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ADA Title II · Section 504 · Section 508
For municipalities, counties, school districts, public authorities, and any organization receiving federal financial assistance. A credentialed assessment, the program documentation the regulation requires you to hold, and a remediation plan that survives review.
What binds a public entity, what standard applies, and when. Dates reflect the interim final rules issued in 2026, which extended both the Title II and Section 504 conformance dates by one year.
| Rule | Standard | Citation | Date |
|---|---|---|---|
| Nondiscrimination dutyThe underlying obligation, independent of any web standard | Program access and effective communication | 28 CFR Part 35 | In force now |
| Section 504 obligationApplies to every program or activity receiving federal financial assistance, from any federal agency. Each agency issues its own implementing regulation: 45 CFR Part 84, 34 CFR Part 104, 28 CFR Part 42 Subpart G, and so on across the funding agencies | Nondiscrimination on the basis of disability | 45 CFR Part 84 | Since July 8, 2024 |
| ADA Title II web and mobilePublic entities with a total population of 50,000 or more, other than special district governments. Extended by interim final rule of April 20, 2026, RIN 1190-AA82 | WCAG 2.1 Level AA | 28 CFR 35.200(b)(1) | April 26, 2027 |
| ADA Title II web and mobilePublic entities with a total population under 50,000, and every special district government regardless of population | WCAG 2.1 Level AA | 28 CFR 35.200(b)(2) | April 26, 2028 |
| Section 504 web and mobileUnder the rule codified at 45 CFR 84.84. Recipients with fifteen or more employees. Extended by interim final rule published May 11, 2026, 91 FR 25507. Other funding agencies codify Section 504 separately and may set their own dates | WCAG 2.1 Level AA | 45 CFR 84.84(b)(1) | May 11, 2027 |
| Section 504 web and mobileRecipients with fewer than fifteen employees under the same rule. The codified threshold is fifteen, not fifty | WCAG 2.1 Level AA | 45 CFR 84.84(b)(2) | May 10, 2028 |
| New York State entity websitesState Technology Law 103-d. A higher standard than the federal rule, and an earlier date. Applies to State Entity websites including those provided by third parties, which reaches vendors | WCAG 2.2 Level AA | NYS STL 103-d | January 2027 |
| NYC Local Law 27 of 2016Every City agency designates a Disability Service Facilitator | Designated DSF, published contact information | LL27 of 2016 | In effect |
| NYC Local Law 12 of 2023Five-year accessibility plan and an annual progress report | Physical, digital, programmatic access and effective communication | Admin. Code 23-1004 | Annually, May 1 |
| Section 508Applies to federal agencies and flows to their vendors | WCAG 2.0 Level AA | 36 CFR Part 1194 | Existing baseline |
| WCAG 2.2Frequently requested, sometimes assumed to be required | Best practice, above the legal baseline | W3C recommendation | Not required in the U.S. |
The table scrolls sideways on a narrow screen. It is reachable by keyboard.
Both interim final rules are being challenged, and the Department of Justice has signalled it may revisit the underlying rule. An organization treating the new dates as firm is relying on something that is contested from two directions at once.
National Federation of the Blind v. U.S. Department of Justice, No. 1:26-cv-02007-RDB, filed May 21, 2026 in the District of Maryland, asks the court to declare both interim final rules unlawful, vacate them, and order the agencies to enforce the original 2024 compliance dates. The grounds are that the rules issued without notice and comment and were arbitrary and capricious.
Administrative Procedure Act
This is the part that matters operationally. An entity that stood down in May 2026 and later faces a vacatur has no protection written into either rule for having relied on it. The original dates would simply be the dates again.
No textual protection
The Department's regulatory agenda published August 14, 2026 states it is considering whether to extend the deadlines and then issue a proposed rule reconsidering whether provisions of the April 24, 2024 rule could be made less burdensome. Timetable listed as to be determined.
RIN 1190-AA82
The date could move earlier by court order or later by rulemaking. Neither outcome changes the nondiscrimination duty that has applied since July 8, 2024, and only one of them is survivable without having started. Work performed now counts under every version of this.
Verified August 14, 2026
No ruling had issued in the litigation as of August 14, 2026. Every regulatory statement on this page carries the date it was last checked against the codified text and the docket, so a reader can see how current it is rather than assuming.
The date is not the decision point. Budget approval is. Counted backward from a Title II conformance date, an entity that has not started is already inside the window where the sequence has to begin.
Section 504 recipients can substitute May 2027 and read the same sequence.
Nearly every entity has a website vendor and an accessibility statement. An investigator asks for neither. The four documents below are what gets requested, and producing them honestly takes months rather than weeks.
A named ADA Coordinator with published contact information and real delegated authority, rather than a title assigned to whoever was available.
28 CFR 35.107(a)
A documented review of programs, services and activities, current rather than inherited from a vendor file nobody has opened in a decade.
28 CFR 35.105
Identified barriers, the steps to remove them, a schedule, and the official responsible. Entities with 50 or more employees are required to have one.
28 CFR 35.150(d)
A published procedure with a working intake path, so a complaint resolves internally instead of arriving as a demand letter.
28 CFR 35.107(b)
Project Civic Access is a Justice Department initiative that reviews whether counties, cities, towns and villages comply with Title II. It has been running since 1999 and has produced more than 220 settlement agreements covering over 200 localities in all fifty states, the District of Columbia and Puerto Rico.
The Department originated the majority of these compliance reviews on its own initiative. Selection has turned on factors like population, geographic spread and proximity to a university or tourist attraction. An entity can be reviewed without anyone having complained about it.
28 CFR Part 35
Settlement agreements open with whether the entity conducted a self-evaluation, designated an ADA Coordinator, adopted a grievance procedure, and made its programs, services and activities accessible. The four documents above are not a best-practice checklist. They are the opening question in a federal compliance review.
28 CFR 35.105 and 35.107
Where a locality receives financial assistance from the Department, the review proceeds under Section 504 as well as Title II, which brings suspension or termination of that assistance into scope if voluntary compliance is not reached.
28 CFR Part 42, Subpart G
Every settlement is posted publicly, which makes the collected set the clearest available statement of what the Department expects from a public entity. The practice works from those agreements directly rather than from a vendor's summary of them.
Published on ada.gov
Automated scanning finds a fraction of the applicable success criteria and cannot judge whether a screen reader user gets through a task. The federal government does not rely on it, and neither does this practice.
Websites, portals and native mobile applications tested against WCAG 2.1 Level AA using the Department of Homeland Security Trusted Tester process, with assistive technology in the loop.
WCAG 2.1 AA
Payment portals, permit systems, board-agenda platforms and student information systems. Obligation follows the service rather than the ownership of the code.
28 CFR 35.130
Board packets, budgets, notices and forms, where most public entities carry the largest unmeasured barrier and the least vendor coverage.
PDF/UA and WCAG 2.1 AA
Contract and solicitation terms that put conformance obligation on the vendor supplying the system, so the next platform arrives compliant.
Section 508 alignment
Federal rules set the floor. States, counties, cities, towns, villages and municipal agencies answer to requirements stacked on top of that floor, frequently on an annual cycle rather than a single date in 2027. More than three thousand counties and tens of thousands of municipalities each sit under some version of this. The practice is a certified New York City vendor and holds NYC MBE certification, and works with public entities outside New York on the same structure.
The layers differ by jurisdiction but the shapes repeat: a designation requirement, a planning requirement, a recurring reporting requirement, and in some states a private right of action with damages the federal ADA does not provide. Verified examples are below. The practice identifies the applicable layer at the start of an engagement rather than assuming the federal floor is the whole obligation.
The Unruh Civil Rights Act treats an ADA violation as a state civil rights violation, and adds what federal law does not: a private right of action with statutory damages of no less than $4,000 per violation, plus fees. It reaches businesses serving Californians whether or not they are located there. State entities separately answer to Government Code accessibility requirements.
Cal. Civ. Code 51 and 52
Chapter 2054 Subchapter M requires state agencies and institutions of higher education to develop, procure and maintain accessible electronic and information resources, with standards in 1 TAC 206 and 213 aligned to Section 508. House Bill 5195, effective September 2025, adds a modernization duty requiring agencies to assess their sites for accessibility.
Tex. Gov. Code 2054.457
The Information Technology Accessibility Act has required state agencies, public universities and entities using state funds to meet published accessibility standards since 2007. Its standards cover websites, applications, documents and procured technology, so private vendors are pulled in through contracts.
IITAA and IITAA standards
State Technology Law 103-d requires State Entity websites, including those provided by third parties, to conform to WCAG 2.2 Level AA by January 2027. That is a higher standard than the federal rule and an earlier date, and the third-party clause reaches vendors. In New York City, Local Law 27 of 2016 adds a designated Disability Service Facilitator and Local Law 12 of 2023 adds a five-year plan with an annual progress report.
NYS STL 103-d and Admin. Code 23-1004
House Bill 21-1110 established state-specific digital accessibility requirements for state government and public higher education, with the state setting the technical standard rather than leaving it to each entity.
HB 21-1110
Most states have at least a human rights statute reaching disability discrimination, and many add an information technology accessibility law for public entities. The practice establishes which layers apply before scoping, because the state layer often carries remedies, deadlines or reporting duties the federal rules do not.
Identified at engagement start
Entities where a single accountable signature matters more than a large bench, and where the documentation has to be defensible rather than decorative.
A 30-minute call establishes which rule binds your entity, which of the four documents you could produce today, and what closing the gap would involve.
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