Beginning April 24, 2026, most state and local government websites, mobile apps and social media content must comply with new accessibility requirements under Title II of the Americans with Disabilities Act. For many cities, this will require coordination across departments, vendors and procurement practices to ensure compliance. This rule will have wide-ranging impacts for many city departments, staff and vendors.
Why Accessibility Standards?
Web accessibility standards ensure that residents with disabilities can fully access and interact with the content, tools and features of a local government’s digital presence. Residents with disabilities may use assistive technologies such as screen readers, captioning and alternative keyboards and input devices. They may also rely on certain design features like clear, high-contrast text, predictable menus, or multiple formats of information to effectively use government websites, social media posts and mobile apps. These standards ensure that all residents can access government services and information, complete important forms and processes and receive important updates regardless of ability.
Key Requirements of the Rule
The rule requires all state and local governments to conform to WCAG 2.1, Level AA technical standards for accessibility. These are a set of guidelines developed by the World Wide Web Consortium, an international standards-setting body. The rule applies to nearly all digital content, including text, images, sound, videos and documents. It also applies to content not directly developed by the local government or not hosted directly on the local government’s website, including mobile apps, dashboards and other site features developed by third parties on behalf of the local government, and social media posts. The requirements apply prospectively to all content posted beginning April 24, 2026 for public entities (other than special district governments) serving populations of 50,000 people or more, and April 26, 2027 for those serving populations of below 50,000 people.
Important Exceptions
There are several key exceptions to the rule that local governments may keep in mind as they work to upgrade digital platforms. First, archived web content — which is retained only for archival purposes — is exempt from the requirements. Preexisting conventional electronic documents like PDFs are exempt, although all documents posted from the effective date forward must be accessible. PDF documents that are not strictly archival and contain currently relevant information must be made accessible. Third-party content is only exempt from requirements if it is not covered by a contractual, licensing or other arrangement with the local government. Individualized, password-protected content, such as individual bills, are exempt, although those individuals may still request alternative formats of those materials. Lastly, preexisting social media posts are exempt, although all social media content on or after the effective date must comply.
Things to Keep in Mind
Many different city departments and vendors have a role to play in accessibility. For example, city communications teams should be trained on how to post accessible social media content, including image descriptions and captions. City council staff may need to understand requirements around captioning of public meetings that are streamed or posted to the city’s website, as well as how to ensure that documents such as meeting minutes, memos and agendas are accessible. City departments handling billing and permitting will need to ensure that these forms and portals meet accessibility requirements. Vendors providing meeting streaming services, video production, website design, data portals, parking apps and more will need to comply with accessibility requirements as well, and city procurement officials should verify these vendors’ compliance.
City legal teams should also be up to speed on the rule. Federal accessibility laws are enforced through litigation, and failure to comply with accessibility requirements can put cities at risk for costly legal battles.
What Should You Do Next?
Cities should begin by conducting an inventory of their digital assets, including websites, mobile applications, third-party dashboards and social media accounts. City staff may be able to use free online tools to conduct a preliminary assessment. W3, the body that sets accessibility standards, has created a guide for planning and executing accessibility improvements. Staff should assess vendor contracts to confirm accessibility obligations and identify gaps that may require remediation before the compliance deadline, as well as any changes that may need to be made to procurement policies. Accessibility consultants may be a crucial element of your city’s compliance plans and can provide actionable guidance, as can existing city technology vendors. Early planning will help cities avoid costly last-minute upgrades and reduce legal risk.
The Department of Justice has created resources for local governments to help understand the rule, including a First Steps Compliance Guide for state and local governments and a Small Entity Compliance Guide. DOJ also hosted a webinar to answer questions about the rule. Any questions can be directed to the DOJ’s toll-free ADA information line.
Take Our Survey
In February 2026, the Department of Justice announced it intends to formally reconsider whether some provisions in the rule may be made less costly. To help NLC advocate more effectively for cities, please share your city’s estimated compliance costs via a brief survey.
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