ADA Title II · 28 CFR Part 35 · Every public entity, every size
Who ADA Title II Applies To
Last updated June 11, 2026
Title II of the Americans with Disabilities Act covers every state and local government entity in the country. Not just the big ones. Not just the ones that take federal money. All of them. Find your kind of organization below and see exactly what the web accessibility rule means for you.
The Short Version
If your organization is part of state or local government, Title II applies to you. The law says "public entity," and it means any state or local government, any department, agency, special purpose district, or other instrumentality of one. A three-person village clerk's office is covered. A school district with one building is covered. A library that runs on donations and a county line item is covered.
Two things surprise people. First, size does not matter. There is no small-government exemption anywhere in Title II. Population only changes your deadline, never whether the law applies. Second, federal funding does not matter. That is Section 504 logic, and Title II deliberately dropped it. You are covered because you are a public entity, full stop.
Since the 2024 web rule, that coverage has a specific technical meaning online: your websites, mobile apps, and the documents on them must meet WCAG 2.1 Level AA under 28 CFR Part 35, Subpart H. Larger entities have until April 26, 2027. Smaller entities and special districts have until April 26, 2028. The deadlines page explains which date is yours.
Private businesses fall under Title III, not Title II. Federal agencies fall under Section 508. This site covers state and local government.
Find Your Organization
Each guide below explains why Title II applies to your kind of entity, which of your web content is covered, which deadline bucket you are in, and the first three things to do.
Public Schools
K-12 districts, charter schools, and BOCES. Parent portals, learning platforms, enrollment forms, IEP documents, lunch menus.
Public Libraries
City, county, and district libraries. Catalogs, ebook platforms, event calendars, room booking, digitized collections.
Parks and Recreation
Park departments and park districts. Program registration, league schedules, facility reservations, trail maps.
Cities, Towns, and Counties
General purpose local government. Agendas and minutes, permits, utility billing, emergency notices, every department's pages.
Public Health Departments
State and county health agencies. Clinic scheduling, inspection records, vital records requests, health alerts.
Police and Courts
Law enforcement and the judicial branch. Online reporting, records requests, e-filing, jury duty, fine payment.
Election Offices
Secretaries of state and county clerks. Voter registration, ballot tracking, polling place lookup, sample ballots.
Community Colleges
Public two-year colleges. Course catalogs, learning management systems, financial aid forms, student portals.
Why "Public Entity" Is So Broad
- Congress wrote Title II to reach all "services, programs, and activities" of state and local government, and the Department of Justice has applied that phrase to everything a government does, including how it communicates online
- Special purpose districts count as public entities too: water districts, transit authorities, library districts, park districts, mosquito abatement districts, and thousands of others
- You cannot contract your way out. If a vendor runs your payment portal or a contractor hosts your recreation registration, that content is still yours under § 35.200
- The definitions live in § 35.104, and the general nondiscrimination duties in Subpart B have applied since 1992. The web rule did not create your obligation. It told you how to measure it
Not Sure Where You Fit?
Some organizations straddle categories. A county library system is both a library and part of a county. A school district's recreation programs look a lot like parks and rec. Read the guide that matches what your website does most, then use the compliance checklist to cover the rest. If you are brand new to all of this, start with the complete Title II web accessibility guide or jump straight to your first steps.
Know your deadline. Know your gap.
Whichever kind of public entity you are, the question is the same: how far is your website from WCAG 2.1 AA, and what should you fix first? An assessment answers both.