This article summarizes technical requirements published by the U.S. Department of Justice. It is not legal advice. Government entities should review the rule and coordinate legal, policy, procurement, content, and technical responsibilities.
Who has the April 26, 2028 date?
As of August 26, 2026, the Department of Justice's interim final rule gives public entities with a total population under 50,000, other than special district governments, until April 26, 2028. Special district governments use the same date. The interim rule also moved the date for entities with populations of 50,000 or more to April 26, 2027. Because this is a live rulemaking, readers should confirm the current dates with the Department of Justice.
What is the technical standard?
The rule generally requires covered web content and mobile apps that state or local governments provide or make available, directly or through contractual or other arrangements, to conform to WCAG 2.1 Level AA.
The work is broader than the public homepage
- Public service information, forms, meeting materials, notices, and online payment or application workflows.
- Mobile applications offered by the public entity.
- Content or services provided through a contractor where the rule applies.
- Documents and files that do not fall within a specific exception.
- Authenticated experiences used for public programs or services.
The rule contains specific exceptions
The final rule describes exceptions for certain archived web content, some preexisting conventional electronic documents, content posted by third parties, individualized password-protected documents, and preexisting social media posts. Each exception has conditions. An exception should be evaluated against the rule rather than assumed from a file's age or location.
Conforming alternate versions are limited
The rule limits reliance on a separate conforming alternate version. The Department explains that a public entity may use one only when making the content directly accessible is not possible because of technical or legal limitations.
A practical preparation sequence
- Assign an accountable owner and include legal and procurement stakeholders.
- Inventory websites, mobile apps, third-party platforms, documents, and high-value public tasks.
- Identify shared templates and systems where one remediation can improve many pages.
- Test representative content and workflows against WCAG 2.1 Level AA using automated and hands-on methods.
- Prioritize blockers in essential services while planning broader remediation.
- Add accessibility requirements to procurement, publishing, and release workflows.
- Retest after changes and monitor new content through the compliance date and beyond.
Why waiting for a final scan is risky
An inventory may reveal thousands of documents, multiple vendors, and repeated component problems. Procurement and remediation can take longer than testing. Starting with ownership and scope gives the entity time to make deliberate decisions rather than treating accessibility as a last-minute report.
The deadline is a compliance date, not a sensible project start date. Inventory, procurement, remediation, and retesting all take time.
