Government
ADA Title II Web Accessibility Deadlines: What They Mean for Translated Content
Under the Department of Justice (DOJ) ADA Title II rule, as extended in April 2026, state and local governments with 50,000 or more residents must make web content and mobile apps meet WCAG 2.1 Level AA by April 26, 2027. Smaller governments and special districts have until April 26, 2028. Translated content is covered too.
- By Xun Yang
- October 5, 2026
- 6 min read
Key takeaways
- State and local governments with 50,000 or more residents must meet WCAG 2.1 Level AA by April 26, 2027.
- Smaller governments and special districts have until April 26, 2028.
- The April 2026 extension changed only the dates. The technical standard is still WCAG 2.1 AA.
- Translated PDFs, notices, videos and right-to-left pages are covered like English content.
In this guide
- What Does the ADA Title II Web Rule Require?
- What Are the New Compliance Dates After the April 2026 Extension?
- Does the Rule Apply to Translated and Multilingual Content?
- What About Section 504 for HHS Funding Recipients?
- What Should Your Multilingual Accessibility Checklist Include?
- Frequently asked questions
Apr 26, 2027
Deadline for governments with 50,000 or more residents
Apr 26, 2028
Deadline for smaller governments and special districts
WCAG 2.1 AA
Technical standard, unchanged by the extension
What Does the ADA Title II Web Rule Require?
DOJ published its web and mobile app accessibility rule on April 24, 2024, as Subpart H of 28 CFR Part 35. It applies to state and local governments, including counties, cities, transit agencies, public schools and public hospitals.
The technical standard is WCAG 2.1 Level AA. The rule covers content an agency provides directly or through contracts. Content produced by a translation vendor is the agency’s responsibility.
The rule has five exceptions: archived content, preexisting conventional electronic documents (such as PDFs), third-party content, individualized password-protected documents and social media posts made before the compliance date.
What Are the New Compliance Dates After the April 2026 Extension?
DOJ published an interim final rule on April 20, 2026. It took effect the same day. It moved each compliance date by about one year.
| Public entity | Original date (2024 rule) | Current date (2026 interim final rule) |
|---|---|---|
| Total population of 50,000 or more | April 24, 2026 | April 26, 2027 |
| Total population under 50,000 | April 26, 2027 | April 26, 2028 |
| Special district governments | April 26, 2027 | April 26, 2028 |
The interim final rule did not change the technical standard. WCAG 2.1 Level AA still applies. The public comment period closed on June 22, 2026.
DOJ stated that it plans future rulemaking on the substantive requirements. As of October 5, 2026, we have not found a newer rule that changes these dates or the standard. Check the Federal Register before you set internal deadlines. DOJ also stated that covered entities have an ongoing obligation to provide accessible services, regardless of the compliance dates.
Does the Rule Apply to Translated and Multilingual Content?
Yes. The rule has no exception for content in languages other than English. A Spanish page, a Vietnamese PDF and a Tagalog video must each meet WCAG 2.1 Level AA on the same schedule as the English version. A person with limited English proficiency may also use a screen reader. Your translated content has to work for that person.
Translated PDFs. The preexisting document exception is narrow. A translated application posted in 2025 that residents still use is not excepted. Translated PDFs posted after your compliance date must conform. Each file needs tags, a logical reading order (WCAG 1.3.2) and the correct document language set in its properties.
Translated notices. Some agencies post translated notices as scanned images. A screen reader cannot read a scanned image of text. Publish notices as accessible HTML or tagged PDF.
Videos. WCAG 2.1 requires captions for prerecorded audio (1.2.2, Level A) and live audio (1.2.4, Level AA). It also requires audio description for prerecorded video (1.2.5, Level AA). A video recorded in Spanish needs Spanish captions. Translated subtitles usually leave out sound cues, so they may not meet the captions criterion.
Right-to-left languages. Arabic, Hebrew, Persian, Urdu and Pashto read from right to left. The W3C recommends setting dir="rtl" on the html element in markup, not through CSS. Test reading order, forms and mixed text with numbers.
Language tags. WCAG 3.1.1 (Level A) requires the default language of each page to be programmatically determined. WCAG 3.1.2 (Level AA) requires the same for each passage or phrase in a different language. Without correct tags, a screen reader may read Chinese text with English pronunciation rules. Use BCP 47 codes such as es, vi and zh-Hant, and tag language menu links, for example <a lang="es">Español</a>.
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What About Section 504 for HHS Funding Recipients?
The Department of Health and Human Services (HHS) Office for Civil Rights published an updated Section 504 rule in May 2024. It applies to recipients of HHS funding, such as hospitals, clinics, health plans and state health agencies. Its web and mobile requirements at 45 CFR 84.84 also use WCAG 2.1 Level AA.
The original deadline for recipients with 15 or more employees was May 11, 2026. In May 2026, HHS issued an interim final rule that extended the dates by one year:
| HHS recipient size | Original date | Current date |
|---|---|---|
| 15 or more employees | May 11, 2026 | May 11, 2027 |
| Fewer than 15 employees | May 10, 2027 | May 10, 2028 |
HHS also plans future rulemaking on the substantive requirements. A public hospital may be covered by both Title II and Section 504. Track both sets of dates.
What Should Your Multilingual Accessibility Checklist Include?
| # | Task | What to check | Reference |
|---|---|---|---|
| 1 | Inventory every language version | Pages, PDFs, videos and app screens in each language | 28 CFR 35.200 |
| 2 | Flag documents in active use | Translated forms and notices people use to apply or participate | 28 CFR 35.201(b) |
| 3 | Set page language | lang attribute on the html element |
WCAG 3.1.1 |
| 4 | Tag language changes | Passages, phrases and language menu links | WCAG 3.1.2 |
| 5 | Set text direction | dir="rtl" in markup for RTL pages |
W3C guidance |
| 6 | Tag translated PDFs | Tags, reading order, document language, alt text | WCAG 1.1.1, 1.3.2 |
| 7 | Caption videos | Same-language captions with sound cues | WCAG 1.2.2, 1.2.4 |
| 8 | Add audio description | Prerecorded video in each language | WCAG 1.2.5 |
| 9 | Check contrast and resizing | Non-Latin scripts at 200 percent zoom | WCAG 1.4.3, 1.4.4 |
| 10 | Update vendor contracts | Require WCAG 2.1 AA deliverables for all languages | 28 CFR 35.200(a) |
Frequently Asked Questions
Did the April 2026 extension change the accessibility standard?
No. The DOJ interim final rule changed only the compliance dates. WCAG 2.1 Level AA remains the technical standard for state and local government web content and mobile apps. DOJ has said it may propose changes to the substantive requirements later, so monitor the Federal Register while you continue your accessibility work.
Are translated PDFs posted before the deadline exempt?
Only in some cases. The exception covers PDFs and similar files posted before your compliance date. It does not apply if people still use the document to apply for, gain access to or participate in a program. A translated benefits application that is still in use must be made accessible. Translated PDFs posted after the deadline must conform.
Do translated subtitles count as captions?
Not always. WCAG captions represent both speech and the non-speech audio needed to understand the content, such as sound cues and speaker changes. Translated subtitles usually show only dialogue. Provide captions in the language spoken in the video, then add translated subtitles as part of your language access plan.
Does a public hospital need to follow both rules?
Often, yes. A public hospital is a state or local government entity under ADA Title II. If it also receives HHS funding, such as Medicaid payments, it is a Section 504 recipient. Both rules use WCAG 2.1 Level AA. Under the current interim final rules, the deadlines fall in 2027 or 2028 depending on size.
How AsianText Helps
Accessible Translated Content, Ready Before Your Deadline
AsianText produces translated content that is built to meet WCAG 2.1 AA. Our Accessibility & Alternative Formats team creates tagged accessible PDFs, large print, braille, audio and ASL video. Our Multilingual Desktop Publishing specialists handle right-to-left layouts and language tagging. We provide same-language captions and translated subtitles through Voice-Over, Subtitling & Transcription. Learn more about our government expertise. Contact AsianText to review your multilingual content before your deadline.
This article provides general information, not legal advice. Last updated October 5, 2026.
Written by Xun Yang
Part of the AsianText team, writing about language access, translation and interpreting for government, healthcare and life sciences.
Sources
- DOJ interim final rule extending ADA Title II web compliance dates (Federal Register, April 20, 2026)
- Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps (ADA.gov)
- 28 CFR Part 35, Subpart H: Web and Mobile Accessibility (eCFR)
- HHS interim final rule extending Section 504 web compliance dates (Federal Register, May 2026)
- Web Content Accessibility Guidelines (WCAG) 2.1 (W3C)
- Understanding Success Criterion 3.1.2: Language of Parts (W3C)
- Structural Markup and Right-to-Left Text in HTML (W3C Internationalization)
- Declaring Language in HTML (W3C Internationalization)
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