For state and local government
The compliance date is when the work has to be done.
State and local government has a federal compliance date for its websites and mobile apps: April 2027 or April 2028.
The rule covers more than a website. Once the work can be seen, ranked, and dated, it becomes a plan a council can fund.
Your deadline depends on your population.
Populations of 50,000 or more have until April 2027, and smaller ones until April 2028.
Population is not the whole test. A special district government has until April 2028 at any size: a separate government set up for a single purpose or a few, such as a water, utility, or library district. So two bodies serving the same residents can land a year apart.
| A library that is part of a city of 60,000 | An independent library district | |
|---|---|---|
| Who it serves | The city's residents | The same residents |
| How it is set up | A department of the city | A separate government, with its own board and budget |
| Its date | April 2027 | April 2028 |
An independent school district is not a special district under the rule. It takes its date by the district's own population as the Census Bureau estimates it, which counts residents, not enrollment.
These show how the rule reads. Which date applies to your organization is a question for your counsel, against how it is constituted.
The date is the first deadline, not the last.
Commenters also asked whether public bodies should be required to review their content every few years. The Department answered in the rule:
"Additionally, some commenters suggested that public entities be required to review their content for accessibility every few years. The Department does not view this as necessary given the ongoing nature of subpart H's requirements. However, public entities might find that conducting such reviews is helpful in ensuring compliance."
89 FR 31352
The obligation runs continuously. The rule leaves the method to you.
"It is not the last."
"The compliance date is the first time that public entities need to be in compliance with subpart H's requirements; it is not the last."
Content added after the date is covered too. A plan that ends on the date ends too early.
It covers services, wherever they are delivered.
The rule applies to the web content and mobile apps a public body provides or makes available. The library catalog. Bill pay. Registration for a recreation program. The court's docket search. The transit agency's fare app.
That means every department's services, even the ones you do not run day to day, and the documents behind them: the applications, agendas, and forms a resident completes to get something done.
The standard the rule names is WCAG 2.1 at Level AA, a published international standard for whether people with impairments can use a website, an app, or a document.
A vendor built the system. The obligation stays with you.
Most public bodies did not build their own website or portal. A vendor did, and a barrier may have arrived with the system. Under the rule, the responsibility belongs to the public body, which answers for content it provides "directly or through contractual, licensing, or other arrangements."
Six months, vendors included
A city and county agreed to ensure, within six months, that its websites and all online services, "including those websites or online services provided by third parties upon which Denver relies to provide services or content," met WCAG 2.0 Level AA.
The agreement named the vendors' services outright. An independent measurement is something you hold yourself, rather than an assurance from the party that built the system.
Vendors build for many public bodies at once, and each system leaves its own pattern of issues across the sites built on it. Esther has measured government websites across the country, and can tell which issues come with the platform and which belong to your site. Some public bodies have closed their platform's known weak points themselves.
Five exceptions, each with conditions.
The rule lists them in 28 CFR § 35.201.
- Archives.Content from before the date, kept unchanged, only for reference, in a marked archive.
- Older documents.PDFs and similar files posted before the date, unless still used for a service.
- Others' posts.What others post on their own. Not what anyone posts for you.
- Personal records.Secured PDFs and similar files about one person, like a utility bill.
- Older social posts.Social media posts made before the compliance date.
Whether one of your documents qualifies is your counsel's call.
Federal funding adds its own obligation. Public bodies that receive federal financial assistance, public schools and colleges among them, also answer to Section 504 of the Rehabilitation Act, on the funding agency's terms. The requirements that apply depend on the agency and the program.
A plan a council can fund.
An independent, dated record turns an open-ended worry into work you can scope.
It shows the digital barriers that residents run into, with the ones that stop a resident paying, applying, or registering at the top. Each finding carries enough to hand straight to whoever owns it.
As issues are resolved, they come off the list, and each change is dated.
Procurement can use the same record. Before a contract is renewed, it gives an independent read on what the vendor claims.
And it goes to the council as an appropriation request, with the evidence attached. The work can be funded on your schedule, before the deadline forces it.
The date is known. The work can be planned against it.
Thirty minutes. Your situation, and where to begin.