Recordstake

West Jordan, Utah

ADA Title II · The dates

When is the ADA Title II deadline for your agency?

26 April 2027 if your entity's total population is 50,000 or more. 26 April 2028 if it is under 50,000, or if you are a special district government of any size. The technical standard is WCAG 2.1 Level AA.

  • 26 Apr 2027

    total population of 50,000 or more

  • 26 Apr 2028

    under 50,000, and special district governments

Both dates moved, and a lot of published advice still has the old ones

The rule was published on 24 April 2024 and originally set 24 April 2026 and 26 April 2027. An interim final rule effective 20 April 2026 extended both by a year, to the dates above.

If a vendor or an article quotes you 2026, they have not read the rule since it changed. That is worth checking early, because the difference is not academic — it is a year of budget cycle, and an agency that believes it has already missed a date makes different and worse decisions than one that knows it has twelve months.

You do not have to take our word for either date. The extension is published in the Federal Register, the original rule is there too, and the Department of Justice keeps a plain-language summary. We read all three on 10 September 2026 before writing this page.

Which of the two dates applies to you

The test is the total population of the entity — not its budget, not its headcount, and not the size of its website. A city of 60,000 and a city of 600,000 are on the same date.

Special district governments are on 26 April 2028 whatever their population. That catches transit authorities, water districts, library districts and school districts, and it is the part most often got wrong, because some of them publish more documents than the cities around them. In one Utah survey we ran, a transit authority published more live documents than any city in the same list, and it is on the later date.

What the rule actually covers, which is less than everything

The deadline is the easy half of the question. The expensive half is which of your documents the rule reaches at all.

It does not cover everything your agency has ever published. It excepts archived material meeting four specific conditions, and preexisting documents that are not currently used to apply for, gain access to, or participate in a service. Which of your documents those exceptions remove is the single biggest factor in what this costs you — larger than the deadline, larger than your document count, and larger than any price per file a vendor quotes you.

An exception is not a permanent pass. Even where content is excepted, an entity still owes effective communication under the ADA — if a person asks for an excepted document in a form they can use, it generally has to be provided. Out of scope means "not required proactively", not "never has to be readable". Any vendor who tells you otherwise is selling you a smaller number, not a smaller obligation.

We are not attorneys and this is not legal advice. We produce evidence and a recommendation you can hand to your counsel, who decides.

What to do with the time you have

The first question is not "how do we fix these" but "how many are there, and how many are actually covered". Nobody can price the work without that, and most agencies we have spoken to cannot answer it about their own website.

We will count them for you at no charge. We read what your website already publishes, using a labelled crawler at one request per second that honours your robots.txt. You send us nothing, and we ask for no login, no credentials and no access to your systems.

Get the free scan
Three fields — your agency, its website, and where to send the result. Nothing to install, nothing to sign, and no meeting.

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