The ADA Title II PDF deadline for cities and counties: April 26, 2027

On April 20, 2026 the U.S. Department of Justice published an interim final rule that pushed back the Title II web accessibility compliance dates by one year. The technical standard did not change: web content, including PDFs posted on your website, must meet WCAG 2.1 Level A and AA.

Which date applies to you

• Total population of 50,000 or more (other than special district governments): April 26, 2027.
• Population under 50,000, and all special district governments: April 26, 2028.

"Population" is the entity's total population as defined in the rule, not your staff size or website traffic.

Why PDFs are usually the biggest job

Most city and county sites publish agendas, packets, minutes and forms as PDFs every week. A PDF exported without tags has no reading order, headings or alt text for a screen reader, so it typically fails WCAG 2.1 AA even if the web pages around it pass.

What is excepted

28 CFR 35.201 lists limited exceptions, including archived web content and certain preexisting conventional electronic documents, unless those documents are currently used to apply for, access or participate in your services. New agendas and forms you post going forward are generally not excepted. Read the exact text and talk to your attorney about how it applies to you.

A practical plan for the next six months

1. Inventory the PDFs your residents use most: agendas, minutes, applications, permits, fee schedules.
2. Fix the templates you export from (Word headings, alt text, real tables) so new documents start out closer to compliant.
3. Remediate high-traffic and recurring documents first, and keep a validation report for each.
4. Publish an accessibility statement with a way to request an accessible version.

Sources

• DOJ interim final rule, 91 FR 20902 (Apr. 20, 2026)
• 28 CFR 35.200 (current eCFR)
• 28 CFR 35.201 exceptions
• WCAG 2.1

Last reviewed 2026-10-20.