Extension of Compliance Deadlines for State and Local Government Entities:

Implementing Title II of the Americans with Disabilities Act regarding Requirements for Web Content and Mobile Application Accessibility

On April 24, 2024, the Department of Justice (the “Department”) published a final rule (the “Rule”) titled “Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities.” The Rule updated the Department’s regulations pertaining to Title II of the Americans with Disabilities Act (the “ADA”). Title II of the ADA requires state and local government entities to ensure that their services, programs, and activities are accessible to people with disabilities. The Rule contains specific requirements about how government entities must ensure that their web content and mobile applications (apps) are accessible to people with disabilities. The Rule established initial compliance deadlines of April 26, 2026 for government entities with a total population of 50,000 or more and April 26, 2027 for government entities with a total population of less than 50,000.

Government entities regularly use the web and mobile apps to offer services, programs, or activities to the public. For example, members of the public routinely renew vehicle registrations, submit complaints, purchase event permits, reserve public facilities, and pay traffic fines through a government entity’s website or mobile app. The purpose of the Rule is to ensure that people with disabilities have access to the services, programs, and activities of government entities that are available on websites and mobile apps.

On April 20, 2026, the Department published an Interim Final Rule (“IFR”) extending the compliance deadlines set forth in the Rule in recognition of the challenges facing government entities, including resource constraints, staffing limitations, and slow technological advancement. The new compliance deadline for government entities with a total population of 50,000 or more is April 26, 2027, and the new compliance deadline for government entities with a total population of less than 50,000 is April 26, 2028. For questions regarding the ADA compliance deadlines for state and local government entities, please contact a Municipal attorney at Appel Yost.

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