Web & Mobile Accessibility (Title II)

Yes. Under ADA Title II, all state and local governments must ensure their websites and mobile apps are accessible to people with disabilities. The DOJ issued a final rule in April 2024 establishing WCAG 2.1 Level AA as the required technical standard. This applies to all public entities regardless of size or website scope. Source: U.S. Department of Justice, 28 CFR Part 35

On April 20, 2026, the DOJ issued an Interim Final Rule extending the compliance deadlines by one year. Updated deadlines: April 26, 2027 — Entities serving 50,000 or more (cities, counties, school districts, state agencies). April 26, 2028 — Smaller entities and special purpose districts. The technical standard (WCAG 2.1 Level AA) and scope of coverage are unchanged. Comments on the IFR are due June 22, 2026. Source: DOJ Interim Final Rule, April 20, 2026

WCAG (Web Content Accessibility Guidelines) 2.1 Level AA is the required technical standard for government web accessibility under ADA Title II. It is organized around four principles: Perceivable, Operable, Understandable, and Robust (POUR). In practice it means providing alt text for images, accurate captions for videos, sufficient color contrast, accessible forms, and keyboard navigation throughout the site. Source: W3C WCAG 2.1

The rule covers all web content and mobile applications a public entity uses to deliver services: government websites, mobile apps, PDFs, online forms, posted videos, and third-party platforms used to deliver government services (payment portals, permit systems, etc.). Limited exceptions exist for archived content and certain pre-existing documents. Source: 28 CFR Part 35, Subpart H

Yes. A public entity cannot outsource its ADA obligations. If you contract with a vendor to deliver government services online, you remain responsible for ensuring those services meet WCAG 2.1 AA. Include accessibility requirements in all vendor contracts and request accessibility testing documentation before accepting deliverables. Source: 28 CFR Part 35, Subpart H

No. Overlay tools are add-on scripts that attempt to auto-patch accessibility issues. The DOJ has not recognized overlays as a compliant solution. They can interfere with assistive technologies and do not fix the underlying code-level barriers. Real compliance requires addressing accessibility in the source code and content. Source: U.S. Department of Justice

Non-compliant entities may face DOJ investigations, individual complaints, and federal lawsuits. Entities that document a good-faith compliance effort — a completed audit and a remediation plan with timelines — are in a stronger position if a complaint is filed before full compliance is achieved. Source: U.S. Department of Justice

TitleII.org provides free plain-language guides for all nine Title II subparts, including Subpart H (web and mobile accessibility). Free automated testing tools include WAVE (wave.webaim.org) and Google Lighthouse. For hands-on compliance support — audits, remediation planning, and staff training — AX4E.com specializes in Title II compliance for state and local government. Source: TitleII.org