The obligation
What the rule actually says.
In April 2024 the Department of Justice finalised a rule under Title II of the Americans with Disabilities Act. It sets a specific technical standard and a specific date. Both are now law, and both apply whether or not anyone has complained about your site.
| Public entity | Must comply by | Who this is |
|---|---|---|
| Population 50,000 or more | April 26, 2027 | Cities, counties and other public entities at or above 50,000 residents. |
| Population under 50,000 · special districts | April 26, 2028 | Smaller cities, towns and special district governments — school, water, fire and transit districts. |
The standard is WCAG 2.1 Level AA
Not "accessible" in the abstract — a published, testable specification. That matters, because it means conformance can be evidenced rather than asserted, and it means a vendor who cannot produce evidence is not doing the work.
We build to WCAG 2.2 Level AA, which contains every 2.1 criterion and adds more. Exceeding the standard is the default, not an upgrade.
What counts as covered
This is where most cities underestimate the scope:
Your website — every page the public can reach, not just the homepage.
Mobile apps you provide.
Documents published on your site: agendas, minutes, notices, budgets, forms.
Third-party content you post. If it is on your site, it is your obligation — a vendor’s platform does not transfer the duty.
What this does not mean
The rule contains limited exceptions, and they are narrower than people hope. Archived content, certain pre-existing documents and some third-party posts are treated differently — but "we did not make it" and "it is old" are not general defences. If it is published on your site and the public needs it, assume it is covered and find out otherwise deliberately.
Start with a free accessibility read.
We will run your site and a sample of your documents against the same standard the rule uses, and tell you where you actually stand. No obligation, and you keep the report either way.