Coordinator designation and public notice
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)
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Program accessibility · ADA Title II · Section 504
The obligation is already in force. The 2027 dates cover one channel of it.
For municipalities, counties, state agencies, school districts, public authorities, and any nonprofit or other organization whose programs get federal money, even through a city or state. Title II has required program access since 1992, and the Section 504 regulations since 1977. The 2027 and 2028 dates add a technical standard for websites and mobile apps on top of that obligation. They do not start it.
What a public entity is required to hold
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.
Self-evaluation
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
Transition plan
Identified barriers, the steps to remove them, a schedule, and the official responsible. Required of entities with 50 or more employees when structural changes are needed to reach program access.
28 CFR 35.150(d)
Grievance procedure
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)
One more duty sits beside the four documents. People have to be able to find out where accessible services, activities and facilities are, and each inaccessible entrance needs a sign directing people to an accessible one or to where they can get that information. The practice writes the public access information and keeps it current, and the evaluation records which entrances need signs. 28 CFR 35.163.
Where your program access stands
Every public entity owed a self-evaluation of its services, policies and practices by January 1993, and entities with 50 or more employees also owed a designated coordinator and a grievance procedure. Program access is judged program by program, viewed in its entirety, and the rule lets a program reach people another way rather than altering every building.
Find the row that describes you today. The row under it is the work.
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Stage 1: Nobody named
- What it looks like
- No designated coordinator, no self-evaluation on file, no grievance procedure. Access questions go to whoever answers the phone.
- Who does the work
- Nobody named.
28 CFR 35.105 and 35.107
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Stage 2: Named
- What it looks like
- A coordinator is designated and the grievance procedure is posted. Requests are still handled one complaint at a time, and no one has listed which programs people can't fully use.
- Who does the work
- One employee holds the title, part-time on top of another job.
28 CFR 35.107(a) and (b)
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Stage 3: Evaluated
- What it looks like
- A self-evaluation of services, policies and practices, with a chance for the public to comment, and a list of the programs people can't fully use today. Where a building has to change, a transition plan sets the schedule and the official responsible.
- Who does the work
- The designated employee stays the owner. The practice performs the self-evaluation remotely, from your documents and interviews with program staff.
28 CFR 35.105 and 35.150(d)
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Stage 4: Delivering
- What it looks like
- Programs reach people now by the methods the rule allows, most integrated setting first: changing a policy, providing an interpreter or an accessible document, moving a class to an accessible room, delivering a service another way. People can find out where accessible services are.
- Who does the work
- Program managers make the changes. The practice tracks each one and keeps the record.
28 CFR 35.130(b)(7), 35.150(b), 35.160 and 35.163
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Stage 5: Kept current
- What it looks like
- The self-evaluation comes back when programs move or the rules change. Every request, grievance and change sits in a dated record.
- Who does the work
- Programs and procurement share it. The coordinator holds the record, and the practice keeps it current.
28 CFR 35.105 and 35.107
A row describes how the work runs. It isn't a finding that the law is met.
What each role needs to know
The duty belongs to the entity as a whole, whether it's a town, a county or a state agency. Each role below holds one part of it, and an inquiry usually finds the gap where two parts meet.
Elected officials and the chief executive
The obligation doesn't sit with one office. What only this level can give is real authority for the designated coordinator, a budget line that survives the next cycle, and sign-off on the self-evaluation once it's done.
28 CFR 35.105 and 35.107(a)
The designated coordinator
An entity with 50 or more employees designates at least one employee and publishes that person's name, office address and telephone number. A title without a name doesn't meet it. The practice performs the coordinator function under that designation, administers the grievance procedure and keeps the record. The designation itself stays with the employee.
28 CFR 35.107(a)
Program and department heads
Program access is judged program by program, viewed in its entirety. The person who runs a program decides how it reaches people: a changed policy, a different room, an interpreter, an accessible document, the service delivered another way.
28 CFR 35.130(b)(7) and 35.150
Clerks, communications and web staff
Agendas, board packets, legal notices, forms, social posts and the website all fall under effective communication today. The 2027 and 2028 dates add the WCAG 2.1 AA standard for web and mobile content on top of that.
28 CFR 35.160 and 35.200
Procurement
The duty follows the service, including services run through contracts, licenses or other arrangements. Payment portals, permit systems, recreation registration and meeting platforms are the entity's programs to residents, whoever wrote the code. Conformance terms belong in the solicitation, before award.
28 CFR 35.130(b)(1) and 35.200(a)
Front desk and front-line staff
The few questions staff may ask about a service animal, the mobility devices they must admit, how a request for a policy change or an auxiliary aid gets taken down, and the rule that a person is never charged for one.
28 CFR 35.130(f), 35.136 and 35.137
Human resources
Employment runs on its own track: Title II covers it for every public entity, and Title I and the EEOC's rules apply at fifteen employees. The accommodation process for staff is separate from the request process for the public, and both need a written record.
28 CFR 35.140 and 29 CFR Part 1630
The first 90 days
An entity starting from stage 1 or 2 can get from nobody named to a working record in about a quarter. Ninety days starts the self-evaluation. It doesn't finish it, and for a county or a state agency the full evaluation runs longer.
- Days 1 to 30Name it, publish it, open one doorThe entity names its designee. The practice drafts the public notice and the grievance procedure for publication, opens a single intake path for requests and complaints, and starts a dated log of every one that arrives. 28 CFR 35.106 and 35.107.
- Days 31 to 60Inventory what the entity runsEvery program, service and activity; the buildings where they happen; every website, app, portal, vendor system and document set. People with disabilities and the organizations that represent them get a real way to take part. Department heads supply the facts, and the practice runs the inventory and keeps the participation record. 28 CFR 35.105(a) and (b).
- Days 61 to 90First findings and interim measuresA list of the programs people can't fully use today and how each one reaches people in the meantime, conformance terms in the next solicitations, and a transition plan schedule where a building has to change. Program managers act on it, and the practice produces the findings and dates the record. 28 CFR 35.105(c) and 35.150(d).
What to require from whoever performs the work
Whether the work goes to this practice, another firm or a software vendor, these are the terms that separate a defensible record from a subscription. Put them in the solicitation.
A record the entity keeps
Signed and dated findings that stay with the entity, not a dashboard that goes dark when the subscription ends.
28 CFR 35.105(c)
A named test method, run by hand
The process named in writing, such as the Department of Homeland Security Trusted Tester process, with assistive technology in the loop. An automated scan alone can't show conformance, and an overlay or widget isn't conformance.
WCAG 2.1 AA
Honesty about the designation
Under Title II the coordinator designation goes to an employee. A provider can perform the function under that designation. It can't hold it, and a proposal that says otherwise has misread the rule.
28 CFR 35.107(a)
Every legal statement cited and dated
Each claim tied to the codified text and the date it was last checked, because these dates have moved once in 2026 and are in court.
eCFR and the docket
Deliverables that are accessible themselves
Reports and plans that a screen reader can read, with PDFs that pass PDF/UA. An accessibility report that fails its own standard is a finding against whoever wrote it.
PDF/UA-1 (ISO 14289-1)
Clear limits, in writing
Design and sealed drawings referred to a licensed architect, legal advice referred to counsel, and no promise of guaranteed compliance, since no test can make one.
Scope boundary
- Title II program access, on one page (PDF)
The four documents, the first 90 days and what to require from a provider, sized to forward to a manager or a council. No form to fill in.
The same summary lives on the Resources page as a web page, beside the tools used to check it and the primary sources behind it.
Program accessibility reaches the whole organization
A conformant website is not a compliant organization. The strongest technical evaluation available, WCAG 2.1 and 2.2 AA validation with automated testing, manual assessment, assistive technology testing and functional workflow verification, proves one thing: that accessibility was intentionally designed, tested and governed in the product. That evidence is real and it matters.
It is also not the whole obligation. The ADA, Section 504, Section 508 and FCC requirements each reach past the interface into how an organization operates.
Where programs happen
Entrances, routes, rooms and restrooms where services are delivered. Existing buildings need not all be accessible, but the program must be: relocated, delivered another way, or reached through scheduled structural work. Design and sealed drawings are referred to licensed architects.
Program access, 28 CFR 35.150
Accommodation
An interactive process for employees and for members of the public, with intake, analysis, a written outcome and a file that holds up on review. No test suite produces this.
29 CFR 1630 and 28 CFR 35
Organizational process
Designated ownership with real authority, written policy, an exception path, and accessibility requirements carried into procurement so the next platform arrives conformant.
28 CFR 35.107(a)
Customer service and support
The channels a person reaches for when something fails. A conformant page is little help if the phone line, the intake form and the staff response are not equally usable.
Effective communication, 28 CFR 35.160
Documentation
Self-evaluations, transition plans, grievance procedures, public notice and a dated conformance record. These are the first items an investigator requests and none of them are code.
28 CFR 35.105 and 35.150
Employment practice
Application systems, onboarding platforms and the internal tools staff are required to use, plus the accommodation process behind them.
Title I and Section 501
Procedure and timeline
Notice, complaint intake, response windows and escalation. Entities lose these matters on process and record far more often than on the underlying technology.
28 CFR 35.107(b)
Service animals and mobility devices
Policies that admit service animals, wheelchairs, walkers and other mobility devices as the regulation requires, with staff who know the few questions they may ask and the documentation they may not demand.
28 CFR 35.136 and 35.137
Digital channels
Websites, mobile apps, portals and documents, tested by hand to WCAG 2.1 AA using the Department of Homeland Security Trusted Tester process. The 2027 and 2028 web and mobile compliance dates apply to this channel. The rest of the obligation already applies.
28 CFR 35.200 and 45 CFR 84.84
No testing gate, however rigorous, guarantees statutory compliance on its own. An organization can pass every automated and manual check on its public site and still be exposed, because nobody owns the function, the grievance procedure was never published, or staff cannot handle a request when one arrives.
Accessibility is finally about whether a person can do the thing they came to do. Testing establishes whether the interface permits it. The organization determines whether it happens. This practice covers both, which is why the engagements on this site pair the program work with conformance testing of the digital channels that deliver it.
Five things you should be able to produce on request
None of these are optional. Each is required of covered entities, and each gets requested early when a complaint or an inquiry arrives. Check what you could hand over this week.
0 of 5Check the boxes above to see where you stand.
Why these five
These are the documents an OCR or DOJ inquiry asks for first, and the ones a plaintiff's counsel looks for before deciding whether to file. They are also the slowest to produce, because a self-evaluation and a transition plan describe work an entity has to carry out rather than language it can adopt.
Note what is missing from the list: your website vendor. A vendor can fix a contrast ratio or add alt text. None of them can write your transition plan, run your self-evaluation, or sign your Coordinator designation. That work sits with the entity, and it is where the exposure concentrates.
What a federal compliance review asks for first
Project Civic Access is the Justice Department's program of Title II compliance reviews of counties, cities, towns and villages. Since 1999 it has produced more than 220 settlement agreements covering over 200 localities in all fifty states, the District of Columbia and Puerto Rico. The most recent agreement on the Department's list is dated June 2021.
Most reviews were not complaint-driven
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
The reviews ask for the same four documents
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 optional extras. They are the opening question in a federal compliance review.
28 CFR 35.105 and 35.107
Federal funding can be at stake
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
The agreements are published
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 archive.ada.gov
Regulatory calendar
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, directly or passed through a state, a city or another organization. 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 |
| 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 | Above the federal baseline | W3C recommendation | Not required by federal rule |
The table scrolls sideways on a narrow screen. It is reachable by keyboard.
States add their own layer, and many adopt the Section 508 standards or WCAG for their own agencies and the vendors that sell to them. The practice identifies that layer at the start of an engagement.
The extension is not settled
Both interim final rules are being challenged, and the Department of Justice has signaled 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.
The rules are in litigation
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
Neither rule contains a reliance safe harbor
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
Pressure runs the other way too
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
What follows from both
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.
Docket checked October 19, 2026
No ruling had been reported in the litigation as of October 19, 2026. The court set a briefing schedule on June 29, 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.
Working backward from April 2027
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.
- April 2027Conformance datePublic-facing web and mobile content meets WCAG 2.1 Level AA, and the entity can show the documentation behind it.
- Roughly six to nine months earlierRemediation and retestingDeveloper or vendor work, then validation by hand. Third-party platforms move on their own release schedules, which an entity does not control.
- Roughly nine to twelve months earlierAssessment and documentationThe audit, the self-evaluation, and the transition plan. This is the step that produces the schedule everything after it depends on.
- One budget cycle before thatProcurement and appropriationBoard or council approval, solicitation, and award. For most public entities this is the longest and least flexible step in the sequence.
Section 504 recipients can substitute May 2027 and read the same sequence.
And the technical side, tested by hand
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.
Manual conformance testing
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
Third-party and vendor systems
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
Documents and PDFs
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
Procurement language
Contract and solicitation terms that put conformance obligation on the vendor supplying the system, so the next platform arrives compliant.
Section 508 alignment
Who this is built for
Entities where a single accountable signature matters more than a large bench, and where the documentation has to be defensible rather than decorative.
Find out where your entity stands
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.
Book a 30-minute call