State and local government training under ADA Title II
Title II of the Americans with Disabilities Act covers programs, services, and activities of state and local government. “Title II” on this site means that statute, not Title II of the Elementary and Secondary Education Act.
Who has to follow the web rule
The Department of Justice rule applies to state and local governments, their agencies and departments, and special-purpose districts. The ADA.gov fact sheet gives examples: offices that provide benefits or social services, public schools, community colleges, public universities, police departments, courts, elections offices, public hospitals and clinics, parks and recreation, libraries, and public transit.
If a contractor, vendor, or nonprofit provides a program for a public entity, the entity still has to make sure that service meets Title II. Content the entity or its vendor posts is not “someone else’s post.”
Public schools are public entities. Education-specific training is on the education page. A district that also receives ESEA Title I funds is still under this rule. Those are two different titles. See how the titles differ.
April 26, 2027 and April 26, 2028
28 CFR 35.200(b), as amended by the interim final rule in the Federal Register on April 20, 2026 (document 2026-07663). The 2024 final rule had said April 24, 2026 for larger entities and April 26, 2027 for smaller entities and special district governments. Those earlier dates are no longer the rule. The technical standard is still WCAG 2.1 Level AA.
On a small screen, scroll the table sideways to read every column.
| Public entity | Compliance date |
|---|---|
| Total population of 50,000 or more, and not a special district government | April 26, 2027 |
| Total population of less than 50,000 | April 26, 2028 |
| Any special district government | April 26, 2028 |
How a school district, library, or department finds its date
- A school district is not a special district government.
- A city school district uses the population of the city. A county school district uses the population of the county.
- An independent school district uses the population estimate in the most recent Small Area Income and Poverty Estimates.
- A unit with no population of its own, such as a city police department or a city library, uses the population of the larger government it belongs to.
- The ADA.gov fact sheet points most governments to 2020 U.S. Census Bureau data for that population.
A special district government, in the small entity compliance guide, is a public entity other than a county, municipality, township, or independent school district, authorized to provide one function or a limited set of functions with enough independence to be a separate government. Examples in that guide include a utility district, a water and sewer board, and a transit authority.
Sources: ADA.gov fact sheet, ADA.gov small entity compliance guide, and the Federal Register, April 20, 2026 (document 2026-07663).
Five exceptions in 28 CFR 35.201
The April 20, 2026 interim final rule extended the dates. It did not change these exceptions. If an exception applies, that content generally does not have to meet WCAG 2.1 Level AA. Other ADA duties still apply, including effective communication, reasonable modifications, and an equal opportunity to participate.
On a small screen, scroll the table sideways to read every column.
| Exception | It applies only when | It does not apply when |
|---|---|---|
| Archived web content, 35.201(a) | All four are true: the content was created before the entity’s compliance date, or it reproduces paper or other physical media created before that date; it is kept only for reference, research, or recordkeeping; it is stored in a dedicated area clearly identified as archived; and it has not been altered or updated after archiving. | Any one of those four is missing. Content created after the date, content people still use to do something current, and content edited after it was archived, do not qualify. |
| Preexisting conventional electronic documents, 35.201(b) | The file is a word-processing, presentation, PDF, or spreadsheet document that was already available on the entity’s web content or mobile app before the compliance date, and it is not currently used to apply for, gain access to, or participate in the entity’s services, programs, or activities. | The file is posted or updated after the date, or people still use it to apply, gain access, or participate. A form the public still submits is the usual case that stays in scope. |
| Content posted by a third party, 35.201(c) | A third party posted it, and not because of a contract, license, or other arrangement with the public entity. | The entity posted it, a contractor or vendor posted it for the entity, or the entity provides the tool or platform itself. A message board the city operates is the city’s. A resident’s post on that board can be the resident’s. |
| Individualized, secured documents, 35.201(d) | The file is a conventional electronic document about a specific individual, their property, or their account, and it is password-protected or otherwise secured. | The content is not one of those document types, it is about people generally, or it is not secured. The website around the document still has to meet the standard. |
| Preexisting social media posts, 35.201(e) | The public entity posted it before the date that entity must comply. | The post is made on or after that date. |
Separate from these five exceptions, 28 CFR 35.204 and 35.205 describe fundamental alteration, undue financial and administrative burdens, and a narrow case where noncompliance has a minimal impact on access. Those determinations belong to the public entity and its counsel. A training vendor does not make them.
Not legal advice
Staff training, a sample annotation, and a draft plan do not replace an ADA coordinator, agency counsel, or a formal audit. Read the fact sheet and the Federal Register rule before you rely on a date or an exception.
What government staff practice
Communications, web, program, and procurement staff practice the materials they already touch: pages, forms, documents, meeting packets, and media. Disability awareness is for staff, faculty, clerks, and supervisors who are not accessibility specialists. It is how disability shows up in documents, meetings, classrooms, and online services. It is not a hiring, firing, or reasonable-accommodation legal service. Publishing a public web page, including a public vacancy announcement that lives on the entity’s site, can still be web content under this Title II rule. Training about that page is about publishing it, not about employment-law advice.
Institutions that want a marked-up sample or a written plan should start with the annotation and plan steps.
Which date is yours?
Include the kind of entity you are — state, county, city, school district, special district, or a department of one of those — and whether you also want the education track.
Contact