The DOJ Extended the ADA Title II Deadlines.

On April 20, 2026, the Department of Justice published an Interim Final Rule extending the ADA Title II digital accessibility compliance deadlines by one year. Large entities now have until April 26, 2027. Smaller entities and special districts have until April 26, 2028.

In this episode, AOG founder Becky Rehorn breaks down what changed, what did not, and what public agencies and AEC firms should do with this information. She also shares findings from her recent review of public involvement documents across 20 state DOT websites, all of which failed PDF accessibility validation.

The standard has not changed. WCAG 2.1 AA is still the requirement. The obligation under Title II has not changed. The deadline moved. The work did not.

Resources mentioned in this episode:
- DOJ Interim Final Rule: https://www.federalregister.gov/documents/2026/04/20/2026-07663/extension-of-compliance-dates-for-nondiscrimination-on-the-basis-of-disability-accessibility-of-web
- ADA Title II Readiness Checklist: https://www.aogaccess.com/ada-title-ii-readiness-checklist
- Accessible Organizations Group: https://www.aogaccess.com

Access Brief is produced by Accessible Organizations Group LLC.

Transcript

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I recently reviewed public involvement documents from 20 state Departments of Transportation. These are the documents that describe how agencies ensure inclusive public participation. All 20 failed PDF accessibility validation.

Then on April 20, the Department of Justice extended the compliance deadline by one year. Agencies now have more time to get this right.

This is Access Brief. I am Becky Rehorn with Accessible Organizations Group. Here is what the extension means, what has not changed, and where to start.

So here is what happened. The DOJ pushed both deadlines back by one year. If your agency serves a population of 50,000 or more, your deadline moved from April 24, 2026 to April 26, 2027. If you are a smaller entity or a special district government, your deadline moved from April 26, 2027 to April 26, 2028.

The rule took effect the moment it was published in the Federal Register on April 20.

Now here is what did not change, and this is the part I want people to hear clearly.

The technical standard is still the Web Content Accessibility Guidelines, or W-C-A-G, version 2.1 Level AA. The scope is still all public-facing web content and mobile applications. The obligation under Title II of the Americans with Disabilities Act to make digital content accessible to people with disabilities has not gone anywhere. The only thing that changed is the enforcement timeline.

I use assistive technology every day in my own work. I know firsthand what it is like to open a PDF that has no tag structure, no reading order, no document title. It is not a minor inconvenience. It is a barrier to doing something as basic as reading a public document.

So when I reviewed those 20 public involvement plans and every single one failed, that was not an abstract finding for me. Those are the kinds of documents I rely on.

The extension gives agencies and the firms that serve them more time to do the work well rather than rushing to check a box.

And that is the key point. This is a reason to do it right. Not a reason to stop.

If your agency has not started yet, you now have time to start well. Figure out what you have. Where it is published. Who produced it. Which content carries the most risk, anything tied to public comment periods, federal funding, or essential services. And start building accessibility into how your teams produce new content so you are not fixing the same problems over and over again.

If your architecture, engineering, or construction firm produces content for public agency clients, this extension applies to the agencies you serve. Their timeline shifted but the deliverables you produce still need to meet the standard. This is the year to build that capability into your team's workflow.

One more thing. The Department of Justice noted in the Interim Final Rule that it plans to consider additional rulemaking during the extension period. That means the substance of the 2024 rule, not just the timeline, may be part of the conversation going forward. I will be watching that closely and I will cover it here as it develops.

But for now, the message is simple. The deadline moved. The work has not changed.

That is it for this episode of Access Brief. If you want to assess where your agency or firm stands, the Americans with Disabilities Act Title II Readiness Checklist is available at aogaccess.com. The full text of the DOJ Interim Final Rule is linked in the show notes. Thanks for listening.