ADA Title II
City Government Website Accessibility: What the Rule Requires
For a city or county, the website is where residents pay a utility bill, pull a permit, request a record and read the agenda before a meeting. The DOJ web rule treats all of that as a public service, which means the portal is in scope, not just the brochure pages.
Sources
Key takeaways
- Two dates: April 26, 2027 for entities serving 50,000 or more people; April 26, 2028 for smaller entities and special districts.
- Special districts get the later date regardless of the population they serve.
- Inventory first: most cities underestimate their web estate by counting only the main domain.
- Agendas and minutes are the recurring load: they are published forever and are usually PDFs.
Which deadline applies to a city or county?
It follows the population of the jurisdiction. Entities serving 50,000 or more people work to April 26, 2027; everything smaller, together with special district governments, works to April 26, 2028. Special districts take the later date even where the population they serve is large, which catches people out. The deadlines guide explains where both dates come from and what they do and do not change.
What counts as the city's web content?
More than the main site. Under 28 CFR § 35.200 it is the web content the entity provides or makes available, directly or through contractual and licensing arrangements. In a typical city that means the main domain, the separate police and fire sites, the library catalogue, the utility billing portal, the permitting and licensing system, the records request tool, the job board, the meeting agenda platform and the parks registration system.
In detail
Build the inventory before estimating anything, because the inventory is what the work is sized from and what a scope or a price should be built out of. Departments buy software directly more often than central IT expects, so ask every department what residents log into, rather than asking IT what it hosts. The vendor-run websites guide covers the half of the estate somebody else operates.
Why are agendas and minutes such a persistent problem?
Because they are published on a schedule, forever, usually as PDFs, and often by somebody whose job is not web publishing. A city that fixes its back catalogue without changing how the next agenda is produced will have a fresh backlog within a year.
In detail
The durable fix is the template and the habit: an agenda produced as real text with a proper heading structure rather than a scan, alternative text on anything carrying meaning, tables marked up as tables, and the exported PDF checked before it is posted. Documents people currently use to access or take part in services are squarely covered; genuinely dormant older material may fall under the rule's preexisting-documents exception, which our documents guide explains.
What does a city do with the time that is left?
Measure, sequence, fix, verify. Start from a written baseline across the whole inventory so the size of the job is a number rather than a worry. Sequence by what blocks a resident from finishing a task. Give the findings to whoever maintains each system, in-house or vendor. Then re-test, because a single pre-deadline audit describes a day that has already passed.
That is what the initial assessment and monthly monitoring are for, and why the testing is kept independent: we sell no hosting, design or content services to the entities we monitor, so nobody here is grading their own work.