The U.S. Department of Justice (DOJ) has issued an interim final rule extending the compliance dates for its 2024 Americans with Disabilities Act (ADA) Title II website and mobile application accessibility regulations for state and local governments. This development is noteworthy for anyone watching the long‑running debate over web accessibility standards, as well as the potential implication of this rulemaking for a future DOJ proposed rule governing public accommodations under Title III of the ADA.

Interim Final Rule

In 2024, DOJ finalized its long‑awaited Title II rule requiring state and local governments to make their web content and mobile apps accessible consistent with Web Content Accessibility Guidelines (WCAG) 2.1, Level AA. That rule became effective in June 2024 but set delayed compliance dates: April 24, 2026 for larger entities (population of 50,000 or more), and April 26, 2027 for smaller entities and special districts.

This week, DOJ published an interim final rule that gives public entities an extra year to comply. Large entities now must comply by April 26, 2027, and smaller entities and special districts by April 26, 2028. The substantive requirements of the 2024 rule remain unchanged. DOJ cites resource constraints, staffing limitations, slower-than-expected technological solutions (including limits of generative artificial intelligence for remediation), and litigation risk as reasons for the extension of time.

The interim final rule is effective immediately, but DOJ will be accepting public comments through June 22, 2026.

Our Take

For financial institutions, financial services companies, and other public accommodations in the private sector, this interim final rule does not change current legal obligations, but it is a reminder that DOJ has selected WCAG 2.1, Level AA as the appropriate technical accessibility standard for websites and mobile applications for state and local government entities — which is the standard DOJ could eventually impose under a Title III proposed rule governing public accommodations. While we do not expect a Title III rulemaking under the current Trump Administration, the Title II regulatory framework will remain the likely blueprint if and when a future DOJ decides to address a technical accessibility standard and other issues for private‑sector websites and mobile apps.