Who It Applies To · Election Offices
ADA Title II Website Accessibility for Election Offices
Last updated June 11, 2026
More than 38 million eligible voters have a disability. They register, find polling places, request mail ballots, and check results on your website. The ADA Title II web rule requires all of it to meet WCAG 2.1 Level AA, and the compliance dates collide with the 2028 presidential election cycle.
Why Title II Applies to Election Offices
County clerks, registrars, boards of elections, and secretaries of state are public entities or programs of public entities, so everything they do falls under ADA Title II. Voting is the textbook example of a service, program, or activity of government. The 2024 web accessibility rule added a specific technical standard for the digital side of that service: web content and mobile apps must conform to WCAG 2.1 Level AA under 28 CFR Part 35, Subpart H.
Election websites also carry a timing problem no other government office has. Voter registration closes on a date. Ballot request windows close on a date. A resident who cannot use your registration form does not get a second chance next week; they lose their vote in that election. That is why accessibility failures on election sites convert directly into disenfranchisement, and why advocacy groups test these sites every cycle.
What Counts as Covered Content for Election Offices
Under section 35.200, the rule covers web content you provide or make available, including through state systems and private vendors. For an election office, that means:
- Voter registration. Online registration forms, downloadable registration PDFs, and registration status lookup tools
- Polling place lookups. Address-based finders, maps, and hours. A map alone is not enough; results must be readable by screen readers and usable by keyboard
- Sample ballots. Usually PDFs, and usually the least accessible documents on the site. A sample ballot a blind voter cannot read defeats its entire purpose
- Absentee and mail ballot requests and tracking. Application forms, signature requirements, deadline calendars, and ballot status trackers
- Election-night results. Live dashboards, maps, and tables, often vendor-hosted, viewed by more residents in one night than the rest of your site sees all year
- Candidate filing. Declaration forms, petition requirements, campaign finance portals, and filing calendars. Candidates with disabilities are covered too
Your Deadline, and Why It Is Tighter Than It Looks
Election offices serving a total population of 50,000 or more must comply by April 26, 2027. Offices serving under 50,000 have until April 26, 2028.
Look at where those dates fall. April 26, 2027 arrives while you prepare for the 2028 cycle: ballot design, equipment testing, and poll worker recruitment all start that year. And April 26, 2028 lands in the middle of a presidential election year, after most primaries and weeks before general-election preparation peaks. No election administrator wants to be rebuilding the website that spring. Whichever bucket you are in, the practical deadline is 2027. See the full deadlines breakdown.
The Exceptions That Matter Most for Election Offices
The five exceptions in section 35.201 are narrow, and for elections two are particularly useful to understand:
- Archived web content. Past election results, old sample ballots, and prior-year canvass reports can qualify if they predate your compliance date, are kept for reference only, live in a clearly identified archive section, and are not updated. This is your tool for the mountain of historical results pages
- Preexisting conventional electronic documents. Old PDFs are excepted unless voters currently use them to participate in your programs. Current registration forms, ballot applications, and this cycle's sample ballots are all in active use, so the exception does not help with any of them
- Third-party content. Posts by outside parties on their own initiative are excepted. Your results vendor, your ballot tracking vendor, and your registration platform are not third parties in this sense. Content you arrange to provide is yours
Three Ways to Start Before the Cycle Heats Up
- Walk the voter journey with a keyboard and a screen reader. Register, look up a polling place, request a mail ballot, track it. Note every point of failure. Our first steps guide turns that walk into a work plan
- Fix the documents tied to the next election first. Registration forms, ballot applications, and sample ballot templates get reused every cycle, so one accessible template pays off repeatedly. The Title II compliance checklist covers what accessible documents require
- Call your results and ballot-tracking vendors now. Ask for their WCAG 2.1 AA conformance documentation before the 2028 cycle locks in your contracts. If they cannot produce it, you have time to push or switch. In March 2028, you will not
Questions Election Offices Ask
Is our online voter registration covered if the state runs the system?
Both of you are covered. The state system must conform because the state provides it, and your county or municipal pages that link to it, explain it, and supplement it with local forms must conform too. Voters experience registration as one journey, so an accessibility failure at either end blocks the same voter.
Do sample ballot PDFs have to be accessible?
Yes. A sample ballot for an upcoming election is a document voters currently use to participate in your services, so the preexisting-document exception does not apply. It needs a proper reading order, real text instead of scanned images, and tagged structure. Sample ballots from past elections can move to an archive and qualify for the archived content exception.
Our election-night results page comes from a vendor. Is it our problem?
Yes. Content you make available through contractual or licensing arrangements is covered, and results dashboards are among the highest-traffic pages a county publishes all year. Maps and bar charts need text alternatives, and the underlying numbers should be available in accessible tables that update with the display.
We meet HAVA accessibility requirements for voting machines. Does that cover our website?
No. The Help America Vote Act covers voting systems and polling places. The ADA Title II web rule is a separate obligation covering your web content and mobile apps, with its own standard, WCAG 2.1 Level AA, and its own deadlines. An accessible ballot-marking device does not help a blind voter who could not find their polling place on your website.
Why should a small election office act now if our deadline is April 2028?
Because April 26, 2028 lands in the middle of a presidential election year. Primaries will be over or underway, mail ballots will be moving, and your site will be under its heaviest traffic and scrutiny exactly when compliance becomes mandatory. No election official wants to launch website changes that spring. Finishing in 2027 turns the deadline into a non-event.
Be ready before the 2028 cycle starts
A WCAG 2.1 AA assessment of your registration, ballot, and results pages tells you what to fix while there is still calendar room to fix it. Election years do not leave slack for surprises.