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Public record desk: Title II operating recordCounties and cities: 50,000+ residentsDeadline: April 26, 2027
Deadline brief

Updated Title II deadline brief for counties and cities

The Department of Justice extended the Title II web and mobile accessibility compliance dates by one year in April 2026. PublicProof treats the extension as time to build the operating record: inventory, ownership, remediation, vendor accountability, exceptions, and evidence.

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Dates at a glance
Public entity groupCurrent compliance dateOperating implication
State and local governments serving 50,000+ peopleApril 26, 2027Large counties and cities should use the added year to move from isolated scans to an evidence-ready operating record.
State and local governments serving fewer than 50,000 people and special district governmentsApril 26, 2028Smaller entities and special districts still need a defined scope, owner map, and vendor path before the deadline year arrives.
What changed
  • The April 20, 2026 DOJ interim final rule extended the 2024 final rule compliance dates by one year.
  • The current large-entity compliance date is April 26, 2027.
  • The current smaller-entity and special district compliance date is April 26, 2028.
What did not change
  • WCAG 2.1 Level AA remains the technical standard for covered web content and mobile apps.
  • Vendor-arranged web content and mobile apps can still be in scope when provided for the public entity.
  • Public entities still need defensible documentation for scope, exceptions, remediation ownership, and evidence.
Recommended operating response
  • Build an inventory across websites, subdomains, document repositories, forms, mobile surfaces, and vendor-managed systems.
  • Assign internal and vendor ownership for service-critical findings instead of treating every scan result as the same kind of risk.
  • Track remediation tasks with due dates, verification criteria, blockers, and status.
  • Keep exception review separate from operational evidence gathering so legal judgment is not mixed with scanner output.
  • Produce a recurring evidence pack that leadership, ADA, legal, procurement, and digital services owners can review.
Official sources and legal note

Read the DOJ materials directly: ADA.gov Title II web rule fact sheet and Federal Register interim final rule extending compliance dates. This brief is general product information, not legal advice.