Before you read a single requirement, try three things on your own government website. They take about five minutes total, and they will tell you more about where you stand than any memo.

First, open the page residents use most, paying a bill, reserving a park shelter, finding meeting times, put your mouse away, and try to complete the task using only the Tab, Enter, and arrow keys. Second, open the most recent agenda or notice PDF on your site and press Ctrl+A: if the text will not highlight, that document is invisible to a screen reader. Third, write down one date: April 26, 2027 if your community has 50,000 or more people, April 26, 2028 if it has fewer or if you are a special district.

How did the first two go? If either one made you wince, you are in good company, and in the right place. This ADA Title II compliance checklist walks through everything the Department of Justice’s web accessibility rule requires of cities, counties, towns, school districts, and special districts, in plain English and in the order that actually makes sense to work through it.

The short version of the rule

Title II of the ADA has always required state and local governments to make their programs and services accessible to people with disabilities. In April 2024, the DOJ finalized a rule that spells out what that means online: your web content, mobile apps, and electronic documents must meet WCAG 2.1 Level AA, a specific and testable accessibility standard, think of it as a building code for the web. The deadlines above are when full compliance is required, but the underlying obligation to serve residents with disabilities applies right now.

The Title II compliance checklist, section by section

1. Know your deadline and your scope

Your deadline depends on population: April 26, 2027 for governments serving 50,000 or more people, and April 26, 2028 for smaller communities and for special districts of every size, water districts, fire districts, transit authorities, library districts, all of it.

Then take inventory, because the rule covers more than your main website. List every department microsite, the utility payment portal, the recreation signup system, the mobile app, the meeting video archive, and yes, the thousands of PDFs. You cannot plan a route until you know the size of the map, and most governments are surprised by what they find in this step.

2. Your website

The heart of the requirement. In practical terms, WCAG 2.1 AA means:

• • Everything works by keyboard alone. Menus, forms, search, payments — no task can require a mouse, because many residents cannot use one.
  • Text stands out from its background. Color contrast is a measurable ratio, and pale gray text on white fails it.
  • Images have meaningful alt text. A photo of the new fire station needs a description; a decorative flourish should be marked so screen readers skip it.
  • Videos have captions. Council meetings, public service announcements, recorded hearings — captioned, with transcripts where audio matters.
  • Forms can actually be completed. Clear labels, understandable error messages, and no time-outs that cut people off mid-application.

Automated scanners catch some of this; the barriers that generate complaints usually need human testing to find. Our guide to website accessibility audit costs explains what a proper audit involves and what to budget.

3. Your documents

This is the part that catches governments off guard: the rule explicitly covers documents, not just web pages. Every PDF a resident needs, permit applications, tax forms, agendas, notices, budgets, has to meet the same standard. A scanned paper form is a photograph of text and fails completely.

Work the documents in priority order: forms and notices people need to access services first, high-download documents second, and set up your staff so every new document is created accessible from day one, that stops the backlog from growing while you fix the old one. We cover the document side in detail in our guide to Title II PDF requirements.

4. Third-party tools

Here is a sentence worth reading twice: if a vendor provides it on your behalf, it is your responsibility. The payment portal, the agenda management platform, the recreation registration system, the emergency notification signup, if residents use it to interact with your government, the rule applies, even though you did not build it.

Two practical moves. Ask every current vendor for their accessibility documentation and a demonstration, not just a claim. And add accessibility requirements to every new contract and RFP, so the next procurement cycle works for you instead of against you.

5. The exceptions, honestly

Yes, the rule has exceptions. No, they are probably not as generous as you have heard. The main ones:

• • • Archived content — but only if it is kept purely for reference, stored in a dedicated archive area, and not updated. The minute someone needs an “archived” form to do something today, it is not archived.
    • Preexisting documents — files posted before the compliance date can stay as-is, unless they are currently used to apply for, access, or participate in your services. That “unless” swallows most of the documents people actually care about.
    • Certain individualized, password-protected documents — like a specific resident’s water bill — with important caveats, including that an accessible version must be provided on request.

The safe way to think about exceptions: they reduce the size of the cleanup job, not the obligation to serve people. Plan around what residents need, and the exceptions sort themselves out.

6. Process and paperwork

Compliance is not a one-time project; it is a habit your organization has to keep. The pieces that make it stick:

• • • • Someone owns it. Name a person or role responsible for digital accessibility. “Everyone’s job” is how it becomes no one’s job.
      • Staff are trained. Everyone who publishes a page, posts a PDF, or uploads a video needs to know the basics — a one-hour training prevents months of remediation.
      • Residents can tell you about problems. Post an accessibility statement with a real contact and respond when people use it. Most complaints start as unanswered feedback.
      • You test on a schedule. Websites drift. Quarterly checks of your key service pages keep small problems from quietly becoming big ones.

If you are behind, here is the honest play

Plenty of governments are looking at this list in 2026 with a website built in 2014 and a document library that goes back to the fax machine era. The path forward is triage, not panic.

Get a real audit of your main site and your top ten resident tasks, that tells you the true size of the problem. Fix the service paths first: if a resident can pay, apply, register, and get notices accessibly, you have addressed the highest legal risk and the most human impact. Then work outward through the rest, using the deadline as your project calendar. Our website accessibility remediation guide walks through what that process looks like and what it costs, and remember that budget cycles are the hidden deadline. If your fiscal year starts in July, the money for 2027 compliance has to be requested well before then.

Frequently asked questions

We are a tiny special district with three employees. Does this really apply to us?

Yes. Title II applies to public entities of every size, and special districts get the April 26, 2028 deadline regardless of how many people they serve. The good news: a small district usually has a small website, which makes compliance a much smaller project.

Do our social media posts count?

Content you post on social platforms is covered when you use it to offer services or information, so build the habits now: alt text on images, captions on videos, and never share information only as an image of text. You are not responsible for the platform itself, but you are responsible for what you post to it.

What actually happens if we miss the deadline?

Three kinds of exposure. Residents can file complaints with the Department of Justice, which investigates and can require corrective action. Individuals can also sue directly under the ADA, and website accessibility suits against public entities were common even before this rule existed. And practically: an inaccessible site means some residents cannot pay bills, request services, or participate in public meetings, which tends to become a very public problem before it becomes a legal one.

Where to start

Print the checklist graphic above, bring it to your next staff meeting, and assign a name to each of the six sections, that single act puts you ahead of most governments today. When you want expert eyes on where your site actually stands, request a free audit and we will test your key pages by hand, or visit our web accessibility workspace to see how our manual audit and remediation service takes government sites from where they are to WCAG 2.1 AA before the deadline. Current rates are on our pricing page.