Article
Title II web accessibility: a 90-day plan for the small-city IT person
If you work in IT for a small city, county or district, there’s a decent chance you are also the webmaster, the help desk, the person who knows the Wi-Fi password and, as of 2024, the person someone forwards every email with “ADA” in the subject line.
This is for you. We already have a plain explainer of the Title II deadlines, so we’ll skip the background and go straight to a practical 90-day plan. No panic, no sales pitch disguised as a countdown clock.
First, the dates (checked against ADA.gov)
The Department of Justice’s web rule requires state and local governments’ web content and mobile apps to meet WCAG 2.1 Level AA. According to the ADA.gov fact sheet, an Interim Final Rule published April 20, 2026 extended the compliance dates:
| Your government | Compliance date |
|---|---|
| Total population of 50,000 or more | April 26, 2027 |
| Total population under 50,000 | April 26, 2028 |
| Special district governments | April 26, 2028 |
School districts aren’t special districts; ADA.gov explains which population they use. If your population is anywhere near 50,000, confirm which date applies with your attorney rather than with a hunch.
Either way, the next 90 days are a good time to start. ADA.gov’s own First Steps guide makes the same point more politely: creating and maintaining accessible content takes planning.
Days 1-15: Find everything you own
You can’t fix what you don’t know about, and every city has That One Microsite someone built for the 2017 parade.
- List every website, subdomain and app your organization publishes or pays for: main site, parks registration, utility billing, library catalog, agenda portal, the police department’s separate site.
- Note who controls each one. Your team, a vendor, a hosted platform.
- Pull a page count from your sitemap or CMS, and a rough PDF count. Estimates are fine.
- Flag the “must work” tasks: paying a bill, applying for a permit, registering for a program, finding meeting agendas, reporting a problem.
Deliverable: one spreadsheet. It will be ugly. That’s fine. Ugly spreadsheets have run local government for decades.
Days 16-30: Talk to your vendors before they talk to you
ADA.gov’s fact sheet is explicit that content a government provides through a contractor or vendor (its examples include calendars, maps, reservation and payment systems) generally still needs to meet WCAG 2.1 AA.
- Email each vendor and ask, in writing, what they’ve done to meet WCAG 2.1 AA and how they tested it.
- Ask for any Accessibility Conformance Report (ACR) they have, and read what it actually says, including the “partially supports” rows.
- Check renewal dates. A contract renewing next spring is your best moment to add accessibility language.
Our procurement checklist has questions you can copy.
Days 31-45: Get a baseline
Now find out where you stand on your highest-traffic pages and your “must work” tasks.
- Start with free browser checks. W3C’s Easy Checks walk you through things like page titles, image text alternatives, headings, contrast and keyboard access.
- Try your top forms with only a keyboard. If you get stuck, a keyboard user will too.
- Consider an automated scan of your templates and top pages. Automated tools are fast and consistent, but they can’t judge everything: whether alt text is meaningful or a form makes sense still needs a human. A clean automated report is not proof of conformance. W3C’s evaluation resources explain the difference.
Days 46-60: Fix the templates first
One fix to a shared header, menu or footer can repair hundreds of pages at once. That’s the best return on your time you’ll get all year.
- Navigation and skip links
- Focus visibility (can you see where you are when tabbing?)
- Form labels and error messages
- Color contrast in your theme
- Heading structure in your page templates
Days 61-75: Make a PDF policy (and stop the bleeding)
Many small governments publish a lot of PDFs. The rule has narrow exceptions for some older documents and archived content, with conditions, and ADA.gov notes that documents people currently use to apply for or access services don’t qualify. Don’t assume an exception applies; read the fact sheet and document your reasoning.
The practical move: change the habit going forward.
- Publish new information as web pages where you can.
- Make accessible PDFs the default for anything new (tagged, titled, real text, not a scan).
- Train the two or three people who post the most content. Usually that’s the clerk’s office.
Days 76-90: Write it down and plan the budget
- Draft an accessibility statement with a working way to report barriers. W3C has a statement guide.
- Write a one-page plan: what you found, what you fixed, what’s next, who owns it.
- Put a number in the budget request. Councils tend to approve line items more readily than vibes.
What this plan won’t do
Ninety days won’t make a site conform to WCAG 2.1 AA, and no checklist can promise compliance. Accessibility also isn’t a one-time project: new pages and documents have to meet the standard too. What this plan gives you is a clear picture, fewer barriers for residents right now, and a defensible next step. It also gives you something to say when the city manager asks, “Are we on this?”
This article is general information, not legal advice. Confirm your obligations and dates with your attorney.
Get a budget figure in two minutes
When you get to “put a number in the budget,” our free 2-minute budget estimate turns your page and PDF counts into a rough figure for an automated audit. It’s a planning number, not a quote, and it’s clear about what automated testing covers and what it doesn’t. Our Title II deadline guide and WCAG 2.1 AA in plain language are free too.
Before day one, you can run the free Title II Snapshot to get your likely deadline and a first look at up to 10 public pages. If you would rather hand off the scanning, here is what our automated WCAG 2.1 AA audit covers and what it leaves out.