The Title II Deadline

For cities, counties, districts and public agencies

Your website
has a federal
deadline.


The Department of Justice's Title II rule requires state and local government web content and mobile applications to conform to WCAG 2.1 Level AA. In April 2026 DOJ issued an interim final rule extending the compliance dates by one year. It did not change the technical standard, it did not change the scope of covered content, and it did not pause the underlying obligation — which has been in effect for decades.

What follows is what the rule actually says, which date applies to you, and what a fixed-scope conformance review costs. No countdown theatrics beyond the arithmetic, and no claim that we can make a legal problem go away.

Which deadline is yours

Compliance date April 26, 2027

All special districts — fire, water control, library, mosquito control, community development — fall under the second date regardless of the population they serve.

What the rule says

Five facts, and
none of them are new.

This is the part worth reading before anyone sells you anything, including us.

The standardWCAG 2.1 Level AA. Not "accessible-ish," not a vendor's own scale. A published technical standard with numbered success criteria, which means conformance is checkable and a finding can be pointed at a specific criterion.
What's coveredWeb content and mobile apps that your entity provides — including content you operate through a contracted vendor. Your CMS, your agenda and minutes platform, your payment portal, your job board. "The vendor handles our website" is not an exemption.
The exceptionsNarrow, and worth knowing precisely: archived content, preexisting documents not in active use, third-party content not posted by or for the entity, password-protected individualized documents, and preexisting social media posts. Everything else is in scope.
The extensionAn interim final rule on April 17, 2026 moved both dates out by one year. The technical standard and the scope of covered content are unchanged.
What it didn't doThe extension did not pause Title II. The obligation to provide accessible programs and services predates the web rule. A complaint does not wait for a compliance date, and the new dates are when conformance to this specific standard becomes enforceable — not when accessibility starts to matter.

Florida adds a state layer on top of this for state agencies: Fla. Stat. § 282.603 applies Section 508 standards to electronic information and information technology across the executive, legislative and judicial branches. It does not reach counties, municipalities or districts — those are covered by Title II, above.

The two dates

One of these is yours.

Population served is the test, and it's the population of the area your entity serves rather than your headcount or your budget.

Public entities serving 50,000 or more Most counties, and cities from mid-size upward. If you're near the line, use your official population figure and document which one you used. April 26, 2027
Public entities serving fewer than 50,000 — and all special districts Small municipalities, and every special district regardless of population: fire, water control, library, mosquito control, community development, hospital districts. April 26, 2028

The later date is not the easier position. Small entities are the ones with no in-house IT, the oldest sites, the largest backlog of scanned PDFs, and the least vendor attention — and the work takes longer precisely because there's less staff to do it. If you're on the 2028 date, the extra year is the budget cycle you need, not slack.

The front-door review

A conformance review
your vendor can act on.

Fixed scope, fixed price, and it ends in a written document rather than a presentation. Findings are written against the numbered success criteria, so the fix list can go straight to whoever maintains the site without translation.

01

The conformance pass

Your site and mobile app against WCAG 2.1 AA — automated testing across the templates, then manual checking of the things automation cannot see: keyboard-only navigation, focus order, form labelling and error handling, contrast on live content, and how the page behaves at 200% zoom.

02

The documents nobody checks

Agendas, minutes, budgets, permit applications, board packets. In most public entities this is the largest single body of non-conformant content, it grows every meeting, and it is the material a complaint is most likely to name. The review inventories it, samples it, and gives you a volume figure and a triage order rather than an unusable list of every PDF you own.

03

The contracted-vendor question

The rule covers content you provide through a vendor, so the review names which findings sit with which platform — and which of them your existing contract already obliges that vendor to fix. Some of your remediation is work you have already paid for.

04

The findings document

Now / Next / Later, each finding mapped to its success criterion, split three ways: what your team does, what your vendor is contractually obliged to do, and what we would do. Dated, with the testing method written down, so it stands up as a record of the effort you made.

What this is not: we don't install an accessibility widget and call it done. Conformance is a property of the content itself, not of a script layered over it — an overlay does not make a non-conformant page conformant, and the finding list is what your auditors, your vendor and, if it ever comes to it, a complainant will actually look at.

What it costs

$10,000, fixed,
and priced on purpose.

One scope, one price, one invoice. No hourly billing, and no retainer to begin.

The number is deliberate. The federal micro-purchase threshold rose to $15,000 effective October 1, 2025, and below that ceiling a cardholder may acquire services under simplified procedures without competitive quotes. Many state and local entities set their own small-purchase thresholds in a comparable band. Check yours — if this sits under it, the review is a purchase your department can make on its own authority inside this budget year, rather than a solicitation that lands after your deadline.

If it doesn't sit under your threshold, say so and we'll respond to your process properly. We're not going to advise you around your own procurement rules.

The same $10,000 review is what a private multi-location operator buys from us, and it covers the phones as well — the call census, the intent inventory and the routing map. If your agency runs a 311 line, a permit desk or a utility billing line that people cannot get through to, tell us and that half comes with it. The main site describes that work.

Where we stand

What we hold,
and what we don't.

Every public statement a vendor makes becomes part of the record, so here is ours in a form you can check. We're early in public-sector work and we'd rather you learn that from us than from a reference call.

What we hold

  • ✓A documented incident-response protocol, including what happens when an on-call path fails.
  • ✓Change control — every fix becomes a written, versioned rule rather than a thing someone remembers.
  • ✓A written redaction standard for anything containing resident or customer detail.
  • ✓Defined escalation to a human, with the trigger conditions written down.
  • ✓An operating service company of our own — Innovo Spa, two states, seven zones — running on the same architecture we install.

What we don't

  • ×A GSA schedule or any other contract vehicle.
  • ×SOC 2 Type II. If your requirement calls for it, we don't meet it today and we'll tell you that at the first conversation rather than the last.
  • ×Public-sector past performance. We have commercial work and our own operating company, and that's what a reference call would cover.
  • ×A capability statement listing any of the above. We'll print one when there's something true to put on it.

Why an operations firm is doing accessibility work at all: it's the same job. Our whole practice is what happens to a person trying to reach you — before the call and during it. A resident who can't use your website and a resident who can't get through on your phone are the same failure, counted in two places. We started counting on the phone side because that's where our own company was losing people.

How this starts

Send us your domain.

That's the whole first step. We'll run a first pass on the public templates at no charge and tell you roughly what you're facing and which deadline applies to you — enough for you to decide whether the full review is worth a line in the budget. If it isn't, you'll have that in writing too.