Guide
Title II deadline for school districts, libraries and special districts: 2027 or 2028?
The Title II web rule has two compliance dates. Which one is yours depends on the total population of the government you belong to, and school districts and departments work that out in their own way.
The two dates
| State or local government | Compliance date |
|---|---|
| Total population of 50,000 or more | April 26, 2027 |
| Total population under 50,000 | April 26, 2028 |
| Special district governments (any size) | April 26, 2028 |
The Department of Justice published the rule on April 24, 2024. On April 20, 2026 it published an interim final rule that moved both dates back by one year. After the date, web content and mobile apps must keep meeting WCAG 2.1 Level AA.
School districts are not special districts
This is the most common mix-up. ADA.gov says a school district is not a special district government, so it does not get the 2028 date automatically. Instead:
- City school district: use the population of the city.
- County school district: use the population of the county.
- Independent school district: use the population estimate in the most recent Small Area Income and Poverty Estimates (SAIPE) from the U.S. Census Bureau.
So a small independent district can still have the 2027 date if its SAIPE population is 50,000 or more, and a district inside a large city or county will usually have the 2027 date.
Departments, libraries, police, and other parts of a larger government
A city library, police department, or parks department usually has no population figure of its own. ADA.gov says to use the population of the larger government it is part of. A library run by a city of 80,000 people has the April 26, 2027 date, even if the library itself serves fewer people.
For most governments the population figure comes from the 2020 data published by the U.S. Census Bureau. The rule's appendix explains the details under "Total Population" in the section on definitions.
Who else is covered
The rule applies to all state and local governments and their agencies, including public schools, community colleges and public universities, courts, elections offices, public hospitals and clinics, public libraries, parks and recreation programs, and transit agencies. It also covers web content and apps that a contractor or vendor provides on a government's behalf, such as a payment or scheduling tool.
A quick way to check your date
- Write down which government you belong to: a state, county, city, town, or an independent body.
- If you are a school district, find out whether it is a city, county, or independent district, and use the matching population source above.
- If you are a department or library, use the population of the government that runs you.
- If that total is 50,000 or more, plan for April 26, 2027. Otherwise, and for special district governments, plan for April 26, 2028.
- Ask your counsel to confirm, and keep a note of the figure and source you used.
The free Title II Snapshot walks through the same questions, shows the date that likely applies, and reads basic page and PDF signals from up to 10 of your public pages.
What to do next
Whichever date applies, the work is the same: list your sites, apps and documents, test the pages people use most, fix the highest-impact problems, and publish an accessibility statement. Our Title II deadlines guide has a six-month plan, and WCAG 2.1 AA in plain language explains the standard.
To see what an automated audit would cost before you talk to anyone, use the free budget estimate. It uses the same published prices as our pricing page.
Sources
- ADA.gov, Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments (read October 26, 2026)
- Federal Register, Extension of Compliance Dates (interim final rule), April 20, 2026
This guide is general information, not legal advice. Confirm your obligations with your counsel.