The ADA web accessibility rule and your district

A federal rule says that state and local governments' websites, and the documents posted on them, have to meet a published accessibility standard: WCAG 2.1 at Level AA. For governments of under 50,000 people, and for special district governments, the date is April 26, 2028.

General information, not legal advice. Ask your district's attorney about your own district. Checked against the Federal Register and ada.gov on November 3, 2026.

The dates

Population of 50,000 or more
April 26, 2027
Population under 50,000
April 26, 2028
Any special district government
April 26, 2028

The Department of Justice issued the rule on April 24, 2024, under Title II of the Americans with Disabilities Act. On April 20, 2026 it moved each date one year later. In that notice the Department says it "plans to engage in future rulemaking processes related to the substantive requirements" of the rule, so what the rule asks could change, not only when. Nothing further had been published when this page was checked. We will update this page when anything changes.

Does a fire district count as a special district government?

The rule defines the term this way:

"Special district government means a public entity—other than a county, municipality, township, or independent school district—authorized by State law to provide one function or a limited number of designated functions with sufficient administrative and fiscal autonomy to qualify as a separate government and whose population is not calculated by the United States Census Bureau in the most recent decennial Census or Small Area Income and Poverty Estimates."

The Department's own examples are "a mosquito abatement district, utility district, transit authority, water and sewer board, zoning district, or other similar governmental entity". Fire districts are not named. Whether your district fits each part of the definition is a question for your district's attorney. If it does not, its date follows its "total population", which the rule also defines.

What it means for your PDFs

The rule covers your website's content, and its definition of web content includes documents such as PDFs. Two exceptions matter for minutes and notices:

  • Documents already on your site before your date are excepted, unless they are "currently used to apply for, gain access to, or participate in" your district's services, programs, or activities. ada.gov's guide adds that a document updated after the date no longer qualifies.
  • Archived content is excepted only if all four of these hold: it was created before your date, or it reproduces paper documents created before your date; it is kept only for reference, research, or recordkeeping; it is not changed after it is archived; and it is kept in an area clearly marked as archived.

Neither exception covers minutes and notices written after your date.

The site is built to WCAG 2.1 AA. But if you upload scanned minutes with no text layer, no website can make them accessible: a screen reader sees a photograph. That is why every document you upload is checked for a text layer, and the ones without one are flagged so you know which to fix. Anyone telling you a website alone makes you compliant hasn't thought about your PDFs.

What to do first

  1. List what your district posts, and where.
  2. Make new documents with a text layer: save minutes and notices as PDF from the word processor, rather than printing and scanning them.
  3. Find the old scans with no text layer (how to check a PDF), and decide with your attorney which to fix and which can be left as they are.
  4. Make sure residents can ask for any document in a form they can use, and get it.

Sources

Read on November 3, 2026.