When does the DOJ Title II web rule take effect?

The DOJ's 2024 final rule (89 Fed. Reg. 31320) was published April 24, 2024 and became effective June 24, 2024. The April 20, 2026 Interim Final Rule (91 Fed. Reg. 20902; AG Order No. 6742-2026) extended the compliance dates by one year. New deadlines: April 26, 2027 for entities serving 50,000+ population; April 26, 2028 for smaller entities and special district governments.

Why did DOJ extend the Title II web compliance dates?

DOJ stated in the April 2026 IFR that it "overestimated the capabilities (whether staffing or technology) of covered entities" to comply in the original time frames. The agency also reclassified special district governments to the smaller-entity tier. Public comment on the IFR runs through June 22, 2026.

What does the IFR NOT change?

The IFR extends only the WCAG 2.1 AA technical-conformance deadlines. It does not change: (1) Title II's underlying nondiscrimination mandate, which remains in full force today; (2) DOJ's authority to investigate complaints in the interim; (3) private plaintiffs' ability to sue under Title II for inaccessible content; (4) the 28 C.F.R. § 35.201 exceptions; (5) the April 24, 2024 publication or June 24, 2024 effective date.

What technical standard does the rule mandate?

WCAG 2.1 Level AA — 50 success criteria (30 Level A + 20 Level AA) organized under the four POUR principles. This is codified at 28 C.F.R. § 35.200. The rule preserves the existing Title II undue-burden and fundamental-alteration defenses, requiring written, documented findings to invoke them.

Did HHS also extend its Section 504 web/mobile deadlines?

No. HHS has NOT matched the DOJ Title II extension. Section 504 deadlines remain: May 11, 2026 for HHS funding recipients with 15+ employees, and May 10, 2027 for those with fewer than 15.

DOJ Title II Web Rule (2024) + April 2026 IFR

The DOJ's 2024 Title II final rule (89 Fed. Reg. 31320; codified at 28 C.F.R. §§ 35.200–35.205) requires state and local government websites and mobile apps to meet WCAG 2.1 Level AA. On April 20, 2026, the DOJ published an Interim Final Rule (91 Fed. Reg. 20902) extending the compliance dates by one year — to April 26, 2027 for entities serving 50,000+ population and April 26, 2028 for smaller entities and special districts.

Key dates (updated for April 2026 IFR)

Date	Event
April 24, 2024	Final rule published (89 Fed. Reg. 31320)
June 24, 2024	Rule effective date
April 20, 2026	IFR published extending compliance dates by 1 year (91 Fed. Reg. 20902; AG Order No. 6742-2026). Effective immediately.
June 22, 2026	IFR public comment period closes (submit a comment)
April 26, 2027	Extended compliance deadline for entities serving 50,000+ population (was April 24, 2026)
April 26, 2028	Extended compliance deadline for entities serving under 50,000 population AND special district governments (was April 26, 2027)

What the IFR does NOT change

Title II's nondiscrimination mandate — in full force today, no waiting
DOJ's authority to investigate complaints during the extension
Private plaintiffs' ability to sue under Title II right now
The 28 C.F.R. § 35.201 exceptions (archived web content, preexisting electronic documents, third-party content not under contract, password-protected individualized documents, preexisting social media posts)
The HHS Section 504 deadlines — those are not extended (May 11, 2026 / May 10, 2027)

The five Title II exceptions (28 C.F.R. § 35.201)

Archived web content — clearly identified, not updated, kept solely for reference/research/recordkeeping
Preexisting conventional electronic documents — PDFs/Word documents posted before the compliance date, unless still used to provide services
Third-party content not posted by the entity or under contract/license with the entity (e.g., public comments on social media)
Password-protected individualized documents — prepared for specific individuals, secured, not public
Preexisting social media posts

Enforcement and penalties

DOJ enforces through complaint investigations, compliance reviews, pattern-or-practice lawsuits, and intervention in private suits. Remedies under Title II include injunctive relief, compensatory damages (no cap), attorneys' fees, and potential loss of federal funding. Punitive damages are not available against government entities.

Official sources: ada.gov rule overview · April 2026 IFR · full plain-English breakdown

FAQ

When does the DOJ Title II web rule take effect?: The DOJ's 2024 final rule (89 Fed. Reg. 31320) was published April 24, 2024 and became effective June 24, 2024. The April 20, 2026 Interim Final Rule (91 Fed. Reg. 20902; AG Order No. 6742-2026) extended the compliance dates by one year. New deadlines: April 26, 2027 for entities serving 50,000+ population; April 26, 2028 for smaller entities and special district governments.
Why did DOJ extend the Title II web compliance dates?: DOJ stated in the April 2026 IFR that it "overestimated the capabilities (whether staffing or technology) of covered entities" to comply in the original time frames. The agency also reclassified special district governments to the smaller-entity tier. Public comment on the IFR runs through June 22, 2026.
What does the IFR NOT change?: The IFR extends only the WCAG 2.1 AA technical-conformance deadlines. It does not change: (1) Title II's underlying nondiscrimination mandate, which remains in full force today; (2) DOJ's authority to investigate complaints in the interim; (3) private plaintiffs' ability to sue under Title II for inaccessible content; (4) the 28 C.F.R. § 35.201 exceptions; (5) the April 24, 2024 publication or June 24, 2024 effective date.
What technical standard does the rule mandate?: WCAG 2.1 Level AA — 50 success criteria (30 Level A + 20 Level AA) organized under the four POUR principles. This is codified at 28 C.F.R. § 35.200. The rule preserves the existing Title II undue-burden and fundamental-alteration defenses, requiring written, documented findings to invoke them.
Did HHS also extend its Section 504 web/mobile deadlines?: No. HHS has NOT matched the DOJ Title II extension. Section 504 deadlines remain: May 11, 2026 for HHS funding recipients with 15+ employees, and May 10, 2027 for those with fewer than 15.