The ADA Title II deadline: a 2027 checklist for cities and counties
DOJ moved the web accessibility deadline to April 2027. Here is the quarter-by-quarter checklist that gets a city or county compliant without a panic rebuild, and the reasons not to treat the extension as a pause.
The Department of Justice gave you a year. In April 2026, an interim final rule moved the ADA Title II web accessibility compliance date for governments serving 50,000 or more people from April 2026 to April 26, 2027. Smaller entities and special districts moved from 2027 to April 26, 2028. The technical standard did not change: WCAG 2.1 Level AA, for your web content and your mobile apps.
Here’s the quiet part. The extension didn’t happen because the requirements got easier. It happened because most public entities weren’t going to make it. The same calendar math that produced the extension is already running again, and the entities that treat April 2027 as a 2026 project will be fine. The ones that treat it as a 2027 project will be exactly where they were last spring: out of time, negotiating with vendors who know it, and paying panic prices.
This is the checklist I’d run if I were sitting in your seat. It assumes you’re starting roughly now, mid-2026, with a real budget process and a small team.
First: know what actually counts
The rule covers more than “the website.” It covers web content and mobile apps that you provide or that vendors provide for you: the utility billing portal, the recreation signup system, the agenda packets, the court forms, the transit app, the school district’s grade portal. If a resident uses it to get a service from you, it’s in scope, including the things you license from a vendor and have never once looked at.
There are real exceptions: archived content that sits in a clearly labeled archive and isn’t currently used, certain pre-existing documents, individualized password-protected documents, and some third-party content you don’t control. The exceptions are narrower than people want them to be. The PDF exception, in particular, evaporates the moment a document is currently used to apply for or participate in your services. Your 2014 council minutes can stay as they are. Your permit application cannot.
Summer 2026: inventory and budget
Two jobs before anything else.
Build the inventory. Every domain, subdomain, microsite, mobile app, vendor portal, and document repository you own or contract for. Most cities find systems in this step that nobody currently administers. You cannot scope remediation, or even get an honest quote for it, without this list, and it’s the least technical task on this page. A spreadsheet is fine.
Get it in the budget. If your fiscal year starts in July, the budget that funds this work is being written right now. Remediation money requested in spring 2027 arrives after the deadline. The single most common failure mode we see isn’t technical: it’s a compliance deadline living in one department while the money lives in another, on a different calendar.
Fall 2026: audit and vendor sweep
Audit what you have. Automated scanners are where you start, not where you finish: they catch maybe a third of WCAG 2.1 AA issues. The rest takes a human with a screen reader and a keyboard. Prioritize by service-criticality, not by traffic: the page where someone applies for housing assistance outranks the mayor’s bio, whatever the analytics say.
Sweep your vendors now. This is the step with the longest lead time, because it runs on other people’s contract cycles. For every system on your inventory that a vendor runs, ask for their accessibility conformance report (an ACR or VPAT) in writing, ask what they’ll remediate and by when, and get accessibility language into every renewal that crosses your desk between now and 2027. A vendor who can’t produce documentation is giving you your answer. The rule doesn’t care that the booking system belongs to a contractor: the obligation is yours.
Winter 2026: remediate in the right order
Fix in order of consequence. Service transactions first: anything a resident must complete to receive something. Then the documents currently in use, which for most counties is the ugliest pile: forms, notices, applications, agenda packets. Triage them honestly: archive what genuinely qualifies for the exception, remediate what doesn’t, and stop producing new inaccessible ones, which brings us to the part everyone skips.
Fix the factory, not just the inventory. Most accessibility debt is manufactured fresh every week by content authors who were never trained. Headings used for styling, images without alt text, PDFs exported from Word with no structure. An afternoon of training for the people who publish, plus accessibility checks built into your CMS workflow, does more for April 2027 than a month of consultant remediation, because it stops the bleeding.
This is also where modern tooling has genuinely changed the workload. Continuous scanning, first-pass alt text drafts, document triage at scale: AI agents handle that grind well under human supervision, and they should, because your two-person web team was never going to hand-audit nine thousand PDFs. The point isn’t replacing your staff with software. It’s that the clerk who maintains the agenda system should spend her hours on judgment calls, not on opening files one at a time to see which ones have headings. We run our own products on exactly this kind of leverage, so this is practice, not theory.
Spring 2027: prove it
The last quarter is documentation. A public accessibility statement with a working feedback channel. A named owner, because compliance without an owner is a rumor. Records of what you tested, what you fixed, what you triaged into the archive exception and why. If you ever need to make an undue-burden or fundamental-alteration argument, it has to be documented and signed by the right official, not improvised in a deposition.
And then re-test, because remediation regresses. The site that passed in January fails in June after two redesigned department pages and a new events calendar.
The reason not to coast
One more thing about that extension, because I’ve heard the sigh of relief in too many rooms this spring.
Title II itself didn’t pause. Residents can file complaints today, demand letters are circulating today, and WCAG 2.1 AA was the de facto standard in litigation before this rule existed. The 2027 date is when DOJ’s specific technical requirement attaches, not when your exposure begins. An extension spent waiting converts a manageable eighteen-month project into the 2028 emergency procurement nobody budgets well.
The math is boring and it’s on your side if you start now: eighteen months, four phases, no heroics required.
If you want a second set of eyes on where your city or county actually stands against this list, bring us your inventory, or bring us nothing and we’ll help you build one. We’ll tell you honestly how big your version of this is, and what the smallest useful engagement looks like.
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