The ADA Title II deadline is eight months out. Here is the plan that fits.

What the rule requires, precisely

The DOJ's Title II web rule - the first time a US regulation named a specific technical standard for the web - requires WCAG 2.1 Level AA conformance for the web content and mobile apps of state and local government entities. The compliance dates, as extended by the April 2026 interim final rule, are:

• 26 April 2027 - entities of 50,000 population and above;
• 26 April 2028 - entities under 50,000 and special district governments.

Coverage is broader than most inventories assume: it includes content provided through contractors and vendors, mobile apps, and - with defined exceptions - documents. Conventional electronic documents like PDFs are covered whenever they are currently used to apply for, access or participate in services. Archived content and certain preexisting documents have exceptions, but the exceptions are narrower than they sound and each has conditions.

The full breakdown lives on our ADA Title II guide.

The eight-month plan

Working back from 26 April 2027:

1. Months 1-2: inventory and baseline. List every property: main site, department microsites, payment portals, forms systems, mobile apps, and the document library. Run automated scans across all of it - a full-domain crawler for pages, a batch PDF checker for documents - to map failure density and triage.
2. Months 2-4: audit what matters, fix templates first. Expert manual audit on the highest-traffic templates and critical service flows (apply, pay, register, request). Remediate at the template and component level - one fixed form component closes failures across hundreds of pages.
3. Months 3-6: documents and vendors, in parallel. Prioritize actively-used PDFs (applications, notices, agendas) for remediation; fix the source templates that generate next month's documents. Send vendors the conformance requirement in writing now - procurement lead times are the most common cause of missed deadlines.
4. Months 6-7: verification round. Re-audit remediated flows, screen reader and keyboard passes on the service journeys residents actually use, and close the stragglers.
5. Month 8: documentation and steady state. Publish the accessibility statement, compile the conformance evidence, and switch on continuous monitoring so the April 2027 state survives the May 2027 website update.

The three places Title II projects slip

• The document library. Agencies discover thousands of PDFs late in the project. Batch scanning early - up to 1,000 documents at a time - turns an unknown into a plan.
• Third-party systems. Payment processors, agenda platforms, form vendors: their accessibility is your obligation under the rule. Contract language and vendor VPATs need to move in month one, not month seven.
• Treating it as a one-time project. The rule has no sunset. Content published on 27 April 2027 must conform too - which is why monitoring and authoring-time checks belong in the plan, not after it.

Why starting now is cheaper

Remediation capacity - internal and vendor - will tighten as the deadline approaches, exactly as it did before the European Accessibility Act's June 2025 date. Entities that started early bought remediation at normal prices on their own schedule; entities that started late paid rush rates under scrutiny. Eight months is comfortable. Five is tight. Three is expensive.

If you need the starting point today: a free page check for a first read, and a scoped managed compliance program to carry inventory-to-evidence end to end.

Keep reading

• ADA Website Compliance: the full guide
• Web Accessibility: the complete guide
• The WCAG library

Last updated 12 August 2026. Reviewed by the EqualWeb accessibility team.