Blogpost
6.8 minute read
April 01, 2026
California public agencies are facing a new compliance requirement for digital services. In April 2024, the U.S. Department of Justice (DOJ) published a landmark final rule under Title II of the Americans with Disabilities Act (ADA), establishing enforceable technical standards for the digital content of state and local governments. The rule applies to agencies providing services through websites, mobile applications (apps), PDFs, online forms, and other digital tools, requiring that this content be accessible to people with disabilities.
To meet this requirement, the DOJ has adopted the Web Content Accessibility Guidelines (WCAG) Version 2.1 Level AA, with compliance deadlines approaching over the next two years. For agencies managing large volumes of public-facing and legacy content, early planning will be critical. This blog outlines the rule, key deadlines, and practical steps to help your agency prepare.
Who Does This Apply To?
Like the rest of Title II, this rule applies broadly to all state and local governments, including their agencies and departments, as well as special purpose districts and commuter authorities.
Examples of covered state and local entities include:
- State and local offices providing benefits or social services (e.g., food assistance, health insurance, or employment services).
- Public schools, community colleges, and universities.
- Police departments.
- Elections offices.
- Public hospitals and healthcare clinics.
- Public parks and recreation programs.
- Public libraries.
- Public transit agencies.
A note on contractors: State and local governments that contract with outside entities to deliver public services, such as a private engineering firm managing permit applications or inspection records through an online portal on behalf of a municipality, are responsible for ensuring their contractors also comply.
For more information, visit the ADA’s State and Local Governments page.
Key Compliance Deadlines
Your compliance deadline depends on the size of the population your agency serves:
- April 24, 2026: State and local agencies serving a population of 50,000 or more
- April 26, 2027: State and local agencies serving a population under 50,000, as well as special district governments
Population figures are based on the 2020 decennial Census, and it’s worth noting that the relevant population is that of the broader government entity, not the number of employees, students, or patrons a specific department serves.
What Digital Content Is Covered?
The rule applies to digital content that a public entity provides or makes available to the public, including:
- Websites and individual web pages.
- Mobile apps.
- PDFs, Word documents, spreadsheets, and presentations.
- Online forms, portals, and payment systems.
- Video and multimedia content.
- Social media posts (made after the compliance deadline).
- Third-party tools and vendor-operated platforms used to deliver services.
- Learning management systems and course content (for public schools and universities).
Content delivered through third-party vendors is still the agency’s responsibility.
Limited Exceptions
The rule does include some exceptions, but they’re limited, and most active digital content will still need to comply:
- Archived web content. Content created before the compliance deadline, retained solely for reference or recordkeeping, not updated after archiving, and clearly identified as archived.
- Pre-existing conventional electronic documents. PDFs, Word files, presentations, and spreadsheets posted before the compliance deadline that are not currently used to access services or programs.
- Content posted by third parties. Such as a member of the public posting on an open government message board (not content posted by a vendor on the agency’s behalf).
- Individualized, password-protected documents. Documents about a specific person, property, or account within a secure portal.
- Pre-existing social media posts. Posts made before the compliance deadline. New posts after the deadline must comply.
Even where an exception applies, agencies still have existing ADA obligations to provide effective communication and equal access and, in many cases, will still need to provide accessible formats upon request. Exception examples can be found in the final rule.
What’s at Stake
Non-compliance carries significant risks on two fronts:
- Legal exposure
- Real harm to the people you serve
On the legal side, the DOJ has the authority to investigate agencies, file lawsuits, and mandate remediation under federal oversight. Private lawsuits can add further liability through costly settlements and legal fees.
Beyond the legal risk, inaccessible digital content creates real barriers for community members with visual, auditory, cognitive, physical, and neurological disabilities, preventing them from accessing essential government services like registering to vote, applying for benefits, paying utility bills, or participating in public hearings.
Getting Started: The DOJ’s Recommended Action Steps
The DOJ has published a helpful resource, “First Steps Toward Complying with the ADA Title II Web and Mobile Application Accessibility Rule,” outlining 11 suggested action steps for public entities:
- Learn about the rule’s requirements. Review the DOJ’s Fact Sheet, Small Entity Compliance Guide, and full rule text.
- Determine your compliance deadline. Use the 2020 decennial Census to identify your entity’s population and corresponding deadline.
- Identify who will be involved. Assign roles across departments, not just IT. Procurement, content authors, and leadership all play a part.
- Train your staff. Provide foundational accessibility training for all staff and specialized training for designers, developers, content authors, and procurement personnel.
- Inventory your digital content. Catalog all websites, web pages, mobile apps, PDFs, documents, social media accounts, and third-party tools.
- Understand the exceptions. Review the five limited exceptions and determine which of your content may qualify.
- Determine which content needs to comply. After reviewing the exceptions, identify all content that must meet WCAG 2.1 Level AA.
- Assess what fixes are needed. Evaluate current accessibility using a combination of automated tools and manual review. Automated tools alone cannot identify all issues.
- Prioritize remediation. Focus first on content that enables key public-facing tasks, is high-traffic, or has been flagged as inaccessible.
- Review vendor contracts. Ensure third-party vendors can produce accessible content and update contracts to include WCAG 2.1 Level AA requirements and accessibility warranties.
- Create accessibility policies. Establish ongoing policies for maintaining accessible digital content across your organization.
How Harris Can Help
Meeting these new requirements can feel overwhelming, especially for agencies managing large volumes of documents, reports, and public-facing materials. That’s where Harris can help.
Harris’ Publications Services team collaborates with technical teams to develop accessible documents that comply with federal and state accessibility laws, including Section 508 of the Rehabilitation Act, the Americans with Disabilities Act, and California Assembly Bill 434, as well as the newly required WCAG 2.1 standards.
Using advanced tools and industry best practices, our team ensures documents are accessible to the widest possible audience. Our services include:
- PDF Remediation: Comprehensive WCAG-compliant remediation covering tags, reading order, alternative text (alt text), bookmarks, heading structure, and accessible tables and figures.
- Accessible Template Development: Custom accessible templates built to your agency’s standards, reducing remediation time on future documents.
- Accessibility Testing and Validation: Automated checker plus manual review, identifying issues beyond what automated tools alone can catch.
- Drafting-Stage Review: Early stage structure review while documents are still in draft form, catching problems before they become costly.
- Compliance Documentation: Development of agency-specific compliance standards, processes, and supporting documentation, giving your team a clear, repeatable framework to follow from project initiation through publication.
- Staff Training: A multi-module training series available for your agency’s team.
Don’t Wait — Start Planning Now
Comprehensive document remediation for agencies with large volumes of PDFs, reports, documents, and other public-facing materials can take months. The DOJ’s guidance is clear: start planning now.
Accessible digital services aren’t just a legal requirement. They mean better experiences for people with disabilities, older adults, and the public at large. Starting early gives your agency the best chance to meet deadlines without disruption, reduce legal risk, and demonstrate a genuine commitment to equitable public access.
Ready to get started? Contact Harris to learn how we can help your agency meet the ADA Title II requirements.
Disclaimer: This blog post is for informational purposes only and does not constitute legal advice. Agencies should consult with legal counsel regarding their specific compliance obligations under ADA Title II.
