Which Title II Date Applies to You: April 2027 or April 2028

The date you planned around has moved

If your Title II plan was built in 2024 or 2025, it pointed at April 24, 2026 or April 26, 2027, depending on your size. Both dates have moved. Budgets, vendor contracts, and board updates written around the old date now need a correction, and the first question is simple: which new date is yours?

The two dates

On April 20, 2026, the Department of Justice extended the Title II web and mobile app compliance dates. State and local government entities with a total population of 50,000 or more now have until April 26, 2027. Entities under 50,000, and every special district government, now have until April 26, 2028. The standard is unchanged: WCAG 2.1 Level AA. Source: the DOJ interim final rule extending the Title II compliance dates (91 FR 20902).

Smaller entities should note that April 26, 2027 was their old date. It is now the date for larger entities. If you are under 50,000 or a special district, your date is April 26, 2028.

How population is counted

The rule uses the total population of the public entity. For a city or county, that is the jurisdiction’s population. For an entity that belongs to a larger government, such as many public universities and community colleges, the relevant population may be that of the parent government. This is a legal question. Get your counsel’s reading in writing and put it in the plan.

Special districts

Every special district government is on the April 26, 2028 date, regardless of population. Water, transit, library, and park districts should check whether they are special districts under the rule.

What did not change

• The standard. WCAG 2.1 Level AA, described in the WCAG 2.1 specification from the W3C.
• Scope. Web content and mobile apps the entity provides or makes available, including through contracts.
• Exceptions. They are narrow and have conditions. Archived content and some third-party content qualify only in specific cases.

Use the time you have

For a 2027 entity, most of the work needs funding before that date, so check when your next budget cycle starts. For a 2028 entity, the extra year is useful mostly if you start now, because smaller teams have fewer people to do the fixes.

Either way, the first step is the same: a full list of the sites you are responsible for. Plans built on a partial list miss the department and program sites that carry the most risk.

Where Accorbis fits

Accorbis is a standalone web governance platform. It gives one dashboard across the WordPress, Drupal, and custom sites an organization already runs. It is not a CMS and not a hosting company.

It discovers the sites on your domains, records owner and platform, and scans them against WCAG 2.1 so you can see which ones need work first. Read more about how Accorbis works.

Three hypothetical entities

A large county

Imagine a county well above 50,000 residents. Its date is April 26, 2027. Its departments, courts, and elected offices all publish online, and some run separate sites. It needs funding for most of the work in place well before that date.

A small town

Now imagine a town under 50,000 residents. Its date is April 26, 2028. It has one main site and a few vendor portals. The extra year helps, but its team is small, so starting now matters more, not less.

A transit district

Finally, imagine a regional transit authority organized as a special district. Its date is April 26, 2028 regardless of how many riders it serves, because every special district government is on the later date. Counsel should confirm its status under the rule.

A checklist for confirming your date

• Identify the legal entity that publishes your sites.
• Ask counsel whether it is a state or local government entity, an instrumentality of one, or a special district.
• Confirm which population figure applies.
• Get the answer in writing.
• Update plans, budgets, vendor timelines, and anything you told leadership.
• Correct any public page that still shows an old date.

Do not let the date decide the order of work

Whatever your date, the sequence is the same: inventory, triage, remediation, then ongoing review. The date only decides how much time you have to do it.

What to do this month

Confirm the date, correct any page that shows the old one, and start the inventory. Those three steps cost little and make every later decision easier to defend.

Frequently asked questions

Does the new rule apply to private universities?

Title II covers state and local government entities. Private institutions have obligations under other laws. Ask counsel.

Can we still use the old April 2026 plan?

The work is the same. Update the dates, the budget timing, and anything you told leadership or vendors.

Is WCAG 2.2 now required?

No. The rule names WCAG 2.1 Level AA. Building to 2.2 is a choice some teams make.

Could the dates move again?

Any rule can change. Plan to the published dates and watch the Federal Register.

What should we tell vendors whose contracts mention the old date?

Share the new date in writing and confirm their delivery plan still fits. Keep accessibility requirements in the contract unchanged.

Do we need to update public pages that mention the old date?

Yes. Pages showing April 2026, or April 2027 for smaller entities, as the current deadline are now wrong, and answer engines may repeat them.

Where can we read the rule itself?

The interim final rule is published in the Federal Register, linked above.

Does the later date mean smaller entities can wait?

The date is later, but smaller teams usually have fewer people to do the work. Starting the inventory now keeps the extra year useful.

Next step

Schedule a 30-minute working session to see your estate and which sites need attention first.