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Guide · ADA Title II

Which ADA Title II deadline applies to you? 2027 or 2028, by population

Since the April 2026 extension, there are two dates. Which one you get depends on the population of the government you belong to, and a few cases are not obvious.

Prepared by ClearLayer Access

Published · facts checked

6 min read

The short answer

Under the Department of Justice’s ADA Title II web rule, as extended by an interim final rule effective April 20, 2026:

  • Public entities with a total population of 50,000 or more must meet WCAG 2.1 Level AA by April 26, 2027.
  • Public entities under 50,000, and all special district governments, have until April 26, 2028.

The old dates of April 24, 2026 and April 26, 2027 no longer apply. You can check your own date in seconds with our free ADA Title II deadline checker.

Decision tree. Special district governments such as water, fire, park, transit or utility districts get April 26, 2028 regardless of size. Everyone else uses the population of the government they belong to: 2020 Census for states, counties and cities, SAIPE estimates for independent school districts. 50,000 or more means April 26, 2027; under 50,000 means April 26, 2028. The standard is WCAG 2.1 AA for every size.
Two questions decide your date. Source: ADA.gov small entity compliance guide and the April 2026 interim final rule.

How population is counted

According to the ADA.gov small entity compliance guide:

  • Most governments use their population from the 2020 U.S. Census.
  • A department or agency of a larger government uses the population of the government it belongs to. A city police department uses the city’s population; a county health department uses the county’s.
  • Special district governments, which the Census does not give populations, all get the later date, April 26, 2028.
  • A school district is not a special district. A city or county school district uses that city’s or county’s population. An independent school district uses the most recent Census Small Area Income and Poverty Estimates (SAIPE).

The size of your department or the number of visitors to your website does not matter. Only the population of the government you are part of counts.

Examples by entity type

Table of examples. State agency or public university: part of the state, April 26, 2027. City or county of 50,000 or more: April 26, 2027. Town, village or county under 50,000: April 26, 2028. City or county school district: uses the city or county population. Independent school district: latest SAIPE estimate. Special districts such as water, fire or transit: April 26, 2028.
Typical outcomes. Edge cases (joint authorities, regional bodies) should be confirmed with counsel.

Two cases surprise people most often. First, state agencies and public colleges are part of a state, and every state has far more than 50,000 residents, so they generally face the 2027 date even if the agency is small. Second, a library or transit system can fall on either side: if it is a department of a city or county it uses that population, but if it is legally a separate special district it gets 2028.

How to look up your number

  1. Confirm your legal form. Are you a department of a city or county, a separate special district, or a school district? Your charter or enabling law says.
  2. Find the population. For cities and counties, use the 2020 decennial Census figure on data.census.gov. For independent school districts, use the latest SAIPE school district estimate.
  3. Write it down. Record the figure, its source and the date you checked it in your accessibility plan, so the decision is documented.

What does not change

  • The standard is WCAG 2.1 Level AA for everyone, whichever date applies.
  • The scope covers web content and mobile apps you provide or make available, including PDFs, forms and video, unless an exception applies.
  • Existing duties continue. The ADA already required effective communication; people with disabilities can still ask for accessible versions and file complaints before the deadline.
  • Other rules have their own dates. Recipients of HHS funding follow a separate Section 504 web deadline: May 11, 2027 with 15 or more employees and May 10, 2028 with fewer, after HHS moved its dates back by one year (see our HHS Section 504 guide).

What to do with the time

An extra year helps only if it is used. A practical order of work:

  1. Inventory your web pages and documents (our PDF inventory guide shows how).
  2. Fix templates first: the agenda, minutes and form templates you publish every week.
  3. Prioritise documents people use to apply for or access services.
  4. Budget the backlog using per-page prices (see PDF remediation cost in 2026).

Prepared by ClearLayer Access. Published November 3, 2026; dates, rules and references checked against official sources on November 3, 2026. This guide is general information, not legal advice, and following it does not guarantee compliance or any legal outcome.

Frequently asked questions

Cities, towns and counties with a population under 50,000 must meet WCAG 2.1 Level AA by April 26, 2028, under the interim final rule effective April 20, 2026.

No. The Department of Justice extended it. Entities of 50,000 or more now have until April 26, 2027, and smaller entities and special districts until April 26, 2028.

Most governments use the 2020 U.S. Census. Departments use the population of the government they belong to. Independent school districts use the latest Census SAIPE estimate. Special districts get the later date regardless of size.

Generally no. A state agency is part of the state, and it uses the state’s population, which is above 50,000 in every state. Confirm your situation with counsel.

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