The DOJ Title II Deadline Just Passed. Your City, School, or Library Is Almost Certainly Out of Compliance. Here's What To Do This Week.

April 24, 2026 came and went, and the U.S. Department of Justice’s Title II Final Rule officially took effect for every public entity in America serving a population of 50,000 or more. That includes essentially every county, every mid-sized city, every public-university system, every transit agency, every public library system, and every K-12 school district in the country with a few thousand or more enrolled students.

If you work for one of those entities and the deadline caught you flat-footed, you are in extremely good company. We have spent the past four weeks talking to municipal IT directors, K-12 webmasters, library systems administrators, and university accessibility coordinators, and the pattern is consistent: somewhere between a third and a half of in-scope entities entered May 2026 with a website that has never been audited for WCAG 2.1 AA, a third-party platform contract with no accessibility-conformance language, and no documented remediation plan.

This is not a “panic and pull the website” situation. DOJ enforcement does not work that way, private lawsuits take months to materialize, and the most aggressive plaintiffs’ firms are still working through the backlog of January and February demand letters. But it is also not a situation you can ignore for another quarter. The next ten business days matter, and the work is mostly non-technical.

Quick refresher: what the rule actually requires

The 2024 DOJ Title II Final Rule (28 CFR Part 35, Subpart H) requires every state and local government’s web content and mobile applications to conform to the Web Content Accessibility Guidelines 2.1 Level AA. The rule applies to:

  • Your main public-facing website
  • Every subdomain (parks-and-rec, library, transit, planning department)
  • Every PDF, Word document, video, and downloadable file you post
  • Every third-party platform you make available to the public — board-meeting agenda systems, library catalogs, e-book lending platforms, online room reservations, transit trip planners, parks-and-rec class registration, online utility-bill payment, online permit applications

The deadline that just passed (April 24, 2026) was for “large” public entities, defined as those serving populations of 50,000 or more. The deadline for smaller entities and special-purpose districts is April 24, 2027 — twelve months from now.

There are narrow exceptions for archived content, pre-existing conventional electronic documents not currently in active use, and certain third-party content. None of them are as broad as people hope, and “we didn’t know” is not one of them.

What “out of compliance” actually exposes you to

Three categories of risk attach to a public entity that missed the deadline:

Federal enforcement. DOJ can investigate based on complaints or its own initiative, can demand a corrective-action plan, and can pursue litigation. Federal funding eligibility — Department of Education grants, FTA grants, IMLS library funding, HRSA health-center funding — is on the line if the entity is found in violation under Section 504 in parallel.

Private lawsuits and demand letters. Title II permits private rights of action with attorneys’-fee shifting under 42 U.S.C. § 12205. The plaintiffs’ bar that has been driving ADA Title III demand-letter campaigns against private businesses for the past decade is now turning the same intake pipelines on public entities. A handful of firms have built dashboards that scrape municipal websites for common WCAG failures and generate demand letters in bulk.

State-law exposure. California Unruh ($4,000 per visit), Colorado HB 21-1110 (up to $3,500 per violation per day), New York Human Rights Law administrative penalties, and similar state statutes attach independently and in some cases more aggressively than the federal rule.

The realistic risk profile for a typical city or school district that missed the deadline is not “DOJ knocking on the door tomorrow” — it is a demand letter from a private plaintiff’s firm sometime in the next six to nine months, with the leverage to extract a meaningful settlement because the entity has no documented evidence of good-faith remediation efforts.

That documentation is what the next ten business days are about.

The ten-business-day plan

This plan does not require a developer, an accessibility consultant, or a procurement process. It does require an IT director or webmaster to spend two to four hours per day on it for two weeks. The point is to produce a defensible position — not full conformance, which most entities cannot reach in two weeks — that you have understood your exposure, started remediation, and can credibly demonstrate good-faith progress.

Days 1-2: Inventory what you actually have

List every domain, subdomain, and third-party platform under your entity’s umbrella. Most municipalities have between fifteen and forty in-scope properties when this is done honestly. Common ones get missed: the human-resources job-application portal, the payroll-services single-sign-on, the parks-and-rec activity-registration platform, the volunteer-management software, the public-records-request portal, the board-of-education livestream platform, the property-tax-payment platform.

For each, record: (1) the URL, (2) the vendor name if it’s third-party, (3) the contract status and renewal date, (4) whether the vendor has provided a Voluntary Product Accessibility Template (VPAT), (5) the platform owner internally.

This inventory is the single most important deliverable of the two-week sprint. If you can show DOJ or a plaintiff’s firm a complete inventory plus a remediation roadmap, you are in a defensibly different posture than an entity that has none.

Day 3: Run automated scans on your top ten properties

Use a free tool — WAVE, Lighthouse, or axe DevTools — on the top ten properties from your inventory. Save the results. Automated scans catch only thirty to forty percent of WCAG failures, but they catch the most embarrassing and most-litigated ones (missing alt text, low contrast, missing form labels) and they produce a reproducible record.

If you’ve never used these tools, see our five-minute accessibility audit guide for a non-technical walkthrough.

Days 4-5: Identify and fix the “easy critical” issues

About fifteen percent of automated-scan findings are quick fixes that can be done in an afternoon by a webmaster who knows the CMS: alt text on images, color-contrast adjustments on key pages, form-field labels on the most-used forms (contact form, public-records request, board-meeting comment submission). Fix these on the top ten properties first.

Day 6: Tackle PDFs in the most active places

The DOJ rule explicitly covers PDFs. Most public entities post hundreds of them: board agendas and minutes, budget documents, public-notice flyers, permit forms, school-handbook PDFs. You cannot tag every legacy PDF in two weeks. You can do three things that materially shift your posture:

  1. For new documents going forward, train staff on the Microsoft Word and Adobe Acrobat accessibility checkers and require accessibility checking before posting. Most “new” PDFs are easier to fix at creation than after.
  2. For active high-traffic legacy PDFs (this year’s budget, current school handbook, this season’s parks-and-rec catalog), prioritize remediation.
  3. For the long tail of historical PDFs, publish a documented alternative-format request channel: a phone number and email that produces an accessible version within five business days.

See our accessible PDF guide for the specifics.

Days 7-8: Open vendor support tickets on every third-party platform

This is the single most impactful step for most municipalities, because seventy percent of public-entity in-scope content sits inside third-party platforms — the library catalog, the e-book lending app, the parks-and-rec registration system, the agenda-management tool, the transit trip planner, the school-information system. You cannot fix the vendor’s code, but you can put the vendor on notice and document that you did.

Open a formal support ticket with each major vendor. The ticket should:

  • Cite the 2024 DOJ Title II Final Rule and the April 24, 2026 effective date
  • Reference the contract’s accessibility-warranty clause if one exists (if not, note that one will be required at renewal)
  • Request a current VPAT
  • Ask for a remediation roadmap with committed dates for any known WCAG 2.1 AA defects
  • Request a designated accessibility contact at the vendor

Save every ticket number and vendor response. This is direct evidence of good-faith efforts and the easiest single thing to produce in a complaint response.

Day 9: Publish (or update) your accessibility statement

Every public entity needs a published accessibility statement. It does not need to claim full conformance. It does need to:

  • Acknowledge the entity’s commitment to WCAG 2.1 AA
  • Identify the conformance status honestly (partial, in progress, etc.)
  • Provide a contact channel for accessibility issues
  • Document an alternative-format request process
  • Be dated and reviewed at least annually

A good accessibility statement that admits partial conformance and demonstrates active remediation is significantly more protective than a generic claim of full conformance you cannot back up. We’ve written about why the audit-versus-statement question is the wrong framing — the answer is both, and the statement is what stops most demand letters from escalating.

Day 10: Document the program and report to leadership

Compile the inventory, the scan results, the remediation log, the vendor-ticket log, and the accessibility statement into a single packet. Brief your council, school board, library board, or executive director. Get budget authority for the next phase: the manual audit and full remediation work that automated scanning cannot replace.

What you do not need to do this week

You do not need to retain an accessibility consultant before doing the inventory and scans. The inventory is internal work; the scans are free. A consultant becomes high-leverage at week three or four when you have a clear inventory and need a manual audit of the priority properties.

You do not need to take any platform offline. The DOJ rule does not require that, and removing services would itself raise Title II program-access issues.

You do not need to publish a public mea culpa. A clear, honest accessibility statement is the right public communication; a press release about non-compliance is not.

You do not need to install an accessibility overlay widget. They do not produce conformance, they have been the subject of their own demand-letter campaigns, and they will not protect you under Title II.

What “good faith” looks like in a Title II complaint

If a complaint is filed, the question becomes whether the entity acted in good faith and is making meaningful progress. The documentation produced by the ten-day plan is what good faith looks like in writing:

  • A complete property inventory
  • Automated scan results dated within the past 30 days
  • A remediation log showing what’s been fixed and when
  • Vendor support tickets with dates and reference numbers
  • A published accessibility statement with current contact information
  • A budgeted plan for the next phase

Entities that walk into a complaint with that packet are typically able to negotiate reasonable corrective-action plans. Entities that walk in with nothing find themselves on much steeper terms.

The smaller-entity grace period (April 2027)

If your entity serves a population under 50,000 — small towns, rural school districts, special-purpose districts, smaller libraries — the deadline is April 24, 2027. That is twelve months. It is enough time to do the work properly, but only if the inventory and vendor-engagement work starts now. The smaller-entity demand-letter wave will start around twelve to eighteen months after the smaller-entity deadline, which means roughly late 2028, but private litigation under the existing Title II program-access standard is available now.

A note on the people this rule was written for

It is easy in compliance writing to lose sight of the fact that the deadline that just passed was about real people — disabled residents who could not pay their water bill online, blind parents who could not navigate the school-lunch menu, deaf students who could not access the recorded board meeting, wheelchair-using patrons who could not reserve an accessible study room at the library. The Title II rule exists because the federal accessibility framework that began with the original ADA in 1990 had a thirty-five-year hole in it for state and local government digital services, and tens of millions of disabled Americans were on the wrong side of that hole every day.

The reason the ten-day plan above leads with a property inventory and ends with a budget request is not bureaucratic. It is that you cannot fix what you have not seen, and you cannot make meaningful progress on something this big without leadership having an honest picture of where the entity stands. Get the picture, write it down, share it with the people who have to fund the next phase, and start.

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