For Public Agencies

The Federal Website Deadline.

What the rule requires, which date applies to you, and where the exceptions stop helping. One page, no sales pitch.

The Rule

In April 2024 the U.S. Department of Justice published a final rule under Title II of the Americans with Disabilities Act setting a specific technical standard for the websites and mobile apps of state and local governments. The standard is WCAG 2.1 Level AA. In April 2026 an interim final rule extended the dates by which entities have to meet it.

Title II already required your services, programs, and activities to be accessible. What the rule added was a definition of what that means online, and a date.

The Two Dates

  • Public entities serving 50,000 or more
  • Entities under 50,000, and special district governments

Which One Is Yours

  • A special district government is on 26 April 2028 regardless of the population it serves. Population does not enter into it.
  • A school district is not a special district government. A city school district uses the city's population, a county school district uses the county's, and an independent school district uses the most recent Small Area Income and Poverty Estimates.
  • A department inside a larger government, such as a police department or a parks program, uses the population of the government it belongs to.

For most entities the population figure comes from the 2020 Census. The longer version of this is here, including the cases that get read backwards.

What It Covers

More than the pages. The rule defines web content as the information and experiences available on the web, which includes text, images, audio, video, and documents.

  • Every public-facing page, including ones a vendor built and maintains for you.
  • PDFs, word processing files, spreadsheets, and presentations posted to the site. For most agencies this backlog is larger than the website.
  • Mobile apps you provide, including ones run by a private company on your behalf.
  • Calendars, scheduling tools, maps, reservation systems, and payment systems that you post, even when an outside company developed them.

The Exceptions, and Where They Stop

There are five, and each one is narrower than it first sounds. The traps are worth more than the list.

  • Archived content has to meet four conditions at once: created before your compliance date, kept only for reference or recordkeeping, held in a dedicated archive area, and unchanged since it was archived. Miss one and the exception is gone. Meeting minutes written after your date do not qualify just because they sit in the archive.
  • Preexisting documents are excepted only if they were already on the site before your date and have not been touched since. A document people still use to apply for something is not excepted at all, however old it is.
  • Third-party content means content a member of the public posts, not content you post that a third party wrote. Your vendor's work is yours. The platform that lets the public post is also yours.
  • Individualized password-protected documents must be all three: a document file, about one specific person or account, and secured. A rate-increase notice behind the same login is not excepted, and neither is the site around it.
  • Preexisting social media posts are excepted. Anything you post after your date is not.

Underneath all five, the older obligation stays: even where content is excepted, you still owe effective communication and reasonable modifications to a person who asks.

Where to Start

Two separate jobs. Work out your date and write down how you reached it, because in two years somebody will ask. Then find out how far the site is from the standard, which is the part that takes time.

I run that second job as a review. It takes about a week and it produces a document written for a board rather than for a developer: what is wrong, where it is, why it matters, and what it will take to fix. The findings come from tooling I built and maintain myself, so every one of them names the specific element and the specific criterion behind it.

If the honest answer is that you are in decent shape, that is what the document says.

Start a Conversation

Steven Trotter, Waldport, Oregon. hey@steventrotter.com · vesperbuilds.com/compliance

This describes a regulation and is not legal advice. Sources, both primary: the DOJ fact sheet on the web rule, which carries the compliance table, the exceptions, and the school district rule, and the interim final rule published in the Federal Register on 20 April 2026, which set the extended dates.