ADA Title II
Every state and local government, whatever its size: towns, cities, counties, state agencies, school districts, public authorities and special districts.
28 CFR Part 35
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The sources behind the work, kept in one place
The rule texts, the testing tools and the one-page summaries this practice works from, for public entities under Title II and for organizations whose programs get federal money under Section 504. Each is dated when it was last checked. Free to read and forward. No form to fill in.
Which rule reaches you
Federal law carries one idea, that a program has to be usable by people with disabilities, through different rules for different kinds of organization. Many organizations answer to more than one.
Section 504
Any organization whose programs get federal money, directly or passed through a state, a city or another nonprofit: community and social service organizations, schools and camps, health and behavioral health providers, arts and cultural groups, colleges.
29 U.S.C. 794
Both at once
A city agency or a school district that takes federal grants answers to Title II and to each funding agency's Section 504 rule. One coordinator function can carry both records.
Title II and Section 504
And Title III
Private businesses and nonprofits open to the general public also fall under ADA Title III. Religious organizations are exempt from Title III, though not from Section 504 when federal money reaches them.
28 CFR 36.104; 36.102(e); 29 U.S.C. 794
Title II program access, on one page
The duty has applied since 1992. The 2027 and 2028 dates add a web and mobile standard on top of it.
For towns, cities, counties, state agencies, school districts and special districts. Each program, service and activity has to be accessible when viewed in its entirety, whether it runs at a counter, in a meeting room or online. An investigator asks for documents first, and a website vendor can't produce them.
The four documents an inquiry asks for first
Coordinator designation and notice
At 50 or more employees, at least one employee designated, with name, office address and telephone number published, plus public notice of the rights the law gives.
28 CFR 35.106 and 35.107(a)
Self-evaluation
A documented review of services, policies and practices, open to comment from people with disabilities, kept on file for public inspection for three years at 50 or more employees.
28 CFR 35.105
Transition plan
Where a building has to change for a program to be reached: the barriers, the steps, the schedule and the official responsible.
28 CFR 35.150(d)
Grievance procedure, adopted and published
A working path for complaints, so they resolve inside the entity.
28 CFR 35.107(b)
The first 90 days
- Days 1 to 30Name it, publish it, open one doorThe entity names its designee. The notice and grievance procedure go up, one intake path opens for requests and complaints, and every one is logged with a date.
- Days 31 to 60Inventory what the entity runsPrograms, the buildings where they happen, websites, apps, portals, vendor systems and document sets, with a real way for people with disabilities to take part.
- Days 61 to 90First findings and interim measuresThe programs people can't fully use today and how each reaches people meanwhile, conformance terms in the next solicitations, and a transition plan schedule where needed. Ninety days starts the self-evaluation. It doesn't finish it.
The web and mobile dates
WCAG 2.1 Level AA for web content and mobile apps, including those provided through contracts and licenses: April 26, 2027 for entities of 50,000 people or more, and April 26, 2028 for smaller entities and every special district (28 CFR 35.200(b), as extended April 20, 2026). Both dates are challenged in National Federation of the Blind v. Department of Justice, No. 1:26-cv-02007 (D. Md.). No ruling had been reported as of October 19, 2026, and neither rule protects an entity that waited.
- Title II program access, on one page (PDF)
The same summary as a single page, sized to forward to a manager, a council or counsel.
The full treatment, with each role's part, the stage table and the regulatory calendar, is on the government page.
Section 504, on one page
Federal money brings the duty, and for most nonprofits it covers the whole organization.
For community and social service organizations, schools and camps, health and behavioral health providers, arts and cultural groups, and any organization whose programs get federal money, even through a city, a state or another nonprofit. Every application for the money carries a signed assurance of compliance.
Who it reaches
The whole organization, for most nonprofits
Where the main work is education, health care, housing, social services, or parks and recreation, every operation is covered, not only the funded program.
29 U.S.C. 794(b)(3)
Money passed through someone else
Federal assistance that arrives through a state, a city or another nonprofit still makes an organization a recipient. A federal procurement contract doesn't.
45 CFR 84.10
Each funder sets its own rule
HHS, Education and HUD set the coordinator duty at fifteen employees; the Justice Department at fifty employees and $25,000 in its funding. An organization with several funders answers to each.
45 CFR 84.7; 34 CFR 104.7; 24 CFR 8.53; 28 CFR 42.505
The signed assurance
Every application for the money carries an assurance that the program complies. For HHS funding it's form HHS-690, so a gap is hard to explain once a complaint arrives.
45 CFR 84.5; 34 CFR 104.5
What the organization is required to hold
Coordinator designation
At fifteen or more employees, at least one person designated to coordinate compliance. The HHS and Education rules say person, not employee.
45 CFR 84.7(a); 34 CFR 104.7(a)
Grievance procedure
At fifteen or more employees, adopted with appropriate due process standards.
45 CFR 84.7(b)
Notice
Information about the rule and how it applies, made available to participants, applicants, employees and others.
45 CFR 84.8; 34 CFR 104.8
Self-evaluation
A review of policies and practices with interested persons; at fifteen or more employees, the record kept on file for three years.
45 CFR 84.6(c); 34 CFR 104.6(c)
Transition plan
Where a building has to change for a program to be reached: the obstacles, the methods, the schedule and the person responsible, open to public inspection.
45 CFR 84.22(e)
The first 90 days
- Days 1 to 30Name it, adopt it, give noticeThe organization names its coordinator, adopts the grievance procedure, puts out the notice, and opens one intake path with a dated log.
- Days 31 to 60Map the money and the programsThe single audit or the subaward paperwork names each funding agency, and each agency's rule follows (2 CFR 200.501(a); 200.332(b)(1)). Then the programs, the buildings where they happen and the websites.
- Days 61 to 90Self-evaluation under wayInterested persons take part, the programs people can't fully use get interim measures, and a transition plan schedule is set where a building has to change.
The web and mobile dates
Under HHS's rule, WCAG 2.1 Level AA for web content and mobile apps, including those provided through contracts and licenses: May 11, 2027 at fifteen or more employees and May 10, 2028 below fifteen (45 CFR 84.84(b), as extended in 2026). The extension is challenged in National Federation of the Blind v. Department of Justice, No. 1:26-cv-02007 (D. Md.); no ruling had been reported as of October 20, 2026. The Education, HUD and Justice Department rules set no web date; their Section 504 duty still reaches the website.
- Section 504, on one page (PDF)
The same summary as a single page, sized to forward to an executive director, a board or counsel.
The full treatment, with how to check your funding and what the coordinator covers, is on the Section 504 page.
What to require from whoever performs the work
Under either rule, these terms separate a defensible record from a subscription. Put them in the solicitation or the contract.
A record the organization keeps
Signed, dated findings that outlast any subscription.
A named method, run by hand
Such as the DHS Trusted Tester process, with assistive technology. A scan or an overlay isn't conformance.
Honesty about the designation
Under Title II it goes to an employee, and a provider can perform the function under it but not hold it. The HHS and Education Section 504 rules say person instead, so read each funder's rule before deciding who is named.
A read of every funder's rule
Thresholds, notice and who may be designated differ by agency, and a single audit lists every funder.
Accessible deliverables
Reports a screen reader can read, and PDFs that pass PDF/UA.
Limits in writing
Architects and counsel where the work needs them, and no promise of guaranteed compliance.
How accessible PDFs and pages are checked
Every PDF the practice delivers is validated with veraPDF and then reviewed by hand against the conditions a machine can't judge. The tools are named here so anyone can repeat the check.
veraPDF comes out of the archival world. It was commissioned under PREFORMA, short for PREservation FORMAts for culture information and e-archives, a 2014 to 2017 European Commission program coordinated by Riksarkivet, the Swedish National Archives. PREFORMA was built around the question every archive, library and museum asks of a file it takes in: will this still open, and still read correctly, generations from now? The program bought its answer through pre-commercial procurement, and veraPDF was one of the tools it paid to have built. Its consortium was led by the Open Preservation Foundation and the PDF Association, and the tool remains free and open source.
That lineage is the reason to use it. A validator built for institutions that keep records for centuries holds a file to the letter of the standard, and because anyone can download it, an agency, its counsel or a reviewer can run the same test on the same file and get the same answer. The check never rests on taking the practice's word for it.
veraPDF
Open-source validator for the PDF/A and PDF/UA standards. Desktop, command line and library editions. Dual licensed, GPLv3+ and MPLv2+. The practice runs version 1.30.2 against the PDF/UA-1 profile.
The Matterhorn Protocol
The PDF Association's list of every way a file can fail PDF/UA-1, version 1.1 of April 2021. Some conditions a validator tests; others, such as reading order and whether headings and alt text match the page, take a person.
PDF/UA-1, ISO 14289-1:2014
The international standard for accessible PDF: tagged structure, a logical reading order, real text, a declared language and a title a screen reader announces.
DHS Trusted Tester
The federal government's manual test process for WCAG conformance of web content, with a certification exam. The principal is a certified Trusted Tester.
axe-core
Open-source engine for automated accessibility testing of web pages, maintained by Deque Systems, MPL-2.0. Every page of this site is run through it at five screen widths. Automated testing finds a share of issues, never all of them.
Creating accessible PDFs
The federal government's own instructions for building accessible PDFs from common authoring tools.
Primary sources
The texts themselves, rather than anyone's summary of them. Federal law only; states add their own layer. Each link was checked on October 19, 2026.
ADA Title II
- 28 CFR Part 35, the Title II regulation
Self-evaluation (35.105), notice (35.106), coordinator and grievance procedure (35.107), program access (35.150), effective communication (35.160).
- 28 CFR Part 35, Subpart H: web content and mobile apps
WCAG 2.1 Level AA, the compliance dates in 35.200(b), and the exceptions.
- The April 20, 2026 interim final rule extending the dates
Moved the dates one year, to April 26, 2027 and April 26, 2028.
- National Federation of the Blind v. Department of Justice, No. 1:26-cv-02007 (D. Md.)
The challenge to the extension. Briefing schedule ordered June 29, 2026; no ruling reported as of October 19, 2026.
- ADA.gov fact sheet on the web and mobile rule
The Justice Department's plain-language summary, including the exceptions.
- Small entity compliance guide for the web rule
Written for smaller public entities.
- ADA Title II primer
The Department's overview of Title II for state and local governments.
- Project Civic Access
The Department's Title II compliance reviews and the published settlement agreements.
Section 504
- 29 U.S.C. 794, Section 504 of the Rehabilitation Act
The statute itself, including the whole-organization rule in 794(b)(3).
- 45 CFR Part 84, HHS
Self-evaluation (84.6(c)), coordinator and grievance procedure (84.7), notice (84.8), program accessibility (84.22), reasonable modifications (84.68(b)(7)), effective communication (84.77) and the web and mobile rule (84.84), dated May 11, 2027 and May 10, 2028.
- HHS fact sheet on the 2024 Section 504 rule
HHS's own summary of its 2024 Section 504 rule.
- Form HHS-690, the assurance of compliance
The signed assurance that comes with HHS funding, covering Section 504 among other laws.
- 34 CFR Part 104, Education Department
Self-evaluation (104.6(c)), coordinator (104.7), notice (104.8) and transition plan (104.22(e)).
- 24 CFR Part 8, HUD
HUD's Section 504 rule, including the coordinator duty in 8.53.
- 28 CFR Part 42, Subpart G, Justice Department
The Department's Section 504 rule, with its fifty-employee and $25,000 thresholds in 42.505.
- 2 CFR 200.501, the single audit
Required at $1,000,000 or more in federal awards in a year; its schedule of federal expenditures names every funding agency.
Section 508
- 36 CFR Part 1194, the Section 508 standards
The federal ICT standard, incorporating WCAG 2.0 Level AA.
The technical standard
- Web Content Accessibility Guidelines (WCAG) 2.1
The W3C recommendation that the Title II and Section 504 web rules adopt at Level AA.
General information, not legal advice to any entity. Not a law firm; built to be usable by counsel.
What the practice performs
Everything on this page is free to use. The work it describes is what ADA Access for All performs for public entities under Title II and for organizations whose programs get federal money under Section 504, under one accountable signature, so the obligation is carried by someone whose job it is.
The coordinator function
The organization names its designee. The practice performs the coordinator function under that designation, publishes the designee's contact details, administers the grievance procedure and keeps the record.
28 CFR 35.107 · 45 CFR 84.7
Self-evaluation and transition plan
Performed remotely from the organization's documents and interviews with program staff, with the public participation step and the record each rule requires.
28 CFR 35.105, 35.150(d) · 45 CFR 84.6(c), 84.22(e)
Requests and grievances
One intake path, a decision for each request, the answer in writing, and a dated log of every request, grievance and change.
28 CFR 35.107(b), 35.130(b)(7), 35.160 · 45 CFR 84.7(b), 84.68(b)(7), 84.77
Conformance testing
Websites, portals, apps and documents tested by hand to WCAG 2.1 AA with the DHS Trusted Tester process, and PDFs delivered tagged and validated to PDF/UA-1.
28 CFR 35.200 · 45 CFR 84.84
Procurement terms
Conformance terms written into solicitations and contracts, and vendor documentation checked before award, so the next platform arrives conformant.
28 CFR 35.130(b)(1) · 45 CFR 84.84(a)
The record, kept current
The self-evaluation reopened when programs move or rules change, and every regulatory statement dated against the codified text.
28 CFR 35.105 · 45 CFR 84.6(c)
Remediation is performed by the organization or its vendors; the practice specifies, verifies and records it. Matters that need a licensed architect or an attorney are referred out in writing.
Start with where your organization stands
A 30-minute call establishes which rules bind your organization, which of the required documents you could produce today, and what closing the gap would involve.
Or write to info@adaaccessforall.com.