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Accessibility · Regulation

ADA and web accessibility, with Title II and Title III kept apart

The DOJ's Title II rule names WCAG 2.1 Level AA with dated deadlines for state and local government. Title III, for businesses open to the public, has no technical standard at all — and confusing the two is where most planning goes wrong.

Not legal advice · scan a public URL free

The technical standard the Title II rule adopts
WCAG 2.1 AA
Effective date of the DOJ Interim Final Rule
20 April 2026
Compliance date for entities with a total population of 50,000 or more, extended from 24 April 2026
26 April 2027
Compliance date for entities under 50,000 and any special district government, extended from 26 April 2027
26 April 2028

Taken from the Department of Justice Interim Final Rule itself, read on ada.gov on 11 September 2026. These dates have already been extended once; check ada.gov rather than this page before planning around them.

Title II and Title III, side by side

Two titles of the same statute, with entirely different amounts of technical detail behind them.

ItemWhat it covers
Title II — state and local governmentSince the DOJ's 2024 rule, a named standard (WCAG 2.1 Level AA) with dated deadlines staged by entity size. It also reaches special purpose districts, Amtrak and other commuter authorities.
Title III — businesses open to the publicThe DOJ's position is that the ADA applies, but no regulation names a technical standard, and the 2026 Interim Final Rule says Title III was not addressed in it.
What reaches private vendorsSell software to a covered public entity and their Title II obligation becomes your procurement question — usually how a private company first meets the rule.

What a scan honestly contributes

Three things a scan gives you, and one it never will.

ItemWhat it isStatus
A dated record of runsScan history for 90 days; scheduled runs make a continuous series, not a single snapshot.Provided
The machine-checkable subset, cleared23 of the 55 WCAG 2.2 AA criteria on the engine we run, ranked by which fix clears the most.Provided
An explicit not-checked listCriteria no rule can evaluate are reported as not checked, never as passed.Named, never claimed
Not a certificationNo conformance report, no certificate, no overlay. A scan is an input, not a verdict.Not offered

What this does not do

It is not legal advice.
We build testing tools. Whether the ADA reaches your organisation, and what that requires, is a question for a qualified lawyer.
It does not tell you an obligation applies to you.
The page describes who each rule generally covers. Your own position depends on facts we do not have.
Dates move.
The Title II compliance dates have already been extended once. Check ada.gov rather than this page before planning around them.
A clean scan is not compliance.
Automated rules reach 23 of the 55 WCAG 2.2 AA criteria on our engine. The other 32 are reported as not checked and stay unknown until a person checks them.
FAQ

Frequently asked questions

The Department of Justice says yes, and has taken that position since 1996. What it does not do for private businesses is name a technical standard — the DOJ's guidance says organisations have flexibility in how they comply.

Start with a baseline you can date

Run a scan against the journeys that matter, clear the machine-checkable findings, and keep a record that shows the work rather than claiming a verdict.