The ADA Title II Compliance Timeline: April 2027, April 2028, and What Can Still Move

This page is a maintained reference. Dates and case status below were last verified against primary sources on July 26, 2026. When a court ruling, a final rule, or a new extension changes the timeline, this page changes with it.

If you build, maintain, or deliver digital services to state and local governments, there is no single more useful thing to have pinned than an accurate picture of the compliance calendar. Not the headline version — the actual one: which dates are in force, which regulation each one comes from, which are being litigated, and which never moved no matter what the federal agencies did.

That picture currently has three layers: the federal Title II dates (moved, once, by a year), the parallel Section 504 dates for federally funded health programs (moved in lockstep), and the state and procurement clocks (did not move, and in several states now run ahead of the federal ones). A lawsuit pending in federal court could compress all of it again.

Here is the whole timeline, layer by layer.

The dates as they stand

| Who | Deadline | Standard | Source | |---|---|---|---| | Public entities, population ≥ 50,000 | April 26, 2027 | WCAG 2.1 Level AA | 28 CFR 35.200, as amended by the DOJ IFR (91 FR 20902) | | Public entities < 50,000 and special districts | April 26, 2028 | WCAG 2.1 Level AA | Same | | HHS-funding recipients, 15+ employees | May 11, 2027 | WCAG 2.1 Level AA | 45 CFR Part 84, as amended by the HHS IFR | | HHS-funding recipients, < 15 employees | May 10, 2028 | WCAG 2.1 Level AA | Same | | Virginia covered entities | April 24, 2026 / April 26, 2027 (the original federal dates, written into state law) | Per HB 2541 | Virginia HB 2541 (2025) |

Three things to read out of that table before anything else:

• The technical standard never moved. Every row is WCAG 2.1 Level AA. The DOJ's extension changed two dates in 28 CFR 35.200(b) and nothing else — not the scope, not the exceptions, not the standard. The work your deliverable has to meet is identical to what it was before the extension.
• The clocks are staggered by entity size, not by contractor size. Your obligation arrives through your client's deadline, via the procurement, warranty, and flow-down language in your contract. A five-person studio delivering to a county of 300,000 is working against April 2027.
• The earliest binding date in the table is a state one that already passed. Virginia wrote the original federal dates into its own statute, and the federal extension did not touch them. If you sell into the states with their own digital-accessibility laws, the federal timeline is not your binding timeline — the state-law map is the companion reference.

How we got here

The current dates are the product of two rulemakings and one extension. The chronology matters, because the pending litigation turns on it.

• April 24, 2024 — DOJ publishes the Title II web accessibility final rule (89 FR 31320), adopting WCAG 2.1 Level AA as the technical standard for state and local government web content and mobile apps, with compliance dates of April 24, 2026 (≥ 50,000 population) and April 26, 2027 (smaller entities and special districts).
• May 9, 2024 — HHS finalizes the parallel Section 504 rule for recipients of federal financial assistance (89 FR 40066), with compliance dates of May 11, 2026 (15+ employees) and May 10, 2027 (fewer than 15).
• April 20, 2026 — four days before the first Title II deadline, DOJ publishes an Interim Final Rule (91 FR 20902) extending both dates by one year, to April 26, 2027 and April 26, 2028. The IFR is effective immediately; DOJ states it fully anticipates implementing the rule at the new deadlines.
• May 7–11, 2026 — HHS follows with its own Interim Final Rule extending the Section 504 web dates by a year, to May 11, 2027 and May 10, 2028.
• May 21, 2026 — the National Federation of the Blind files suit in the U.S. District Court for the District of Maryland challenging both interim final rules under the Administrative Procedure Act.
• June 22, 2026 — the DOJ IFR's public comment period closes. We covered what that window did and didn't decide in the comment-period close-out.
• July 6, 2026 — the HHS IFR's comment period closes.
• Today — both extensions are in force. The lawsuit is pending. No further rulemaking has published.

What could still move the dates

Two mechanisms could change the table above, and it is worth being precise about each — because "the deadline might move again" is doing a lot of unearned work in how some vendors are talking to municipal clients right now.

The NFB lawsuit could pull the dates back

The National Federation of the Blind's suit argues that DOJ and HHS issued the extensions without the notice-and-comment process the APA requires, and that the extensions were arbitrary and capricious. The relief requested is not symbolic: NFB asks the court to vacate both interim final rules entirely and order the agencies to enforce the original 2024 deadlines — which, for large entities, have already passed.

As of this page's last verification, no ruling has issued. We are not going to predict one. But the planning implication doesn't require a prediction: a contractor whose remediation plan only works if April 2027 holds has built a plan with a single point of failure that is currently in front of a federal judge. The defensible posture — dated documentation of where each deliverable stands, produced continuously rather than in a sprint at the deadline — works under every outcome of the case.

The agencies could finalize, adjust, or extend again

An interim final rule is in force, but it is not the end of the process. Both agencies took comments through the summer, and both retain the ability to finalize the extensions as-is, adjust them, or open new rulemaking. DOJ signaled in the IFR's preamble that it anticipates implementing the rule at the new dates — that is the strongest official statement on record, and it is a statement of intent, not a guarantee.

What we have not seen, and will update this page immediately if we do: a stay of the current dates, a further extension, or a proposed rule revisiting the 2024 rule's substance.

What does not move, no matter what happens to the federal dates

This is the section to internalize if you only keep one. The federal conformance dates are the most movable layer of the stack. Everything under them has been stable throughout:

• The underlying ADA obligation. Title II's prohibition on disability discrimination has been in force since 1990 and applies to digital services today. The conformance date sets when WCAG 2.1 AA becomes the measurable regulatory standard — it does not create the obligation, and its extension does not suspend it. We walked through what enforcement looks like in that gap in Title II after the deadline.
• Private litigation. Title II carries a private right of action with fee-shifting. Demand letters and complaints did not pause for the IFR, and a client whose portal blocks a screen-reader user is exposed now, not in April 2027.
• State law. Virginia, Colorado, Minnesota, Washington, Massachusetts, California — the state clocks run on their own statutes, several of them ahead of the federal dates, some with per-violation damages. The federal extension changed none of them.
• Procurement gates. This is the layer that actually schedules a contractor's work. RFPs asking for accessibility documentation, VPATs/ACRs, contract warranties, and flow-down clauses were spreading before the 2024 rule and have kept spreading through the extension. The procurement officer reviewing your bid next month is not waiting for 2027 — the documentation request is already in the solicitation.

The parallel Section 504 clock

If any of your government clients run on federal health dollars — county hospitals, public health departments, community health centers, Medicaid-funded programs — they are on two federal clocks: Title II because they are public entities, and Section 504 because they take HHS funding. Both moved by a year in spring 2026, and both are challenged in the same NFB suit. The 504 dates land two weeks after the Title II dates in each tier (May 11, 2027 for recipients with 15+ employees; May 10, 2028 below that), and the employee-count threshold means a small clinic and a county hospital can sit in different tiers. The health-program specifics — including what a Business Associate-style accessibility clause in a health-system contract does to your delivery timeline — are in the Section 504 deadline guide.

What to do with this timeline

The honest planning read of everything above: the federal dates are the ceiling, not the schedule. Procurement language, state law, and litigation exposure all arrive earlier, and the one scenario that would change the federal dates changes them backward. So the pre-deadline playbook doesn't depend on which April ultimately holds:

• Inventory what you're on the hook for. Every active municipal deliverable, its contract status, and whether the contract carries accessibility, warranty, or indemnification language. You cannot document a posture you haven't mapped.
• Baseline every deliverable with a dated scan. An automated structural scan against WCAG 2.1 A/AA catches a meaningful portion of issues — roughly 57% by volume per Deque's research, which is exactly why it's a baseline and not a conformance claim. What matters for defense is that the result is dated, repeatable, and states its own methodology and limits.
• Keep the record continuously, not at the deadline. A remediation timeline built from independently dated scans and a maintained log is what procurement officers and counsel can actually use — and it is precisely the artifact a deadline-sprint approach never produces. That record is the whole design brief behind the audit defense log in the Contractor's Defense Bundle; how to build one works whether you use our tooling or your own.
• Re-check this page when the case moves. The single likeliest change to this timeline is a ruling in Maryland. When it comes, the dates table above gets updated the same week.

Quick answers

• Is the ADA Title II deadline still happening? Yes — April 26, 2027 and April 26, 2028, unless the NFB suit or further rulemaking changes them. The full question-by-question treatment is in the 2026 FAQ.
• Did the standard change? No. WCAG 2.1 Level AA, unchanged since the 2024 rule.
• Does the extension pause lawsuits or state law? No and no. Both layers run independently of the federal conformance dates.
• What should be true of my deliverables today? A dated, documented accessibility posture you can hand to a procurement officer or counsel on request — regardless of which federal date survives.

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This post is for informational purposes only and does not constitute legal advice. Consult with qualified legal counsel for guidance specific to your situation.