Your website has a federal accessibility deadline. Here is what actually counts.
The Department of Justice now requires local government web content to meet WCAG 2.1 Level AA. The deadlines, the exemptions, and what a clerk should actually do about it, with sources.
The short version
In April 2024 the Department of Justice published a rule under Title II of the Americans with Disabilities Act: state and local government web content and mobile apps must meet a specific technical accessibility standard, WCAG 2.1 Level AA. In April 2026 DOJ pushed each deadline back one year. For most Michigan cities, villages, and townships, the date that matters is now April 26, 2028.
This is not a suggestion or a best practice. It is a regulation with a compliance date, published in the Federal Register, and it names the exact standard your website content has to meet.
- What
- Web content + mobile apps must meet WCAG 2.1 Level AA (28 CFR 35.200)
- Who
- Every state and local government entity, all sizes
- 50,000+ population
- April 26, 2027
- Under 50,000 + special districts
- April 26, 2028
- Deadline source
- DOJ interim final rule, April 20, 2026 (91 FR 20902)
- Vendor content
- Covered when posted on your behalf, per ADA.gov guidance
What counts as your web content
More than the website itself. The rule covers what your government provides or makes available on the web, directly or through a contractor or vendor posting on your behalf. For a clerk’s office that means the things you publish every week: meeting agendas and minutes, public notices, posted records and packets, forms residents fill out, and meeting video. Prerecorded video needs captions. Documents need to be readable by a screen reader, which a scanned image-only PDF is not.
The practical translation: your website vendor can make the site shell accessible, but the content flowing onto the site every week is where compliance is won or lost, and that content is your office’s.
What is exempt (this part is good news)
The rule is mostly forward-looking. It has explicit exceptions for archived web content and for conventional documents (PDFs, Word files, spreadsheets) posted before your compliance date, as long as they are not currently used to apply for or access your services. You do not have to remediate fifteen years of scanned minutes. What you post after your deadline is what has to conform.
That is why the sensible response is not a one-time remediation project. It is making sure the tools you publish with produce accessible content by default, so compliance is a side effect of doing your job.
One honest caveat
When DOJ extended the deadlines in April 2026, it also said it may propose further rulemaking on the substance of the rule. So describe this as the rule as it stands today, not a certainty carved in stone. Two things do not change either way: the ADA’s general obligation to communicate effectively with residents with disabilities already exists, and content that every resident can read is simply better service from a public office.
Everything Dekree publishes for your government, the public records portal, the widgets embedded on your own website, agendas and minutes as web pages, the FOIA form, meeting pages with searchable transcripts, conforms to WCAG 2.1 Level AA. We verify it with automated checks on every public page, keyboard-only testing, and screen reader testing, and a formal conformance report is available for your procurement file. Even the brand colors your office picks are adjusted automatically so text stays readable. For the records side of your website, the 2028 box is already checked.
Verify it yourself
Do not take a vendor’s word for any of this, ours included. The primary sources: DOJ’s plain-language fact sheet on the web rule (deadlines, exceptions, and the vendor-content language), first steps for compliance, and the April 2026 deadline extension as published in the Federal Register. If your city attorney wants the regulation itself, it is 28 CFR part 35, subpart H. And if you want to see what an accessible records portal looks like in practice, we will show you on your own records.
Common questions
When does my city or township have to comply with the ADA website rule?
Under the current DOJ rule, governments serving 50,000 or more people must meet WCAG 2.1 Level AA by April 26, 2027. Governments under 50,000 and special districts have until April 26, 2028. DOJ extended both dates by one year in April 2026.
Does the rule apply to small townships?
Yes. The rule applies to every state and local government entity regardless of size. Smaller governments simply get the later deadline, April 26, 2028, and the same WCAG 2.1 Level AA standard.
Do old documents on our website have to be made accessible?
Mostly no. The rule exempts archived web content and conventional documents like PDFs posted before your compliance date, unless a document is currently used to apply for or access your services. New content posted after your deadline has to conform.
Are agendas, minutes, and meeting videos covered?
Yes. The rule covers web content your government provides directly or through a vendor posting on its behalf. Agendas, minutes, notices, posted records, and meeting videos on your website all count, and prerecorded video needs captions.
If a vendor runs our website or posts our records, are we off the hook?
No. DOJ says your government is responsible for content a vendor or contractor provides or posts on its behalf. You cannot outsource the obligation, but you can choose tools that publish accessible content by default.
Could the rule still change?
Possibly. When DOJ extended the deadlines in April 2026 it said it may propose further rulemaking on the substance of the rule. Nothing has been rescinded, and the general ADA obligation to communicate effectively with residents exists today either way.
This article is educational information for Michigan public bodies, current as of the publication date. It is not legal advice, and statutes and court decisions change. Confirm specifics with your municipal attorney. Statute text: legislature.mi.gov.