The accessibility deadline covers the pages your vendors run, too

The date, and the sentence most plans miss

In April 2024 the Justice Department published a rule under Title II of the Americans with Disabilities Act. It says state and local governments must make their web content and mobile apps meet WCAG 2.1 Level AA, the widely used technical standard for accessibility.

The original deadlines were close. On April 20, 2026, the department pushed them back by a year, citing what governments had reported about resources, staffing and the pace of technology work. The dates now are:

• April 26, 2027 for state and local governments serving a population of 50,000 or more.
• April 26, 2028 for those under 50,000, and for special district governments such as water, transit or school districts.

As of this week, the larger group has a little over six months.

This note isn't legal advice. Your attorney decides how the rule applies to you. It's about the part most project plans miss.

The rule covers web content and apps a public entity provides "directly or through contractual, licensing, or other arrangements."

Read that slowly. It means the online payment page run by your payment processor, the permit portal you license, the recreation booking site, the meeting-agenda and minutes tool, the map viewer, the job applications site and the app residents use to report potholes. If residents reach it from your website to do business with you, assume it counts until someone shows you otherwise.

There are exceptions, and they're narrower than people hope. The rule lists archived content, documents that were already posted before your compliance date (unless people use them to apply for or take part in a service), content posted by members of the public (unless they post it under an arrangement with you), individual secured documents like a resident's own bill, and social media posts from before the date. Read the list with your attorney rather than assuming a whole portal falls into one.

Six months out: make the list

Start with an inventory, not an audit. One row per thing a resident can open:

• What it is and what people do there (pay, apply, book, read).
• Who runs it: your staff, or a vendor under contract.
• The contract's renewal date.
• How many people use it, roughly, and whether there's a paper or phone alternative today.

Most teams find more vendor-run pages than they expected. That list is your plan. The pages where people pay, apply or book come first, because those are the ones that stop someone from getting a service.

Don't forget the apps. The rule covers mobile apps the same way it covers websites, so a parking app, a transit app or a 311 reporting app built by a vendor belongs on the list too, with the same questions. And if you're a special district, or unsure which population figure applies to you, settle which deadline is yours with your attorney early, before the plan is built around the wrong date.

Five months out: ask each vendor the same questions

Send every vendor on the list the same short letter:

• Does your product meet WCAG 2.1 Level AA today? If not, which parts don't, and when will they?
• Can you send a current accessibility conformance report (often called a VPAT) for the version we use, and say who tested it and how?
• Who do residents contact if they hit a barrier, and how fast do you respond?
• Will you commit to this in our contract?

Keep the replies. A vendor that answers with dates and a recent report is a vendor you can plan with. A vendor that sends a two-year-old report for a different version, or no answer, is a risk you now know about. If a renewal is coming up, this is your leverage: put conformance, a fix timeline and a contact for accessibility problems into the contract.

Three months out: fix your own forms and templates

While vendors answer, fix what you control. Start with your site's templates, because one fix in a template repairs every page that uses it: headings, link text, color contrast, keyboard navigation, focus that's visible.

Then the forms. Labels that are real labels, error messages that say what went wrong and stay put, time limits that warn people first and let them extend. Long forms deserve special care; we've written about a session timeout that took a whole form with it. And a PDF that people must fill in to apply for something is not covered by the "already posted" exception, so the forms people use most need an accessible version. See putting the PDF online isn't putting the service online.

The last two months, and the day after

Test with people, not only tools. Automated checkers catch a useful share of problems and miss plenty. Ask residents who use screen readers, magnification or voice control to try your five most important tasks, and watch where they get stuck.

Make the testing count by choosing tasks, not pages: pay a parking ticket, apply for a permit, find tonight's meeting agenda, report a broken streetlight. A page can pass a checker and still leave someone unable to finish the task it exists for.

Publish an accessibility page with a real contact who answers. Decide how a barrier report gets logged, who owns the fix, and how the resident gets served in the meantime.

And remember that April 26 isn't a finish line. Every new page, form and vendor after that date has to meet the standard too, so build the check into how you buy and publish, not into a one-off project. The rule also includes undue-burden language; if you're relying on it, your attorney will want it documented.

Put this into practice

This month, open your website's homepage and follow every link that lets a resident pay, apply, book or report. Write down each destination and who runs it. That list, with a renewal date beside each vendor, is the most useful accessibility document you can make this year.

We work with government and public-sector teams on resident-facing services, from intake forms to the systems behind them, with accessibility considered from the start. If you need help with the inventory, the vendor questions or the forms that matter most, talk to us.

Related work: Wellthie.