ADA Title II Website Compliance: A Guide for Municipalities
By EVERNET Consulting · · 8 min read
For decades, Title II of the Americans with Disabilities Act has required state and local governments to make their services, programs and activities accessible. What it never did was say exactly what that meant for a website. That changed in April 2024, when the Department of Justice issued a rule setting a specific technical standard for government websites and mobile apps: WCAG 2.1 Level AA.
The rule applies to towns, cities, counties, school districts, special purpose districts and other public entities, including web content and apps they provide through vendors, contracts and licenses. This guide walks through what it covers, when it takes effect, what it exempts and how to build a realistic plan to get there. It summarizes the rule; your municipal attorney should confirm how it applies to you.
Your compliance date
The original rule set deadlines in 2026 and 2027. An interim final rule effective April 20, 2026 moved them back a year:
- Public entities with a total population of 50,000 or more must comply by April 26, 2027.
- Public entities with a total population under 50,000, and special district governments, have until April 26, 2028.
That may sound like plenty of time. It usually isn’t. Accessibility work involves the website itself, years of posted documents, vendor platforms you don’t control and the habits of every staff member who publishes content. Starting a year or more ahead is realistic, not early.
What the rule covers
The rule covers web content and mobile apps that a public entity provides or makes available, directly or through contracts, licenses or other arrangements. In practice that reaches much further than the main website. It includes department and subdomain sites; online payments, permits, licensing, recreation registration and job applications; agendas, minutes, notices and forms; meeting video, livestreams and audio; and mobile apps for things like parking, reporting problems or emergency alerts.
The rule also allows equivalent facilitation: designs, methods or technologies other than WCAG 2.1 AA are acceptable if they provide substantially equivalent or greater accessibility and usability.
The five exceptions
The rule recognizes that not everything a government has ever posted can be fixed, and it carves out five exceptions. Each comes with conditions, and it is easy to read them more broadly than they are written.
Archived web content
Exempt only if all four conditions hold: it was created before the compliance date or reproduces older paper or media records; it is kept only for reference, research or recordkeeping; it is stored in a clearly identified archive area; and it hasn’t been changed since it was archived.
Preexisting documents
PDFs, word processing files, presentations and spreadsheets available before the compliance date are exempt, unless they are currently used to apply for, access or participate in a service, program or activity. An old newsletter may qualify; a permit application still in use does not.
Content posted by a third party
Comments and posts by members of the public are exempt, unless the third party is posting because of a contract, license or other arrangement with you.
Individualized, password-protected documents
Documents about a specific person, their property or their account, such as a tax or utility bill, are exempt. A resident with a disability who needs one in an accessible format must still receive it.
Preexisting social media posts
Posts made before the compliance date are exempt. New posts are covered.
Don’t forget meetings and documents
Board and council meetings are one of the most common gaps we see. WCAG 2.1 AA requires captions for prerecorded video (success criterion 1.2.2) and for live video (1.2.4), so livestreamed meetings need live captions and recordings need accurate captions. Agendas, packets and minutes posted after your compliance date must be accessible documents, or published as accessible web pages. Our guide to PDF accessibility explains how.
A plan to reach compliance
Every municipality’s path looks a little different, but the steps are consistent:
- Inventory every site, subdomain, vendor platform, app, social account and document library.
- Audit representative templates, key services and high-use documents against WCAG 2.1 AA.
- Prioritize what residents need most: payments, applications, meeting information, emergency notices and contact options.
- Fix shared templates first so one change repairs many pages, then remediate content and documents.
- Manage vendors. Request current accessibility documentation, such as a VPAT or Accessibility Conformance Report, test the resident-facing steps yourself, and add accessibility requirements to contracts and renewals.
- Archive deliberately. Move outdated content into a clearly labeled archive that meets all four conditions, or remove it.
- Train staff who publish pages, posts and documents.
- Publish an accessibility statement with a way to report barriers, and keep monitoring after the deadline passes.
Where accessibility widgets fit. Tools like accessiBe, which EVERNET uses on its own site, can give residents helpful controls for contrast, text size and motion. But the Title II rule measures the website itself against WCAG 2.1 AA, so the fixes to templates, content and documents come first.
Get help before your deadline
EVERNET works with municipalities on accessibility audits, remediation, website redesign and staff training. We developed a website concept for the Town of Lyme that organized 101 original URLs into 73 destinations built around the tasks residents come to complete, and clear structure like that makes accessible navigation far easier to build and maintain. Learn more about ADA Title II website accessibility for municipalities, or schedule a call.
Let’s talk about what comes next.
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