AccessHawkby Nighthawk
Briefing memo · print this page

The federal web accessibility deadline: a one-page brief for your council or board.

Written for elected officials and administrators, not developers. Print it (it prints clean) and put it in the packet.

What happened

In April 2024 the U.S. Department of Justice finalized a rule under ADA Title II (28 CFR Part 35) that, for the first time, sets a specific technical standard for the websites and mobile apps of every state and local government entity: WCAG 2.1 Level AA. In April 2026 DOJ extended the original compliance dates by one year. This is not guidance — it is a regulation with fixed deadlines.

April 26, 2027Compliance deadline — entities serving a population of 50,000 or more
April 26, 2028Compliance deadline — under 50,000, and all special district governments
WCAG 2.1 AAThe required technical standard — covering web pages AND documents (PDFs, forms, agendas)
~90,000Public entities covered nationwide: cities, counties, towns, school districts, special districts

What it covers

Everything your entity makes available on the web: pages, online forms and payments, meeting agendas and minutes, budget documents, PDFs, and video (which needs accurate captions). Content provided through vendors and third-party platforms on your behalf is included — outsourcing the website does not outsource the obligation.

The risk of waiting

Title II already applies today; the deadline is when the specific technical standard becomes enforceable. Non-compliance exposes the entity to DOJ enforcement, private lawsuits, and — most commonly — serial demand letters, which typically cost more to settle than fixing the site would have. Just as practically: residents with disabilities can't read the agenda, pay the water bill, or apply for the permit. That's a service failure before it's a legal one.

The reasonable plan

  1. Baseline now. Run a readiness scan and get your score on record. Free, takes a minute: accesshawk.nythawk.com.
  2. Fix the mechanical majority. Most automated findings (missing alt text, unlabeled forms, contrast, heading structure) are template-level fixes your web vendor can complete quickly. Hand them the report.
  3. Inventory documents. PDFs are usually the biggest workload. Decide what gets remediated, what gets converted to web pages, and what gets archived.
  4. Monitor and document progress. Re-scan on a schedule, keep dated reports, and publish an accessibility statement. If a complaint ever comes, documented, dated progress is your best posture.
  5. Budget it. A monitoring line item is small (see pricing); document remediation may need a real line. Put both in this cycle, not the one after the deadline.
Bring data to the meeting: run the free scan first, print the report, and staple it to this brief. A score and a date beats an abstract discussion every time.

Sources: DOJ final rule, 89 FR 31320 (Apr. 24, 2024); DOJ interim final rule extending compliance dates (Apr. 2026). This brief is general information, not legal advice. Prepared by AccessHawk · accesshawk.nythawk.com · July 2026.