Six months to the ADA web deadline. Start by counting what you actually have

The date and who it applies to

The federal web accessibility rule for state and local governments has a new first deadline. In April 2026, the Justice Department extended the compliance dates by a year. Entities serving 50,000 people or more now have until April 26, 2027 to make their web content and mobile apps meet WCAG 2.1 Level AA. Smaller entities and special district governments have until April 26, 2028.

That makes today, October 26, exactly six months out for cities, counties and agencies in the first group. Six months sounds like plenty. It isn't, once you see how much there is to check.

The rule covers what a government provides directly and what it provides "through contractual, licensing, or other arrangements". That's the part people underestimate. Your permit portal, payment page and job application system count even if a vendor runs them. We wrote about that in The accessibility deadline covers the pages your vendors run, too. The rule also describes some circumstances where certain content may not need to meet the standard, and your counsel should tell you which apply to you. Don't assume any of them do until then.

What Tempe's count shows

The City of Tempe, Arizona offers a useful picture of scale. According to an October 20 report in the Tempe Independent, the city is reviewing more than 28,000 online documents and over 300 software applications. The review covers the website, online job applications, mobile apps, social media content and the digital forms residents use every day.

Tempe is working with an accessibility consulting firm, training staff to create accessible documents, and requiring future software vendors to meet federal accessibility standards. The city's IT manager, Andrea Vasile, said older software and thousands of fillable PDFs are among the hardest parts, because many have to be rebuilt rather than fixed.

Most governments don't know their own version of those two numbers. That's the first thing to change. You can't buy your way to a deadline you haven't measured. An audit tool, a remediation contract or a new website platform might all be the right purchase, but only once you know what they need to cover.

Month by month

This is our suggested plan for the next six months. It isn't legal advice, and your counsel should set the priorities that are specific to you.

November: count. Build one list of everything residents use online. That means web pages, but also documents (agendas, reports, forms), online services such as payments, permits and applications, mobile apps, social channels and video. Note who owns each item and whether a vendor runs it. Your web platform can export pages and files, your finance team knows which payment and permit systems you pay for, and the clerk's office knows how many agendas are published each year.

Keep the list in one shared spreadsheet, not in each department's notes. Give every row the same few columns: what it is, where it lives, who owns it, who runs it, how often residents use it, and its current status. That last column is what you'll report on every month until April. Expect the count to grow for a few weeks as departments remember things, such as a recreation booking system, an old grant portal or a parking app. That's normal. A list that keeps growing in November is much better than one that surprises you in March.

December: sort. Put every item into one of four groups. Fix in place: pages and simple documents that need corrections. Rebuild: fillable PDFs and old systems that can't be fixed, which Tempe's experience suggests will be a big group. Replace: vendor systems that won't meet the standard. Retire: content nobody needs, which is usually more than people expect.

January: vendors. Write to every vendor in the replace and rebuild groups. Ask for a current accessibility conformance report and a date they'll meet WCAG 2.1 AA. Add the standard to every contract that's up for renewal, as Tempe has done for future purchases.

February and March: fix and rebuild. Work through the list by how often residents use each item. A form people fill in every day matters more than a 2014 report. This is also when to turn the most-used fillable PDFs into proper online forms. A PDF form posted online is rarely the same as an accessible online service, a point we made in Putting the PDF online isn't putting the service online.

April: test and publish. Have people test the highest-traffic services with screen readers and keyboard-only navigation, not just automated scanners. Publish an accessibility statement that says how residents can report a barrier and get help.

What to buy, and when

Once you've counted, buying decisions become much clearer. A large document backlog points to remediation services and staff training. A handful of vendor systems that won't comply points to procurement, not to your web team. A web platform that can't produce accessible pages, whatever you do, points to a replacement.

The order matters because the wrong first purchase is expensive. An automated scanner bought in November will report thousands of issues on your website and none in the PDF library or the payment portal it never saw. A new content management system bought before the count may move the same inaccessible documents to a nicer-looking site.

After April

Tempe's IT manager made the point that fixing things now is only half of it, and the other half is making sure new things stay compliant. That's where most programs slip. Staff upload a new scanned PDF the week after remediation finishes, or a department signs up for a new survey tool without asking.

The durable fixes are simple: training for everyone who publishes, an accessibility check in the purchasing process, and someone who owns the inventory after the deadline passes. The list you build in November is the one you'll maintain for years.

If you need help building the inventory, rebuilding PDF forms as accessible online services, or replacing systems that won't meet the standard, that's what our government and public sector team does. Talk to us.

Related work: Sutton Place.