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What Is Title II of the ADA?

Title II of the ADA applies to state and local governments. A 2024 rule sets technical standards for their websites, apps, and documents.

By — Published 10/06/2026

Title II of the Americans with Disabilities Act (ADA) applies to state and local governments. It says people with disabilities must have equal access to government programs and services. Since a 2024 Department of Justice rule, that includes government websites, mobile apps, and the documents posted on them.

So Title II is now a technical requirement too. The people who run government websites and publish government documents have specific standards to meet.

Who it applies to

Title II applies to every state and local government, no matter how small. That includes state agencies, counties, cities, school districts, courts, and transit systems. Private businesses are covered by Title III instead.

You can read Title II of the ADA in the U.S. Code, the DOJ’s Title II regulation at 28 CFR Part 35, and the ADA.gov overview of state and local government requirements.

The technical standard

The 2024 rule adopted WCAG 2.1 Level AA as the standard for government web content and mobile apps. WCAG is a list of testable success criteria, so your IT team can check whether a page or document meets it.

The DOJ’s fact sheet on the web and mobile app rule gives some examples:

  • Images need alt text, so a blind person using a screen reader knows what the image shows.
  • Videos need captions.
  • Standard text needs a color contrast ratio of at least 4.5:1.
  • PDFs, Word files, presentations, and spreadsheets must meet the same standard as web pages.
  • Mobile apps are covered too.

Documents are often overlooked. A PDF also needs a document title and a document language set in its metadata, so a screen reader can announce and read it correctly. I wrote about these in Real ADA Title II Findings for Government Documents.

There are some exceptions. They include archived web content, preexisting conventional electronic documents, and content posted by third parties. Each one has conditions that must be met.

The deadlines

An April 2026 rule moved the compliance dates to:

  • April 26, 2027: State and local governments with a total population of 50,000 or more
  • April 26, 2028: Smaller governments and special district governments

The National Federation of the Blind has sued the Department of Justice to set those extensions aside, so the dates could change. I wrote more about the deadline in The Real ADA Title II Deadline for Government Documents.

What you need to do

  1. Inventory what you publish. Include your web pages and your document corpus. Many agencies have thousands of documents, some decades old.
  2. Decide what is in scope. The exceptions depend on dates. The date in a document’s metadata is often the date it was scanned, which can be years after it was created. Our TrueDate™ analysis finds the best supported date from a document’s text, visual content, and metadata. TrueContext™ checks the web pages that link to each document for the archive labeling the archived web content exception requires. Both are covered in how our audits handle the archival exceptions.
  3. Find the defects. Check each page and document against WCAG 2.1 AA, including the hidden metadata.
  4. Fix the source. If a template, scanner, or workflow keeps producing inaccessible files, fix it. Otherwise every new document has the same problem. Tracing a defect back to its source is called document provenance.
  5. Keep checking. New documents get published after the deadline, and each one needs to comply.

Why we built Metadata Minder

Most governments have too many documents to check by hand, and new ones keep coming. Much of the accessibility industry focused on websites. We built Metadata Minder to focus on documents. It reads every file, extracts its metadata, and analyzes its structure and content. It can also check new documents as they are published.

Rietta finds defects and suggests technical solutions. We do not remediate documents, and we are not a law firm, so this post is not legal advice. If you work for a state or local government, see our ADA/WCAG document accessibility audits for government. You may also want to read when to involve legal counsel in an ADA/WCAG audit.

References