The deadline moved. The backlog did not.
Many public web teams had built their plans around the original April 24, 2026 date. Some were behind. A few were close. Then the date moved, and the temptation is obvious: put accessibility back in the queue behind the redesign, the CMS upgrade, and the enrollment campaign.
That would be a mistake. The rule changed the date, not the scope. Every page, PDF, form, and video your institution publishes is still in play, and so is every site a department launched without telling central IT.
On April 20, 2026, the Department of Justice extended the Title II web and mobile app compliance dates. State and local government entities with a total population of 50,000 or more now have until April 26, 2027. Entities under 50,000, and every special district government, now have until April 26, 2028. The technical standard did not change: WCAG 2.1 Level AA. Source: the DOJ interim final rule extending the Title II compliance dates (91 FR 20902).
For who is covered and what the rule requires, see our ADA Title II deadline explainer.
What actually changed, and what did not
Changed
- The two compliance dates, each pushed back one year.
- The planning window for budgets. Budgets for the coming year now need to fund the work itself, not just a plan.
Did not change
- The standard: WCAG 2.1 Level AA, published in the WCAG 2.1 specification from the W3C.
- Who is covered: state and local government entities, including public colleges and universities.
- The exceptions and their limits. Archived content and third-party content still have narrow conditions, not blanket exemptions.
We are not your counsel, and this is not legal advice. If your general counsel has not read the April 2026 rule, send it to them before you rebuild the plan.
Spend the next two quarters on inventory and triage
You cannot remediate what you have not found. The first job is a full list of what you publish: domains, subdomains, department sites, microsites, document libraries, embedded third-party tools, and mobile apps.
Then triage. Rank by how many people depend on the content and how hard it is to fix. Admissions, financial aid, course registration, permits, payments, and public meetings come first. A departmental event archive from 2019 does not.
If the estate is large or spread across colleges and agencies, a platform that maps every site on the domain helps. KWALL implements Accorbis for this; see how KWALL implements Accorbis. A spreadsheet works too if someone owns it and keeps it current.
Fund remediation in the budget you are building now
For an April 2027 entity, most fixes need money that is available before spring. Check when your next budget cycle starts, and if it begins after April 2027, look for funds now. Write remediation in as its own line, separate from a redesign. Redesigns slip. Remediation on the sites you already run cannot wait for one.
Budget for three kinds of work:
- Template and component fixes, which repair hundreds of pages at once.
- Content fixes: headings, link text, alt text, tables, and documents. Editors do most of this, so plan for training.
- Third-party fixes: forms, calendars, payment portals, and video players you license. These need vendor conversations and contract language.
Keep the last quarter for proof and process
By early 2027, the work shifts from fixing to keeping it fixed. That means an accessibility statement with a working feedback channel, editor guidelines, a review step before new sites launch, and a record of what you tested and when.
An ongoing program is the honest answer here. Accessibility is not a project with an end date. Content changes every day. The KWALL Accessibility & Compliance program is built around monthly review and quarterly fix sprints for that reason.
Smaller entities: April 2028 is closer than it looks
If your community college district, special district, or town is on the April 26, 2028 date, the same sequence applies with more slack. Use it. Smaller teams usually have fewer people to do the work, so the extra time matters most for them.
A hypothetical: one state university, two plans
Picture a public university whose plan targeted April 2026. The team had fixed the main site’s header, footer, and navigation, and had a list of known problem sites. When the date moved, two versions of the next year were possible.
In the first, the remediation line comes out of the budget and the redesign moves up. The department sites stay untouched, and by early 2027 the team is back where it started, with less time.
In the second, the team keeps the line, finishes the inventory, retires sites that ended years ago, and trains editors in the colleges with the most content. The redesign still happens, built on components that were already fixed. The second plan costs about the same. It just spends the money in an order that holds up.
A quarter-by-quarter checklist
Now through December 2026
- Get counsel’s written reading of which date applies to you.
- Finish the inventory: every domain, subdomain, and vendor-hosted property.
- Name an owner for every site, or mark it for retirement.
- Put remediation in the next budget as its own line.
January through March 2027
- Fix shared components on the highest-traffic sites.
- Run manual keyboard and screen reader tests on top tasks.
- Train editors in the units that publish the most.
- Ask vendors for current conformance reports.
April 2027 and after
- Publish or update your accessibility statement and feedback channel.
- Move into a monthly review and quarterly fix cycle.
- Gate new sites with an accessibility review before launch.
Frequently asked questions
Did the DOJ change the accessibility standard?
No. The April 2026 rule only extended the compliance dates. The standard is still WCAG 2.1 Level AA.
Which date applies to a public university?
It depends on the total population of the public entity the university belongs to, which is often the state. Many state universities will fall under the April 26, 2027 date. Confirm your entity’s status with counsel.
Are special districts on the later date?
Yes. The rule puts every special district government on April 26, 2028, regardless of population.
Is an automated scan enough to show we complied?
No. Scans find a share of the issues and are useful for tracking. Conformance needs manual testing, fixed templates, and fixed content.
What if our budget year has already been set?
Look for funds in existing redesign, IT maintenance, or vendor lines, and document the request for the next cycle. A written plan with dates shows intent even when funding lags.
Should we pause our redesign to focus on remediation?
Not necessarily. Run them in parallel, and make sure the redesign is built and tested to WCAG 2.1 AA so it does not create new work.
Next step
If you want a second set of eyes on your plan before budgets lock, tell us what you are working on. The founder reads every submission.
