Does the Title II rule apply to private businesses?

No. Title II covers state and local governments. Private businesses open to the public fall under Title III, which has no detailed web regulation. The Justice Department's 2022 guidance still says Title III applies to goods and services offered online.

Yes, web content includes documents such as PDFs, with limited exceptions for some preexisting documents. Read the rule's exceptions carefully or ask counsel which of your documents qualify.

Will the deadlines move again?

They might. The April 2026 rule was an interim final rule with a public comment period. Check ADA.gov and the Federal Register for the current dates.

ADA Title II web rule: who it covers and the 2027 and 2028 deadlines

By WCAGCLEAR Nerds. Published October 22, 2026, updated October 28, 2026.

Short answer: the 2024 Title II rule requires state and local government websites and mobile apps to meet WCAG 2.1 AA. After an April 2026 extension, larger governments must comply by April 26, 2027, and smaller ones and special districts by April 26, 2028.

Who does the Title II web rule cover?

It covers state and local government entities, called public entities, and the web content and mobile apps they provide or make available, including through contracts or licensing. Cities, counties, public schools, public universities, transit agencies and special districts are all public entities. Private businesses are covered by Title III instead.

Vendors that build or run sites for public entities are affected in practice, because the rule applies to content provided through contractual arrangements.

What are the compliance deadlines?

An interim final rule published April 20, 2026 extended both dates by one year. Public entities with a total population of 50,000 or more must comply starting April 26, 2027. Entities under 50,000 and special district governments must comply starting April 26, 2028. The original dates were April 24, 2026 and April 26, 2027.

The Justice Department invited comments on the extension through June 22, 2026. Check ADA.gov for any later changes before relying on these dates.

What technical standard does the rule require?

The rule adopts WCAG 2.1 Level AA, published by the W3C in June 2018, as the technical standard for web content and mobile apps. It also lists limited exceptions, such as certain archived content and some preexisting documents, where content may not need to meet the standard.

Inventory every site, app, PDF and form you provide.
Prioritize services people use most, such as payments, applications and permits.
Write WCAG 2.1 AA into vendor contracts and acceptance testing.
Plan document remediation separately from the website.

Frequently asked questions

Does the Title II rule apply to private businesses?: No. Title II covers state and local governments. Private businesses open to the public fall under Title III, which has no detailed web regulation. The Justice Department's 2022 guidance still says Title III applies to goods and services offered online.
Do PDFs count?: Yes, web content includes documents such as PDFs, with limited exceptions for some preexisting documents. Read the rule's exceptions carefully or ask counsel which of your documents qualify.
Will the deadlines move again?: They might. The April 2026 rule was an interim final rule with a public comment period. Check ADA.gov and the Federal Register for the current dates.

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Sources

Interim final rule: Extension of Compliance Dates (April 20, 2026), Federal Register
Final rule: Accessibility of Web Information and Services of State and Local Government Entities (April 24, 2024), Federal Register
Title II Web and Mobile Application Accessibility Rule, U.S. Department of Justice, ADA.gov
Web Content Accessibility Guidelines (WCAG) 2.1, W3C

This guide is educational and is not legal advice. Talk to an attorney about your legal obligations.