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Seyfarth Synopsis: DOJ issues Interim Rule extending Title II ADA web accessibility compliance deadlines by one year.
The DOJ finally answered the question on everyone’s minds: is it going to take action on the Title II website regulations, and if so, what? We now – 4 days before the compliance deadline – have an answer. Today, April 20, 2026, the U.S. Department of Justice (DOJ) issued an Interim Final Rule extending for approximately a year the compliance deadlines for state and local governments to make their websites and mobile applications accessible under Title II of the Americans with Disabilities Act (ADA). The compliance deadline for governmental entities servicing populations of 50,000 is extended from April 24, 2026 to April 26, 2027. Smaller governmental entities serving fewer than 50,000 people and special district governments’ compliance deadline is extended from April 26, 2027 to April 26, 2028.
Background: How Did We Get Here?
After over 10 years (since 2010) of fits and starts through different presidential administrations work to develop web accessibility rules under Title II (and Title III, now paused indefinitely), the DOJ published a final rule on April 24, 2024 adopting the Web Content Accessibility Guidelines (“WCAG”) version 2.1 Level AA (which was originally published in June 2018), as the technical standard for web content and mobile app accessibility applicable to governmental entities under Title II. As we noted in 2025, under the new administration DOJ announced it would review the economic impact of these regulations, which we expected at a minimum might delay the compliance deadlines.
Why Did DOJ Extend the Deadlines?
In the Interim Rule, the DOJ acknowledged it overestimated both technological readiness and institutional capacity of the governmental entities subject to the Rule when setting the original deadlines. The Rule lists several systemic challenges the DOJ identified:
- Concerning technology limits, automated tools cannot reliably remediate web content—particularly complex educational and STEM materials—without human review.
- Resource constraints facing governmental entities. Many public entities, particularly educational institutions, lack sufficient staffing, specialized expertise, and budget to ensure compliance.
- The “significant litigation risks” facing public entities that were unable to meet the prior deadlines, noting in particular the risk of private enforcement actions.
- Finally, and somewhat ironically, the DOJ noted that it created legal uncertainty surrounding WCAG guidance when it incorporated hyperlinks in the 2024 final rule. The DOJ noted that the website at that hyperlink that was part of the April 2024 final rule was a “dynamically changeable” resource, meaning that the website to which individuals were directed had not only a description of WCAG version 2.1, but also of more recent versions of WCAG and multiple descriptions of criteria, which created compliance ambiguity about what standard it was adopting, and potentially would violate the Administrative Procedure Act and affected entities’ right to notice and an opportunity to be heard.
Impact: What Does This Mean For Governmental Entities and Their Contractors?
While the DOJ’s extension of these compliance deadlines for government websites and apps provides needed breathing room, it does not suspend existing ADA obligations and does not eliminate litigation risk for inaccessible digital content during the extension period – as enforcement actions have happened even absent specific website regulations under effective communication obligations of the ADA. Moreover, the substantive requirements remain unchanged: covered websites and mobile applications ultimately must conform to WCAG 2.1 Level AA by these new deadlines – they just get a year reprieve before being specifically regulatorily-required to do it. The DOJ cautions that it “fully anticipates implementing the regulation at the new deadline.” This could be taken as a warning that, although it has delayed the date for website accessibility compliance to assist governmental entities at this point, the DOJ might be prepared to launch enforcement actions when the compliance deadlines take effect in April 2027 and April 2028.
The DOJ’s extension offers welcome relief—but not immunity. The regulatory clock has been reset, not stopped. State and local governments that use the additional time to meaningfully advance accessibility will be best positioned to manage risk of litigation and enforcement actions and meet their obligations when the extended deadlines arrive. The Interim Rule won’t become final until after a 60-day comment window which closes June 19, 2026.
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