April 2026 Federal Deadline: What You Need to Know

What the Rule Says

On April 8, 2024, the Department of Justice published its final rule under Title II of the Americans with Disabilities Act, establishing specific technical standards for web content and mobile application accessibility for state and local government entities. The rule designates WCAG 2.1 Level AA as the required technical standard.

This is not guidance. It is not a recommendation. It is a legally binding federal regulation published in the Federal Register that carries the full force of law. After years of relying on case law and informal guidance to establish web accessibility standards, the DOJ has codified specific, measurable, enforceable requirements.

The rule applies to all web content and mobile applications of state and local government entities, covering everything from city websites and county portals to state agency applications, public university systems, school district platforms, and any other digital service provided by Title II entities.

The significance extends far beyond the government sector. By establishing WCAG 2.1 AA as the federal government's official accessibility standard, the DOJ has created a definitive benchmark that courts will reference when evaluating accessibility claims against private businesses under Title III.

Who It Directly Applies To

The rule applies to all state and local government entities covered by Title II of the ADA. This includes:

State government entities:

• State agencies and departments
• State courts
• State universities and colleges
• State licensing boards
• State parks and recreation

Local government entities:

• Cities and municipalities
• Counties
• School districts (K-12)
• Public libraries
• Transit authorities
• Water and utility districts
• Special districts

Compliance timeline by entity size:

• Entities serving populations of 50,000 or more: April 24, 2026
• Entities serving populations under 50,000: April 26, 2027

Every digital touchpoint these entities provide to the public must meet WCAG 2.1 Level AA. Websites, mobile applications, web-based portals, online forms, document repositories, and any other digital content offered to the public are covered.

Why Every Business Should Care

The rule directly applies to government entities, but its impact on the private sector is substantial and immediate. Here is why every business should treat this deadline with urgency:

It establishes the legal standard. When the federal government codifies WCAG 2.1 AA as the definitive accessibility standard, courts evaluating private-sector ADA cases will reference this standard. Defendants arguing for a lower standard now face an even steeper burden.

It increases plaintiff confidence. Plaintiffs' attorneys will cite the federal standard in demand letters and complaints against private businesses. The argument is straightforward: if the government has determined that WCAG 2.1 AA is the appropriate standard for government websites, the same standard should apply to commercial websites that serve the public.

It accelerates state legislation. California, New York, Colorado, and other states have been advancing their own digital accessibility legislation. The federal rule provides a template and a precedent that states will build upon, potentially with more aggressive requirements and enforcement mechanisms.

It signals enforcement direction. The DOJ's investment in codifying web accessibility standards signals that digital accessibility enforcement is a long-term priority. Private-sector enforcement actions and guidance are likely to follow.

Vendor and procurement effects. Government entities will require their vendors and contractors to meet WCAG 2.1 AA standards. Any business that sells products or services to government entities will need to demonstrate compliance or lose access to government contracts.

Technical Requirements

The rule requires compliance with WCAG 2.1 Level AA, which encompasses 50 success criteria across four principles. Key technical requirements include:

Perceivable content:

• All images have descriptive alt text
• Videos have captions and audio descriptions
• Content adapts to different presentations without losing information
• Text has sufficient color contrast (4.5:1 minimum)
• Content reflows at 320px width without horizontal scrolling

Operable interfaces:

• All functionality accessible via keyboard
• No keyboard traps
• Users have enough time to interact with content
• Content does not cause seizures
• Pages have descriptive titles and logical heading structure
• Focus is visible on interactive elements

Understandable content:

• Page language is declared
• Navigation is consistent across pages
• Form errors are identified with suggestions
• Legal and financial transactions can be reviewed and corrected

Robust markup:

• HTML uses proper semantics
• Custom widgets have accessible names and roles
• Status messages are announced to assistive technology

The standard is the same WCAG 2.1 AA that has been referenced in court rulings, DOJ settlements, and industry guidance for years. What changes is the codification in federal regulation.

Key Dates and Timeline

Already passed:

• April 8, 2024: Final rule published in Federal Register
• June 24, 2024: Final rule effective date (published)
• Throughout 2024-2025: Preparation period

Approaching:

• April 24, 2026: Compliance deadline for large entities (50,000+ population). This is 68 days away.
• April 26, 2027: Compliance deadline for small entities (under 50,000 population)

Ongoing:

• DOJ enforcement actions against non-compliant entities
• Private litigation referencing the federal standard
• State-level legislation building on the federal framework

For businesses, April 24, 2026 should be treated as a de facto deadline regardless of whether you are a government entity. The standard it establishes will influence every ADA website case filed after that date.

Enforcement Mechanisms

The DOJ has several enforcement mechanisms available:

Direct enforcement: The DOJ can investigate complaints, conduct compliance reviews, and initiate enforcement actions against non-compliant entities. Enforcement can result in consent decrees requiring specific remediation steps, monetary penalties, and ongoing federal monitoring.

Private right of action: Individuals can file private lawsuits against non-compliant entities under Title II. Successful plaintiffs can obtain injunctive relief (court orders requiring compliance) and attorney's fees.

Administrative complaints: Individuals can file administrative complaints with the DOJ, which can trigger investigations and enforcement actions without the individual filing a lawsuit.

Funding implications: For entities receiving federal financial assistance, non-compliance can result in referral to federal funding agencies for potential funding termination under Section 504 of the Rehabilitation Act.

Penalties: While Title II does not provide for compensatory damages in all cases, DOJ enforcement can result in civil penalties of up to $55,000 for a first violation and $110,000 for subsequent violations. State-level enforcement may carry additional penalties.

Exceptions and Limitations

The rule includes several narrow exceptions:

Archived web content: Content that was created before the compliance date, is maintained exclusively for reference or recordkeeping, and is not altered after the compliance date is exempt. However, if archived content is still actively used by or relied upon by the public, it must comply.

Pre-existing conventional electronic documents: Documents such as PDFs that were posted before the compliance date are exempt if they are not currently used to access a government service or activity. Documents still in active use must be remediated.

Third-party content: Content that is posted by third parties on a government platform (for example, public comments on a government social media page) is generally not covered unless the government entity exercises editorial control.

Undue burden defense: An entity may claim that compliance would impose an undue burden (significant difficulty or expense), but this defense requires documented evidence and the entity must still comply to the maximum extent feasible.

These exceptions are narrow by design. The DOJ's intent is comprehensive compliance, and entities should not plan around exceptions. Any content that citizens use, need, or rely upon must be accessible.

Preparation Checklist

With 68 days until the deadline, here is what every organization should do now:

Immediate (this week):

• [ ] Run an automated accessibility scan on your entire digital presence
• [ ] Identify and catalog all web properties, portals, and applications
• [ ] Review any third-party platforms integrated with your services

Short-term (next 2 weeks):

• [ ] Prioritize violations by severity and citizen impact
• [ ] Begin remediation of critical issues (forms, navigation, high-traffic pages)
• [ ] Establish accessibility testing in development workflows

Medium-term (next 4 weeks):

• [ ] Remediate all high-severity violations on citizen-facing services
• [ ] Convert inaccessible PDF documents to accessible formats
• [ ] Test with assistive technology (screen readers, keyboard navigation)

Before the deadline:

• [ ] Achieve WCAG 2.1 AA compliance on all public-facing digital content
• [ ] Establish ongoing monitoring for compliance maintenance
• [ ] Document compliance efforts and testing results
• [ ] Train content teams on accessibility requirements

The Cost of Waiting

Every day of delay increases your risk and reduces your options.

Before the deadline: You control the timeline, budget, and approach. Proactive compliance is planned, systematic, and cost-effective.

After the deadline: You are reacting to enforcement actions, complaints, and lawsuits. Reactive remediation is rushed, expensive, and conducted under legal pressure. Court-ordered remediation typically costs 2-5x more than proactive compliance.

The numbers: AdaScanPro monitoring at $297/month costs $3,564 per year. The average ADA settlement costs $35,000. One settlement equals nearly 10 years of proactive monitoring. The math supports immediate action.

Scan your website free right now. In 60 seconds, you will know exactly where you stand relative to WCAG 2.1 AA and what needs to be fixed before April 24, 2026.