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ADA Title II Deadline Cheat Sheet

Everything ADA coordinators need to know on one page. Deadlines, penalties, scope, WCAG requirements, and a step-by-step action plan — sourced from ADA.gov and 28 CFR Part 35.

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What's Inside

Five questions every ADA coordinator is asking.

Two Deadlines, No Extensions

April 24, 2026 for entities serving 50,000+ residents. April 26, 2027 for everyone else. Population is based on jurisdiction served, not staff headcount.

Real Penalties

$75,000 first violation, $150,000 each subsequent. Recent TX settlements averaged $52K. Accessibility lawsuits rose 37% in 2024.

PDFs Are Explicitly Covered

Board minutes, budgets, financial aid applications, forms — if it's on your website, it must be WCAG 2.1 AA accessible. 28 CFR §35.104.

WCAG 2.1 Level AA

50 success criteria across four principles: Perceivable, Operable, Understandable, Robust. For PDFs: tagged structure, reading order, alt text, table headers.

5-Step Action Plan

Inventory → Triage → Remediate → Validate → Document. Prioritize by traffic and risk, validate with veraPDF, publish an accessibility statement.

Deadlines

Two deadlines. No extensions.

14 days until the ADA Title II deadline

By April 24, 2026, entities serving 50,000+ residents must make all digital content WCAG 2.1 AA compliant — including every PDF.

14d
April 24, 2026
Entities serving
50,000+ residents
April 26, 2027
All remaining
public entities
$75,000
First violation
federal civil penalty

The DOJ's final rule (published April 24, 2024) requires all state and local government entities to make their web content and mobile apps — including every PDF on their website — conform to WCAG 2.1 Level AA. The population threshold is based on the jurisdiction served, per the U.S. Census Bureau.

Why This Matters

Most government PDFs are not compliant.

Automated accessibility tools catch roughly 30% of WCAG issues. The remaining 70% require human or AI-assisted review — tagged structure, reading order, alt text on figures, table header associations, and font embedding with correct Unicode mappings.

Most government entities have hundreds or thousands of public PDFs. Board minutes, budget documents, permit applications, course catalogs — all explicitly covered under the rule. Manual remediation at scale is not feasible before the deadline.

Need help getting compliant?

AbleLayer AI automates PDF remediation at scale. Upload a document, get a WCAG 2.2 AA compliant version back — validated by veraPDF. Or scan your entire site for free.

Or email us: greg@ablelayer.ai