Which compliance date is actually yours

There are two dates. Public entities serving 50,000 people or more have until 26 April 2027. Everyone under 50,000, plus any special district government, has until 26 April 2028. The standard in both cases is WCAG 2.1 Level AA.

That much is on the front page of this site. What is not on the front page, and what I get asked about more than anything else, is which of the two numbers a particular board is actually working against. The answer is less obvious than the table makes it look, and getting it wrong in either direction costs you.

Special districts do not count population at all

If you are a special district government, your date is 26 April 2028. Your population does not enter into it.

This is the part that surprises people, because the other row of the table is all about population and it is natural to assume the same logic runs through the whole thing. It does not. The Department of Justice named special district governments as their own category, separate from the population test. A large district and a small one land on the same day.

The ones I run into on this coast are the fire districts, the water and sanitary districts, the port districts, and the parks and recreation districts. If your entity has its own board, its own budget, and one job, this is almost certainly you.

A school district is not a special district

This is the one that reliably goes wrong, and it goes wrong in the direction that costs you a year.

School districts feel like special districts. They have their own boards, their own budgets, and one job. But the Department of Justice says plainly that a school district is not a special district government, and so a school district does not get the 2028 date by default. It gets a date derived from a population, and which population depends on what kind of district it is:

1. A city school district uses the population of the city.
2. A county school district uses the population of the county.
3. An independent school district uses the population estimate in the most recent Small Area Income and Poverty Estimates from the Census Bureau.

So a school district serving a city of 60,000 is working toward 26 April 2027, not 2028. If someone told your board you had until 2028 because you are a district, that advice was wrong by a year, and a year is roughly the amount of time this work takes when a site is starting from a bad place.

A department inside a government uses the government's number

Most agencies are not standalone entities. A city police department, a county parks program, a city public works office: none of these has a population of its own in the census data, and none of them needs one. They use the population of the government they belong to. If the city is 12,000, the city's police department is working toward 2028 along with the rest of the city.

For most governments the population number comes from the 2020 Census. It is worth writing down which number you used and where you got it, because in two years somebody will ask and the person who knew will have moved on.

The date is not when the obligation starts

One more thing that gets read backwards. These dates are not the moment your website has to start being accessible. Title II of the ADA already requires that your services, programs, and activities be accessible, and it has for a long time. What the 2024 rule did was set a specific technical standard for what accessible means online, and what the 2026 interim final rule did was move the dates by which you have to meet it.

Which means two things at once. You have longer than you thought to meet the specific standard, and you have had an obligation the whole time. The people who read the extension as permission to wait are the ones who will be doing this work in a hurry in early 2028.

What to actually do with this

Work out your date, write down how you got there, and then find out how far you are from the standard. Those are separate jobs and the second one is the one that takes time. A site that looks fine can fail badly on the things that matter, and a site that looks dated can be closer than you would guess.

If you want the second job done for you, I run a review that produces a plain document your board can read: what is wrong, where, why it matters, and what it will take to fix. It takes about a week. Tell me what you are working with.

The two sources behind this, both primary, are the DOJ fact sheet on the web accessibility rule, which carries the compliance table and the school district rule, and the interim final rule in the Federal Register, published 20 April 2026, which set the extended dates. This describes a regulation and is not legal advice.