Cities, towns, townships, villages, counties, boroughs
ADA Title II Website Accessibility for Cities, Towns, and Counties
Last updated June 11, 2026
If you run a municipal or county website, the ADA Title II web rule is now the floor, not a best practice. Every department's pages, every form, every vendor portal with your seal on it must meet WCAG 2.1 Level AA by your deadline. Here is what that covers and how to get moving.
Why Title II Applies to Your Government
Cities, towns, townships, villages, boroughs, and counties are the textbook public entities. Title II has covered all of your services, programs, and activities since 1992, and the 2024 web rule in 28 CFR Part 35, Subpart H made the digital side explicit: websites, mobile apps, and the documents on them must conform to WCAG 2.1 Level AA. Federal funding is irrelevant. Population only sets your date, never your obligation.
What makes general purpose government different is sprawl. A municipal website is really thirty websites wearing one domain: the clerk's pages, the police blotter, the planning department's PDFs, the utility billing portal, the court payment system, the parks calendar. Under the rule, all of it is yours, including the systems vendors host for you. The clerk who posts the agenda and the IT director who signs the CMS contract are working on the same compliance project, whether they know it or not.
About one in four adults in your jurisdiction has a disability. They pay the same taxes and need the same permits, bills, and emergency information as everyone else. The web rule simply requires that the digital city hall serve them too.
What Municipal Web Content Is Covered
- Agendas, minutes, and meeting video. Current agendas and packets must be accessible documents, and live or recorded meeting video needs captions. Agenda management platforms like Legistar, CivicClerk, and BoardDocs are covered because you provide them
- Permits and licensing. Building permits, business licenses, pet licenses, special event applications, and the citizen portals that process them, whether built in-house or by Accela, Tyler, or OpenGov
- Utility billing and payments. Water and sewer billing portals, autopay enrollment, court fines, parking tickets. Payment is access to a service, so the whole flow must work with assistive technology
- Emergency and public safety notices. Boil water advisories, snow emergencies, road closures, evacuation information, and alert signups. These must be accessible the moment they go up, not after the storm
- Forms and requests. Public records requests, service requests, pothole reporting apps, board and commission applications, job postings and applications
- Every department's pages. Assessor data lookups, GIS and zoning maps (with text equivalents for what they convey), election information, court dates, transit schedules, and the 311 app
Your Deadline
Your date comes from your own Census population. 50,000 or more: April 26, 2027. Under 50,000: April 26, 2028. Counties and the municipalities inside them are measured separately, so a 20,000-person city in a 300,000-person county has 2028 while the county itself has 2027.
The deadline moved. The work didn't. The budget cycle you are in right now is the one that pays for remediation, CMS work, and vendor changes, especially for 2027 entities. Find your exact date on the deadlines page.
The Exceptions That Matter Most for Municipalities
- Archived web content. Your deepest pile of risk is old meeting documents, and this exception handles most of it. Decades of minutes, agendas, and superseded plans can stay as-is in a clearly identified archive area, kept for reference and never updated
- Preexisting conventional electronic documents. PDFs, Word files, and spreadsheets posted before your compliance date are excepted, unless residents currently use them to apply for or access services. The 2014 comprehensive plan qualifies. The current fence permit form does not
- Individualized password-protected documents. A specific customer's water bill inside their secure account is excepted. The billing portal around it is not, and the bill must be made accessible on request
- Third-party content. Resident comments on your engagement platform are not your obligation. Your vendors' platforms are. Read the strict conditions in § 35.201 before you count on any exception
Three Ways to Start This Budget Cycle
- Inventory every digital property. Main site, department microsites, payment portals, agenda platform, alert system, social accounts, and apps. Most cities find systems nobody remembers buying. The compliance checklist gives you the structure and the order
- Name an owner. Entities with 50 or more employees already need an ADA coordinator under § 35.107. Make web accessibility an explicit part of that role, with authority over the CMS, the publishing workflow, and vendor contracts
- Test the top ten resident tasks. Pay a water bill, find tonight's agenda, apply for a permit, report a pothole, sign up for alerts, using only a keyboard. Fix what breaks first, because those are the pages residents and plaintiffs both reach first. First steps walks through the sequence
City and County Questions
Our town has 3,000 residents. Does the ADA web rule really apply to us?
Yes. There is no small-government exemption in Title II. Population only sets your deadline: under 50,000 means you have until April 26, 2028. The standard, WCAG 2.1 Level AA, is the same for a village of 3,000 and a city of 3 million.
Do twenty years of council agendas and minutes have to be remediated?
Almost certainly not. Old agendas, minutes, and packets kept for reference qualify as archived web content if you keep them in a clearly identified archive area and do not update them. Documents posted before your compliance date may also fall under the preexisting document exception. Current and future agendas and minutes must be accessible.
Is our vendor-hosted utility billing portal covered?
Yes. Content a public entity provides or makes available through contractual, licensing, or other arrangements is covered. The payment portal, court fine payments, permit applications, and your agenda management platform are all your responsibility, whoever hosts them. Individual customers' own bills inside a secure account may fall under the individualized password-protected document exception.
Which deadline applies to our city or county?
Use your Census population. Cities, towns, townships, and counties with 50,000 or more people must comply by April 26, 2027. Those under 50,000 have until April 26, 2028. DOJ extended both dates by one year in an interim final rule effective April 20, 2026.
Do emergency alerts and snow notices have to be accessible too?
Yes, and they are among the most important things to get right. Emergency notices, boil water advisories, road closures, and snow emergency declarations published on your website or app must be accessible in real time. An image-only alert posted during a crisis excludes exactly the residents who most need the information.
Thirty websites, one deadline
An assessment maps your entire digital footprint against WCAG 2.1 AA, separates what your staff can fix from what your vendors owe you, and gives your council a number to budget against.