ADA Title II website rules for small towns: what the 2028 deadline means

For years, website accessibility for local governments was a gray area. Everyone agreed that the Americans with Disabilities Act applied to city and town services, but there was no specific technical rule for websites, so most small towns did their best and moved on. That changed in April 2024, when the Department of Justice published a rule under Title II of the ADA that sets a clear standard and firm deadlines for state and local government websites and mobile apps.

If you serve a town of a few hundred or a few thousand people, the rule applies to you. The good news is that small governments have the most time, the standard is well documented, and most of the work is ordinary website maintenance done carefully. This guide explains what the rule asks for, what it doesn't, and how to plan the work without a big budget.

What the rule requires

The rule adopts the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA as the technical standard. WCAG is the international standard for accessible web content, published by the W3C, and it is organized around four principles: content must be perceivable, operable, understandable and robust. In practice, Level AA includes requirements such as:

• Text alternatives for images, so people using screen readers know what a photo, chart or flyer shows.
• Captions for prerecorded video, including recorded council meetings posted on your site.
• Enough color contrast between text and its background (4.5:1 for normal text).
• Everything works with a keyboard alone, with a visible focus indicator.
• Form fields have labels, and errors are explained in text.
• Pages have meaningful titles, headings in a logical order, and link text that makes sense.
• Text can be enlarged to 200 percent without breaking the page.

The standard applies to the content itself, not just the HTML pages. Documents you post, such as PDFs, Word files and spreadsheets, are covered too.

The deadlines

The original 2024 rule set compliance dates in 2026 and 2027. In April 2026, the Department of Justice issued an interim final rule that pushed each date back one year. The requirements themselves did not change.

Population is based on the census population of the jurisdiction. A lawsuit challenges the extension, and the department has said it may propose further changes, so treat these dates as current but not guaranteed. The safest plan is to aim for the earlier work now and use the remaining time for documents and vendor fixes.

What's covered

The rule covers "web content and mobile apps" that a public entity provides or makes available. For a typical small town, that means:

• The main website, including department pages, news, the calendar and contact information.
• Documents: agendas, minutes, packets, budgets, ordinances, newsletters, forms and applications.
• Vendor platforms you use to deliver services: online bill pay, utility portals, permit and licensing systems, agenda management, recreation registration, job applications. The rule covers content provided "directly or through contractual, licensing, or other arrangements", so the town remains responsible even when a vendor hosts it.
• Video and audio you post, such as recorded meetings and informational videos.
• Social media posts made after the compliance date (images need alt text, videos need captions).
• Mobile apps the town provides or contracts for.

The exceptions that matter

The rule includes several exceptions, and understanding them saves small towns a lot of unnecessary work:

• Archived web content. Content created before the compliance date, kept only for reference, research or recordkeeping, stored in a clearly marked archive area, and not changed since it was archived.
• Preexisting documents. PDFs, Word files and other conventional electronic documents posted before the compliance date, unless people currently use them to apply for, access or participate in a service. A 2019 meeting agenda is likely excepted; a building permit application you still accept is not.
• Third-party content. Content posted by members of the public or others who aren't acting for the town, such as comments, is excepted. Content a vendor provides under contract is not.
• Individualized, secured documents. Documents about a specific person or account behind a login, such as a utility bill, are excepted, but the town must provide them in an accessible format to anyone who asks.
• Preexisting social media posts. Posts made before the compliance date.

Even when content is excepted, the town still has a general ADA duty to communicate effectively. If a resident asks for an old document in an accessible format, provide it promptly.

Where small town websites usually fall short

After reviewing many local government sites, the same handful of issues come up again and again:

1. Untagged and scanned PDFs. Agendas exported without tags, or scanned signed copies with no text at all. These are invisible to screen readers.
2. Low-contrast design. Light gray text, colored buttons and text placed over photos.
3. Images of text. Event flyers and announcements posted as a single image with no text version.
4. Uncaptioned meeting videos. Auto-generated captions that were never reviewed, or none at all.
5. Inaccessible vendor tools. Payment and permit portals that can't be used with a keyboard.
6. Unlabeled embeds. Facebook feeds, maps and calendars dropped into pages without titles or text alternatives.
7. Accessibility overlays. A widget added in place of real fixes. Overlays don't make a site conform, and they can get in the way of assistive technology.

A practical 12-month plan

You don't need to fix everything at once. A steady plan spread over a year is realistic for a small staff.

Months 1 and 2: inventory and quick scan

List your website pages, the vendor tools you link to, and where documents live. Run your homepage through the ADA Compliance Checker in Key pages mode, which also scans the most used pages it links to, to get a baseline. Note the problems that repeat across pages; those live in the template.

Months 3 and 4: fix the template

Work with your web provider on sitewide fixes: header and footer contrast, the main menu and search box, a skip link, focus outlines and page language. One template fix clears the same issue on every page.

Months 5 to 7: documents going forward

Change how documents are made. Create agendas and minutes in Word using real headings and lists, add alt text to images, and export with tagging turned on. If your agenda software can publish an HTML version, turn it on. Stop posting scans of typed documents; post the original file and keep the signed scan on file. Then fix the older documents people still use, like applications and fee schedules.

Months 8 and 9: media and vendors

Caption recorded meetings and videos, and review auto-captions for errors. Ask every vendor for a current accessibility conformance report (often called a VPAT) and a timeline for fixing known issues.

Months 10 to 12: manual testing, statement and training

Test key tasks with a keyboard and a free screen reader (NVDA on Windows or VoiceOver on Mac and iPhone). Publish an accessibility statement. Train everyone who posts content on alt text, headings, link text and accessible documents, because new content is where problems come back.

Working with vendors

Because vendor platforms are the town's responsibility, contracts are one of the most effective tools you have. When you renew or sign a contract, include:

• A requirement that the product and any content the vendor provides conform to WCAG 2.1 Level AA.
• A current accessibility conformance report, and a commitment to update it.
• A process and timeline for fixing accessibility defects you report.
• Responsibility for remediation costs when the product doesn't meet the standard.

Publish an accessibility statement

An accessibility statement isn't a formal requirement of the rule, but it is one of the most useful things a small town can publish. It shows good faith and gives residents a way to get help. Keep it short and include:

• Your commitment to WCAG 2.1 Level AA and the date of your last review.
• Known problem areas and what you're doing about them.
• A named contact, phone number and email for reporting barriers or requesting documents in another format.
• How quickly you'll respond.

Link it from the footer of every page. The ADA Compliance Checker tells you whether a page links to one.

Frequently asked questions