In April 2024, the U.S. Department of Justice issued a final ADA Title II rule requiring state and local governments to make their websites and mobile applications accessible for people with disabilities. For municipalities under 50,000 people, the compliance deadline is April 24, 2027, making now the ideal time to start.
Who must comply (and when)
The rule applies to virtually all state and local government entities: cities, towns, villages, counties, school districts, library systems, and special districts that provide programs, services, or information through websites or mobile apps. The deadlines are staggered by population size so smaller governments have an extra year to plan and implement changes.
- Governments serving 50,000 or more people must comply by April 24, 2026.
- Governments serving fewer than 50,000 people, and special district governments, must comply by April 24, 2027.
- There are no size-based exemptions: even the smallest municipalities must ultimately meet the same WCAG 2.1 AA standard.
What “accessible” means: WCAG 2.1 AA
To provide clarity, DOJ adopted the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA as the technical standard for covered web and mobile content. WCAG 2.1 AA defines testable success criteria around perceivable, operable, understandable, and robust content, including areas like keyboard access, color contrast, headings, link text, error handling, and mobile responsiveness.
In practice, that means municipal websites and apps must support common assistive technologies, be usable via keyboard-only navigation, and avoid common barriers like images without text alternatives, inaccessible PDFs, and forms that screen readers cannot use effectively. The rule also covers multimedia, requiring captions for prerecorded and live video content and audio descriptions where appropriate.
How ADA Title II and Section 508 relate
Many municipalities have heard of “Section 508 compliance” because federal agencies and some state governments use Section 508 standards for ICT accessibility. Section 508 applies directly to federal agencies and certain federally funded ICT, while ADA Title II applies to state and local government programs and services, including their websites and apps.
Both frameworks now point to WCAG 2.0/2.1 AA as the accessibility baseline, which means aligning with WCAG 2.1 AA positions municipalities well under both ADA Title II and any 508-based procurement or grant conditions they may encounter. The key difference is enforcement pathway: ADA Title II is a civil rights law enforced through DOJ actions and private lawsuits, while Section 508 is primarily enforced through federal agency oversight and procurement.
Why small municipalities should start now
Although smaller entities have until April 2027, the required work often spans multiple budget cycles, vendor contracts, and internal processes. Municipal sites commonly include legacy CMS templates, thousands of documents, and third‑party tools that each require accessibility review and remediation.
Starting now helps municipalities to:
- Spread remediation and redevelopment costs over several years instead of rushing near the deadline.
- Integrate accessibility requirements into upcoming RFPs, CMS upgrades, and redesign projects rather than retrofitting later.
- Reduce legal exposure under existing ADA obligations even before the specific deadlines take effect.
A practical roadmap to April 2027
For small and mid‑sized municipalities, a phased, realistic plan is often the most sustainable path to compliance. A typical roadmap includes:
- Baseline audit
Conduct an independent WCAG 2.1 AA audit of your primary website, high‑traffic subsites, and core web applications (such as bill pay, permit portals, and online request systems). This should cover templates, navigation, key workflows, and sample content types including PDFs and forms. - Prioritize critical services and content
Focus first on content and tasks related to essential services: public safety, emergency alerts, utilities, elections, public meetings, and core resident services. Align this prioritization with DOJ’s guidance on “first steps” for Title II web accessibility. - Remediate templates and components
Fix global issues in your CMS templates, design system, and shared components (headers, footers, menus, buttons, form controls) so every page published going forward starts from an accessible baseline. This step usually yields large accessibility gains with relatively fewer changes. - Address documents, media, and third‑party tools
Identify which PDFs, forms, and multimedia are in active use and plan to convert, replace, or remediate them. Review embedded tools such as payment portals, GIS viewers, and meeting platforms to ensure they meet WCAG 2.1 AA or are replaced with accessible alternatives. - Build accessibility into policy, training, and procurement
Adopt a written web accessibility policy referencing WCAG 2.1 AA and the ADA Title II rule, and train staff who publish content or manage vendors. Update procurement language so future contracts for web, mobile, and software solutions require accessibility and testing up front. - Monitor, test, and iterate
Combine automated testing with periodic manual reviews and user testing involving people with disabilities. Treat accessibility as an ongoing quality standard rather than a one‑time compliance project.
Risks of waiting too long
The ADA has long required accessible digital services; the new Title II rule clarifies expectations and sets firm deadlines. Waiting until 2026 or 2027 compresses remediation into a short window, often increasing costs and forcing rushed decisions.
Non‑compliance can expose municipalities to DOJ enforcement, settlement agreements, and private lawsuits that may require rapid, expensive remediation and ongoing reporting. It can also erode public trust when residents with disabilities cannot access critical information or services such as emergency notices, online payments, or public meeting materials.
How an accessibility consultant can help
Specialized accessibility consultants can accelerate compliance by bringing focused WCAG 2.1 AA expertise, tooling, and repeatable processes. A11Y Pros provides senior-level specialists who routinely help public entities align their websites and digital services with ADA, Section 508, and WCAG requirements.
Typical support for municipalities includes comprehensive audits, remediation guidance for internal teams and vendors, targeted training, policy development, and ongoing monitoring aligned with the ADA Title II rule and April 2027 deadline. If you’re ready to understand exactly where you stand, you can schedule a Section 508/ADA Title II readiness audit with A11Y Pros and get a prioritized roadmap tailored to your municipality’s size, budget, and technology stack.
For small municipalities with limited IT staff, partnering with an experienced consultant can make the difference between scrambling at the last minute and following a manageable, phased plan to meet the April 2027 compliance date. To start that process, contact A11Y Pros to discuss a phased engagement—beginning with a baseline audit and extending through remediation support, staff training, and policy implementation—so accessibility is built into all future digital projects instead of treated as an afterthought.