The April 2026 WCAG Deadline —
What Every Municipality Must Do

On April 24, 2024, the Department of Justice published its final rule on web and mobile accessibility under Title II of the ADA. That rule sets a hard compliance deadline: April 24, 2026 for state and local governments with populations of 50,000 or more, and April 24, 2027 for smaller entities.

This isn't a suggestion. It's a federal regulation with enforcement teeth. And most municipalities are not ready. For a plain-English breakdown of what counsel should brief the town manager on, see our complete ADA compliance guide.

What the Rule Requires

The final rule (28 CFR Part 35, Subpart H) requires all web content and mobile applications of state and local governments to conform to WCAG 2.1, Level AA. That includes:

• All public-facing web content — websites, portals, PDF forms, online services
• Mobile applications — any app provided by or on behalf of the government entity
• Third-party content — embedded widgets, payment processors, scheduling tools that live on government sites
• Archived content — if it's linked from the current site, it's in scope (with limited exceptions)

The Timeline

What Most Municipalities Get Wrong

1. "Our website is ADA compliant because we added an overlay widget"

Overlay widgets (AccessiBe, UserWay, etc.) do not make a site WCAG compliant. The DOJ has explicitly rejected overlay-based remediation in consent decrees. The final rule requires conformance at the code level, not a JavaScript patch on top of broken HTML.

2. "We only need to worry about the website"

The rule covers all digital services offered by or on behalf of the entity. That includes online permitting, utility payments, meeting agendas, police reports, court filings, park reservations — anything accessible through web or mobile.

3. "We'll handle it when we get a complaint"

The compliance deadline is absolute. The DOJ doesn't need a complaint to investigate. And once a complaint is filed, the conversation starts at settlement, not at "let us fix it."

4. "This only applies to the website, not in-person services"

Wrong on two counts. First, the rule explicitly covers web and mobile. Second, the existing ADA effective communication requirement (28 CFR § 35.160) already covers in-person services — and has since 1991. The new rule adds digital; it doesn't replace physical. You need both.

What "WCAG 2.1 AA" Actually Means

WCAG 2.1 Level AA has 50 success criteria organized under four principles:

• Perceivable — Text alternatives for images, captions for video, sufficient color contrast, resizable text
• Operable — Full keyboard navigation, no time traps, no seizure-triggering content, clear page structure
• Understandable — Readable text, predictable navigation, input assistance for forms
• Robust — Compatible with assistive technology, valid HTML, proper ARIA attributes

Meeting all 50 criteria across every page of a government website is a significant technical undertaking. It requires audit, remediation, testing with actual assistive technology, and ongoing monitoring.

The Effective Communication Gap

Here's what the WCAG deadline doesn't cover: the person who walks into your building and can't speak. The deaf resident at a town meeting. The stroke survivor at a permitting counter. The non-English speaker trying to pay a water bill.

WCAG addresses digital accessibility. 28 CFR § 35.160 addresses communication accessibility — the requirement to provide auxiliary aids and services for effective communication with people who have disabilities. For a deeper look at the regulation, see our blog post on Title II effective communication and the specific rules covering QR communication boards under 28 CFR.

Both are ADA obligations. Both are enforceable. And most municipalities are failing at both. Town IT leads coordinating deployments across CT should review the state partnerships page for rollout context.

What to Do Before April 24, 2026

1. Audit your website against WCAG 2.1 AA using automated tools (axe, WAVE) and manual testing with screen readers
2. Remediate the highest-impact issues first: missing alt text, form labels, keyboard navigation, color contrast
3. Fix your PDFs — most government PDFs are completely inaccessible. Tagged PDFs or HTML alternatives are required
4. Audit third-party tools — if your payment processor or scheduling widget isn't accessible, you're liable
5. Document everything — your accessibility statement, remediation timeline, and ongoing monitoring process
6. Deploy an in-person communication aid — the WCAG deadline doesn't replace 28 CFR § 35.160. Cover both.