ADA Title II now sets clear expectations for how state and local governments must make their digital services accessible. With public services increasingly delivered through websites and mobile apps, accessibility is no longer optional or unclear.
This guide explains what ADA Title II requires, who must comply, what content is covered, and how to achieve compliance using a practical, step-by-step approach. It is designed to help public entities understand the new requirements and take meaningful action.
What Is ADA Title II?
ADA Title II is a part of the Americans with Disabilities Act that applies to state and local governments. It requires public entities to make sure people with disabilities have equal access to their services, programs, and activities.
In today’s context, many government services, programs, and activities are delivered online. Because of this, ADA Title II requires that these digital services be accessible as well. This includes websites, online systems, and mobile apps used to provide public services.
What Changed in ADA Title II?
Short answer: The rule did not add new requirements; it clearly defined WCAG 2.1 Level AA as the standard for ADA Title II website and mobile app compliance.
Long answer: The 2024 update did not create any brand new accessibility obligation. What changed is that the Department of Justice (DOJ) removed long-standing uncertainty by clearly defining how accessibility must be achieved for websites and mobile apps.
Earlier, ADA Title II did not name a specific technical standard for website or mobile app accessibility. While WCAG 2.1 Level AA was widely treated as the benchmark, it was never written into the regulation. This lack of clarity caused confusion and inconsistent compliance.
The 2024 update closes this gap.
WCAG 2.1 Level AA is now the official technical standard under ADA Title II. This removes ambiguity and sets a clear, testable requirement. Public entities now have a clear standard to meet for ADA Title II compliance.
Who Must Comply With ADA Title II?
ADA Title II applies to all state and local governments. This includes agencies, departments, and any government body that provides services, programs, or activities to the public, as well as special-purpose districts and public commuter authorities such as Amtrak.
This responsibility does not end when services are delivered by another organization. When a state or local government contracts with a third party to provide public services, the government remains responsible for ensuring those services meet ADA Title II requirements.
Entities that must comply include:
- State and local government offices that provide benefits or social services, such as food assistance, health insurance, or employment services
- Public schools, community colleges, and public universities
- State and local police departments
- State and local courts
- State and local elections offices
- Public hospitals and public healthcare clinics
- Public parks and recreation programs
- Public libraries
- Public transit agencies
In simple terms, if an organization is part of a state or local government or provides public services on its behalf, ADA Title II applies. If those services are offered through websites or mobile apps, they must be accessible.
ADA Title II Compliance Deadlines
ADA Title II compliance deadlines are based on the population size of the state or local government. Larger entities must comply sooner because their digital services affect more people. The compliance deadlines are as follows:
- State and local governments serving 50,000 or more people: April 24, 2026
- State and local governments serving fewer than 50,000 people: April 26, 2027
- Special purpose districts: April 26, 2027
After this time, state and local governments must continue to make sure their web content and mobile apps meet WCAG 2.1, Level AA.
Web Accessibility Requirements Under ADA Title II
Under ADA Title II, state and local government websites must meet WCAG 2.1 Level AA.
These requirements apply to all web content a public entity provides or makes available to the public. This includes pages, forms, media, documents, and embedded content such as social media posts used to deliver information or services online.
Third-party content and tools are also covered under ADA Title II.
When a public entity relies on external platforms or vendors to deliver services or functionality through its website, the accessibility requirement does not change. These third-party features are treated as part of the website and must meet the same accessibility standards.
Examples include:
- Payment or billing systems run by an external provider
- Scheduling or booking tools from a vendor
- Licensing or permit portals built by a contractor
- Embedded maps or search tools
- Social media embeds
- Chat or support widgets
This means accessibility should be checked before selecting or deploying a vendor tool. Governments should confirm that third-party platforms, widgets, and services can conform to WCAG 2.1 Level AA and do not introduce accessibility barriers.
Accessibility for Schools and Colleges
Public schools, colleges, and universities must also meet these web accessibility requirements. Study materials shared online are considered web content under ADA Title II.
This includes:
- Lecture slides and PPT files
- PDFs, Word documents, and spreadsheets
- Course outlines and reading materials
- Learning portals and downloadable resources
If students rely on these materials to learn or participate in a course, they must be accessible. This applies whether the content is hosted on the institution’s website or delivered through third-party learning platforms.
ADA Title II Accessibility Exceptions
ADA Title II includes five exceptions. These exceptions apply only in specific situations and are intended to reduce undue burden, allowing state and local governments to focus resources on the most important and widely used content.
The five exceptions are:
- Archived web content that is kept only for reference, research, or recordkeeping and has not been changed since it was archived.
- Preexisting conventional electronic documents, such as PDFs or Word files, unless they are currently used to apply for, access, or participate in a public service.
- Content posted by a third party, when the third party is not posting due to a contractual, licensing, or similar arrangement with the public entity
- Password-protected, individualized documents that relate to a specific person, property, or account.
- Preexisting social media posts published before the compliance date.
Content that falls under these five exceptions does not need to conform to WCAG 2.1 Level AA by default. However, if a person with a disability requests access to exempt content, the public entity may still need to provide that content in an accessible format.
How to Achieve ADA Title II Compliance
Achieving ADA Title II compliance requires a structured approach that covers both web and mobile accessibility. Because public services are delivered through many types of digital content, accessibility efforts must address websites, mobile apps, documents, media, and third-party tools.
The steps below outline a practical way for public entities to meet requirements and maintain accessibility over time.
Step 1: Identify all covered digital services
Start by listing every website, web system, and mobile app used to deliver public services. This includes main websites, sub-sites, portals, and third-party tools. If the public relies on it to access information or complete a task, it is covered.
Step 2: Audit all web and mobile content
Conduct accessibility audits across all websites, mobile apps, and digital content. This includes web pages, landing pages, online forms, service portals, images, videos, PDFs and other documents, interactive tools or widgets, and all mobile app screens and features.
- Website testing: Use WebYes Accessibility to scan for WCAG 2.1 Level AA issues.
- Mobile app testing: Use Android Accessibility Scanner and Xcode Accessibility Inspector.
For auditing content such as PDFs, see our article on web accessibility testing tools.
Step 3: Ensure third-party tools are accessible
Review third-party platforms and vendor tools used on websites or in mobile apps. Accessibility obligations remain with the public entity, so vendors should be evaluated and held to WCAG 2.1 Level AA requirements.
Step 4: Prioritize high-impact content
Focus first on the content that people rely on most to access public services. This includes application forms, payment and billing content, scheduling information, permits, and critical public information. Addressing high-impact content early improves access and reduces compliance risk.
Step 5: Fix accessibility issues at the source
Remediate issues using WCAG 2.1 Level AA guidelines. This may involve improving keyboard access, adding text alternatives, fixing color contrast, ensuring accessible forms, and making media usable with assistive technologies. Fix code, design, and content issues.
Step 6: Verify accessibility fixes
After remediation, verify that accessibility issues have been properly resolved. Test updated content using keyboards, screen readers, and other assistive technologies to confirm that people can access information and complete tasks independently.
Verification helps ensure fixes work in real-world use and meet WCAG 2.1 Level AA requirements. User testing with people who rely on assistive technologies provides additional assurance that accessibility improvements work as intended in real-world scenarios.
Step 7: Publish an accessibility statement
An accessibility statement helps communicate your commitment to ADA Title II compliance. It should explain that you are working to meet WCAG 2.1 Level AA, outline known limitations, if any, and provide a clear way for users to report accessibility issues or request accessible alternatives.
Step 8: Maintain accessibility over time
Accessibility is not a one-time task.
Public entities should build accessibility checks into content updates, website changes, mobile app releases, and vendor onboarding. Ongoing testing and monitoring help ensure new content and features continue to meet WCAG 2.1 Level AA and do not introduce new barriers.
Wrapping Up
ADA Title II compliance is about ensuring equal access to public services in today’s digital-first world. With clear requirements now in place for websites and mobile apps, state and local governments have a defined path forward using WCAG 2.1 Level AA as the standard.
By following the steps outlined in this article, auditing all web and mobile content, prioritizing high-impact areas, fixing accessibility issues, verifying improvements, and maintaining accessibility over time, public entities can move toward ADA Title II compliance with clarity and confidence.
AUTHOR
Melwyn holds a Bachelor's degree in Computer Science and has been writing professionally for over 4 years. He has a strong background in SEO and is certified in web accessibility from the World Wide Web Consortium (W3C). When he's not writing about website optimisation, you can find him enjoying a game of FIFA or exploring the open world of GTA.
Melwyn Joseph 
