Title II requires state and local governments to ensure equal access to programs, services, and activities — including digital services.
Legal and Regulatory Foundation
ADA Title II
- U.S. Department of Justice ADA Title II Web and Mobile Accessibility Rule (2024) ↗Full text of the 2024 DOJ final rule establishing WCAG 2.1 Level AA as the technical standard for state and local government digital content.
- ADA.gov Title II Technical Assistance Materials ↗Guidance and plain-language summaries supporting implementation of Title II web accessibility requirements.
DOJ Final Rule on Web and Mobile Accessibility (2024)
Requires conformance to WCAG 2.1 Level AA for state and local government web content and mobile applications.
April 2026 Update: Compliance deadlines were extended by one year. Entities with population ≥50,000: now April 26, 2027. Entities with population <50,000 and special districts: now April 26, 2028. WCAG 2.1 Level AA requirements are unchanged.
Technical Standard: WCAG 2.1 Level AA
The Web Content Accessibility Guidelines (WCAG) are a set of international recommendations for digital accessibility.
It’s important to recognize that WCAG itself is not a legal standard and it is not developed by the US government.
These technical guidelines are instead generated by representatives of interested W3C member organizations, invited experts, and professionals who are interested in making the web more accessible to individuals with disabilities.
WCAG 2.1 Level AA is the technical benchmark referenced by DOJ.
- W3C WCAG 2.1 Quick Reference ↗Customizable, filterable checklist of all WCAG 2.1 success criteria, organized by principle and level.
- W3C Understanding WCAG 2.1 ↗Detailed explanations of each success criterion, including intent, examples, and techniques.
Accessibility Policy and Governance
A formal accessibility policy operationalizes legal obligations and reduces fragmentation across agencies. Effective policies typically address:
- Adoption of WCAG 2.1 Level AA
- Governance structure and oversight
- Defined agency roles
- Procurement alignment
- Monitoring and reporting mechanisms
State Digital Accessibility Policy Models
The following state policies provide practical models that can be reviewed within the context of your own state's laws and governance structures.
Pennsylvania
Pennsylvania Office of Administration Digital Accessibility Policy
Establishes enterprise-wide requirements ensuring all digital content, systems, and services meet WCAG 2.1 AA, supported by clear governance, accountability, and procurement expectations.
View Pennsylvania's Policy ↗Minnesota
Minnesota IT Services – Digital Accessibility Policy
Establishes a statewide standard requiring all government digital systems, content, and services to meet WCAG 2.1 AA and Section 508.
View Minnesota's Policy ↗Washington
Washington State Office of the CIO – Digital Accessibility Policy
Statewide requirements ensuring all digital systems, tools, and content meet WCAG 2.1 AA, with defined governance, reporting, and timelines.
View Washington's Policy ↗
