The DOJ Title II web rule, in plain English

Who is covered

Title II covers state and local government entities. In Texas, that includes cities, counties, school districts, community colleges, public libraries, transit authorities, courts and special districts. The rule also covers content you provide through contracts or other arrangements. That means your bill-pay portal, agenda software, permit system or vendor-hosted website counts, even if a vendor built and runs it.

What the standard requires

WCAG 2.1 Level AA is a set of 50 testable success criteria published by the World Wide Web Consortium (W3C). In everyday terms, it means people can:

• use every link, button and form with a keyboard alone;
• hear a meaningful description of images and documents through a screen reader;
• read text with enough color contrast, and zoom in without content breaking;
• understand form labels and error messages;
• watch videos with captions.

WCAG 2.2, published in 2023, adds a few more criteria. The DOJ rule doesn’t require it, but a site that meets 2.2 AA also meets 2.1 AA, so it’s a good target for new work.

What’s not covered (the exceptions)

The rule has five narrow exceptions. They matter a lot for small bodies with years of PDFs:

1. Archived web content created before your compliance date, kept only for reference, research or recordkeeping, stored in a special archive area, and not changed since it was archived. All four conditions must be true.
2. Preexisting conventional electronic documents (PDF, Word, presentation and spreadsheet files) posted before your compliance date, unless people are currently using them to apply for, access or take part in a service.
3. Content posted by third parties who are not acting under a contract or other arrangement with you, such as public comments. Content a vendor posts for you is still covered.
4. Individualized, password-protected documents such as a resident’s water bill PDF. You may still need to provide an accessible version on request.
5. Preexisting social media posts made before your compliance date.

Using these exceptions well can shrink your workload a great deal. Using them loosely can leave you exposed. Even where an exception applies, you may still owe effective communication to a person who asks for the content in an accessible form.

The pending NFB v. DOJ case

On May 21, 2026, the National Federation of the Blind sued to undo the one-year extension (NFB v. DOJ, No. 1:26-cv-02007, U.S. District Court for the District of Maryland). It argues the agency skipped the required public comment process. As of November 1, 2026, no ruling had been reported, so the extended dates above still apply.

If the court sides with NFB, the original dates could come back. Those were April 24, 2026 for large entities, which has already passed, and April 26, 2027 for smaller entities and special districts. Planning for the earlier date is the safer choice.

A deadline isn’t the start of the risk

Title II has required equal access for decades. People can file DOJ complaints or lawsuits about inaccessible websites today. The dates above are when the specific technical standard applies, not when your obligations begin.