ADA Compliance Deadlines Approaching for City Websites and Apps

Summary

Compliance deadlines for new DOJ ADA rules for municipal websites and apps are April 24, 2026 for large cities and April 24, 2027 for small cities and commissions.

The U.S. Department of Justice (DOJ) has released a rule requiring local governments to make their websites and mobile applications accessible to individuals with disabilities. The new rule, issued under Title II of the Americans with Disabilities Act (ADA), is a major development for cities, counties, school districts, and special-purpose entities that provide digital public services.

This year, Mike Bradley has presented on the new requirements at 3CMA, NATOA, and MACTA. Here is a summary of his presentations.

Key Takeaways

• Compliance is mandatory and based on the widely accepted WCAG 2.1 Level AA standard.
• Deadlines vary by population size:
  • April 24, 2026 – for public entities serving 50,000 or more people.
  • April 26, 2027 – for smaller public entities and special districts.
• Applies to websites, mobile apps, and online documents, even if maintained by third-party vendors.

---

Who Must Comply?

The rule applies to all state and local government entities, including cities, counties, public schools, courts, and transit agencies. It also includes special-purpose districts such as water, housing, and library boards.

Even if a public entity contracts with a private party to manage its online presence, the government is still responsible for ensuring accessibility under this rule.

---

What’s Required?

Websites and mobile apps are navigable by screen readers, have sufficient color contrast, and include text alternatives for images and non-text content.

• PDFs and other digital documents meet accessibility standards.
• Forms, alerts, menus, and other user interfaces are accessible without a mouse and compatible with assistive technologies.

---

Exceptions

The rule does include narrow exceptions for:

• Archived web content not updated after the effective date.
• Pre-existing third-party content (e.g., external links not under the entity’s control).
• Password-protected individualized documents (such as personal student or account records).
• Social media posts made before the compliance deadline.

Importantly, these exceptions do not eliminate the ADA’s general obligation to provide access. Alternative formats or accommodations must still be available upon request.

---

Implementation Strategies

To meet the deadlines, public entities should act now:

1. Assess your population size – Determine your compliance deadline using 2020 Census data.
2. Inventory your digital content – Include websites, forms, PDFs, videos, and mobile apps.
3. Prioritize frequently used services – Such as bill payment, permits, public notices, and meeting agendas.
4. Develop a remediation plan – Assign staff or hire consultants to update or replace non-compliant content.
5. Train your teams – Procurement, IT, communications, and records departments must understand accessibility requirements.
6. Include accessibility in all future contracts – Ensure that vendors and platforms commit to WCAG compliance.

---

Additional Resources

• The U.S. Department of Justice published “action steps” in early January designed to help city and county governments ensure that their web content and apps comply with DOJ’s Web and Mobile Application Accessibility Rule adopted in 2024.
• Additionally, DOJ’s Small Entity Compliance Guide is designed to help people working for or with state or local governments better understand the rule.
• State of California Website Accessibility Resources
  • https://webstandards.ca.gov/Accessibility/
  • https://www.dgs.ca.gov/Resources/Statewide-Forms/ADAComplianceToolkit
• Cablecast TV Blog
• League of Minnesota Cities Website Recommendations

---

How We Can Help

Our firm assists local governments in developing compliance strategies, reviewing digital accessibility policies, and negotiating contracts with third-party web vendors. We also provide ADA training for IT staff and public information officers.

For questions or to schedule a consultation, please contact Mike Bradley or our team at Bradley Werner, LLC.