of the Census-based population.
• Assuming the extension means the rule is going away. The standard and the requirement are unchanged.

Sources

• Extension of Compliance Dates, 91 FR 20902 (Federal Register, 20 April 2026), opens in a new tab
• First Steps Toward Complying with the Title II Web Rule (ADA.gov), opens in a new tab
• 28 CFR Part 35, Subpart H: Accessibility of Web Information and Services (eCFR), opens in a new tab

This page is for informational purposes only and is not legal advice. For binding requirements, refer to the official ADA statute and regulations, and ask a lawyer how they apply to you.