ADA Title II web accessibility Your public website has a federal accessibility deadline.
The Justice Department's Title II rule says state and local government websites and apps must meet WCAG 2.1, Level AA. That covers counties, cities, towns, special districts and school systems in Northeast Tennessee and Southwest Virginia.
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Dustin Lifford. More than 20 years building government, school and utility websites in this region. About Dustin
Find your deadline.
From the Justice Department's April 2026 rule. School districts use the population of the city or county they serve. Sources
Who does the work
Public-sector websites, built under these rules for more than 20 years.
Few people in this region have built government, school and utility sites and also worked under the accessibility rules that come with them. Nearly every one of these had to meet them.
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Government
- City of KingsportMunicipal website, design and development
- Town of Jonesborough
- Carter County
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Education
- Mountain Empire Community College
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Utilities
- BrightRidgeElectric and broadband
- Mountain Electric Cooperative
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Tourism and regional
- Scott County TourismScott County, Virginia
- Daniel Boone Wilderness Trail
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Medical
- Several doctor and dental offices
Past work, by sector. These are not current builds, and the list says nothing about how any of these sites stands today. The full background is on the About page.
Where the rule stands.
The rule was adopted in 2024. In April 2026 the Justice Department moved the compliance dates out a year.
April 2024
Rule adopted
WCAG 2.1, Level AA becomes the standard for state and local government web content and apps.
April 2026
Dates moved
An interim final rule pushed both compliance dates back.
April 26, 2027
Population of 50,000 or more
Larger cities and counties.
April 26, 2028
Under 50,000, and special districts
Most towns and counties in this region, plus utility and other special districts.
A school district uses the population of the city or county it serves. An independent school district uses the Census Bureau's Small Area Income and Poverty Estimates. The Justice Department's fact sheet explains how to find your number.
The standard
WCAG 2.1, Level AA
The Web Content Accessibility Guidelines, named by version and level in the rule.
Vendors count
Bill pay and permits too
The rule covers content a vendor provides for you, not only the pages you write.
Not a pass until then
Some duties apply now
Existing Title II obligations, like communicating effectively with people with disabilities, already apply.
What usually needs work on a local government site.
All six are things WCAG 2.1 AA covers.
PDFs and scanned documents
Agendas, minutes, ordinances and forms posted as scans are pictures of text. A screen reader cannot read them, and they often have no headings or reading order.
Forms
Fields with no labels, errors shown only in red, and time limits nobody can extend.
Images without text alternatives
Photos, maps and charts with no alt text, so what they show never reaches someone who cannot see them.
Color contrast
Light gray text and pale buttons that many people cannot read.
Keyboard access
Menus, pop-ups and sliders that only work with a mouse, and no visible sign of where the keyboard is on the page.
Third-party tools and payment portals
Bill pay, permits, calendars and maps that come from a vendor. The rule covers content a vendor provides for you, so these count too.
One fix, up close
Contrast is measured, not eyeballed.
WCAG 2.1 AA asks for a contrast ratio of at least 4.5 to 1 for normal text. The pale button is a common sight on town sites. It looks fine to the person who picked the color.
From the first call to a written record.
Dustin does the work himself. One price for the job, and no long-term contract.
A free 15-minute call
About your site and your deadline. Book 15 minutes
An audit, by tool and by hand
Automated checks first, then a keyboard and a screen reader, because some checks cannot be automated.
A written proposal
What was found, what it takes, and one price.
Fix or rebuild
Fix the site where it can be fixed, like an old website rescue. Rebuild when fixing costs more. See web design.
Documents
Inaccessible PDFs become accessible files or web pages.
Handoff
A written record of what was checked and what changed.
What the record looks like
| Checked | Found | Status |
|---|---|---|
| Main menu | Dropdowns open on hover only | Fixed |
| Meeting agendas | Scanned PDFs, no text | Converted |
| Bill pay portal | Vendor form, unlabeled fields | Reported to vendor |
After the handoff
New agendas keep arriving.
The rule expects the site to keep meeting WCAG 2.1 AA after the date. A website support plan checks new content, with a report every month.
This is not legal advice, and no one can guarantee legal compliance. What you get is a site checked against WCAG 2.1 AA, the problems fixed, and a written record of what was checked and what changed.
About the widget you keep getting pitched.
A lot of governments get offered an accessibility overlay, a toolbar added to the site for a monthly fee and sold as the quick fix. It sits on top of the page. WCAG 2.1 AA is about what is underneath.
The Justice Department's own web accessibility guidance says automated checkers and overlays need to be used carefully, and that a clean report does not necessarily mean everything is accessible. The Overlay Fact Sheet, written and signed by accessibility practitioners, concludes that full compliance cannot be achieved with an overlay.
| A widget on top | Fixing the site | |
|---|---|---|
| The page code | Unchanged underneath | Headings, labels and keyboard behavior fixed |
| PDFs and documents | Unchanged | Converted or replaced |
| Forms | Unchanged | Labeled, with errors anyone can find |
| What you pay | A monthly fee | One price for the job |
Tools are useful for finding problems. Fixing them happens in the site itself.
Questions we hear.
Does this apply to our small town?
Yes. The rule covers state and local governments of every size. A town or county with a total population under 50,000 has until April 26, 2028, and so does any special district government. Governments of 50,000 or more have until April 26, 2027.
What standard do we have to meet?
WCAG 2.1, Level AA. That is the Web Content Accessibility Guidelines, version 2.1, published by the World Wide Web Consortium. The rule names that version and level for the web content and mobile apps a state or local government provides.
Will a widget or plugin make us compliant?
Not by itself. A widget layered on top of a site does not fix the underlying code, documents or forms, and that is what WCAG 2.1 AA measures. The section on widgets above explains why.
What about PDFs already on our site?
The rule has an exception for many documents posted before your compliance date. It does not cover documents people still use to apply for or take part in your services, such as a current application form, or old documents you update after that date. Even when a document falls under the exception, a person with a disability who needs it is still entitled to get it in a form they can use.
What does ongoing compliance look like?
New pages, meeting documents and vendor tools keep arriving after the work is done. The Justice Department says governments must keep their web content and mobile apps meeting WCAG 2.1, Level AA after the compliance date. A website support plan covers checking new content, with a report every month.
Is this legal advice?
No. Dustin is not a lawyer, and no one can guarantee legal compliance. For questions about your legal obligations, talk with your attorney or the Justice Department. What the work delivers is technical: a site checked against WCAG 2.1 AA, the problems fixed, accessible documents, and a written record of what was checked and what changed.
Sources.
Checked November 7, 2026.
- ADA.govFact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments
The rule, WCAG 2.1 Level AA, the current compliance dates, school district populations and the document exceptions.
- Federal Register, April 20, 2026Extension of Compliance Dates for Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities
The interim final rule (91 FR 20902) that moved the dates to April 26, 2027 and April 26, 2028.
- ADA.govGuidance on Web Accessibility and the ADA
The Justice Department on automated checkers and overlays, and pairing them with manual checks.
- World Wide Web ConsortiumWeb Content Accessibility Guidelines (WCAG) 2.1
The standard itself.
- W3C Web Accessibility InitiativeSelecting Web Accessibility Evaluation Tools
Why some accessibility checks cannot be automated.
- Overlay Fact SheetOverlay Fact Sheet
A statement by accessibility practitioners that full compliance cannot be achieved with an overlay.
- Tennessee Comptroller of the TreasuryMemo to Tennessee local government officials, March 24, 2026
A Tennessee reference on the requirement. It was issued before the April 2026 extension, so it lists the earlier dates.
- UT County Technical Assistance ServiceADA Web Accessibility Rule: Implementation Guidance for County Governments (revised June 2026)
A checklist for Tennessee counties, with the current dates.
The first conversation is free.
Send the address of your site. Dustin will tell you what he sees and what it would take.