The Title II Dates Moved Again: April 2027 and 2028, and What Still Applies

The DOJ extended the Title II web accessibility deadlines by a year in April 2026. The standard is unchanged, the obligation is unchanged, and the old dates are still printed on half the internet.

Four days before the first Title II deadline, the Department of Justice moved it. On April 20, 2026, an interim final rule pushed the compliance dates for state and local government web content and mobile apps back by one year: April 26, 2027 for entities serving 50,000 or more people, and April 26, 2028 for smaller entities and special district governments. The standard did not move. It is still WCAG 2.1 Level AA.

The problem now is that half the guidance on the internet still prints the old dates, April 24, 2026 and April 26, 2027, as if they were current. A store or agency working from a plan written before April 2026 is working to a calendar that no longer exists, and a public entity that thinks it missed its deadline may not know it has another year.

What changed, and what did not

The original rule, published April 24, 2024 and effective June 24, 2024, set WCAG 2.1 Level AA as the technical standard for the web content and mobile apps that state and local governments provide or make available. The April 2026 interim final rule changed only the dates. It did not change the standard, the scope, or the underlying obligation.

That last point is the one the DOJ itself stressed. Covered entities have an ongoing obligation to make their services accessible through web content and mobile apps, whatever the compliance date. The extension is a scheduling change, not a pause, and a public entity that stops work until 2027 is misunderstanding the rule it is reading.

The dates as they stand

For public entities with a total population of 50,000 or more, the compliance date is April 26, 2027, extended from April 24, 2026. For entities under 50,000, and for special district governments regardless of population, the date is April 26, 2028, extended from April 26, 2027. Special districts, water, transit, and library districts among them, sit in the later group whatever their size.

One caveat: the extension is being challenged. In May 2026 the National Federation of the Blind sued the DOJ in federal court in Maryland, arguing the extension was issued without the required notice and comment, and asking the court to restore the original deadlines. As of October 2026 the case is pending. A ruling for the plaintiffs could make the original dates enforceable again, which is a real reason to keep working to the earlier schedule where you can.

What to do with the extra year

Treat the extension as working time, not waiting time. The work that takes longest is not the code fix, it is the content: untagged PDFs, uncaptioned videos, and form flows that were never tested with a keyboard. Start with the services people use most, the payment portal, the permit application, the meeting recordings, and work outward.

Update the plan itself. If your compliance plan, your vendor contracts, or your accessibility statement still cite April 2026, correct them now, and note the pending lawsuit so nobody is surprised if the dates move again. A plan with the wrong dates in it is worse than no plan, because it creates a false sense of urgency about the wrong deadline and none about the real one.

Related reading: Ready Means Not Asking Twice: Redundant Entry at Checkout, Title II Dates Are Set: What Public Sector Sellers Should Already Have Done, Getting a Store Ready for the European Accessibility Act: Dates, Scope, and Evidence.

Frequently asked questions

What are the current Title II compliance dates?

April 26, 2027 for public entities serving 50,000 or more people, and April 26, 2028 for smaller entities and special district governments. Both were extended by one year in the DOJ interim final rule of April 20, 2026. The technical standard remains WCAG 2.1 Level AA.

Did the extension change the accessibility standard?

No. The interim final rule changed only the dates. The standard is still WCAG 2.1 Level AA, and the DOJ was explicit that covered entities keep an ongoing obligation to provide accessible services whatever the compliance date.

Can the extended dates change again?

Possibly. The National Federation of the Blind sued in May 2026, arguing the extension was issued without proper notice and comment, and asked the court to restore the original deadlines. As of October 2026 the case is pending, so working to the earlier schedule where possible is the safer course.

Does Title II apply to private stores?

No. Title II binds state and local governments. Federal agencies are covered separately under Section 508. Private businesses face Title III, which has no technical standard written into the statute but is enforced against WCAG in practice.