ADA Title II Checklist: WCAG 2.1 AA Steps and New Deadlines

What Is ADA Title II?

Title II of the Americans with Disabilities Act prohibits disability discrimination in the services, programs, and activities of state and local governments. In April 2024 the Department of Justice published a final rule, 89 FR 31320, that set a specific technical standard for their websites and mobile apps.

According to the ADA.gov fact sheet on the web and mobile app rule, that standard is WCAG 2.1 Level AA. Conforming means meeting every Level A and Level AA success criterion in WCAG 2.1, which the web accessibility guide explains principle by principle.

ADA.gov also allows an equivalent alternative to WCAG 2.1 AA only where the government can show it gives the same or better accessibility and usability. For most teams, the practical target is WCAG 2.1 AA itself.

ADA Title II Deadlines After the 2026 Extension

The Department of Justice published an interim final rule extending the compliance dates (91 FR 20902), effective April 20, 2026. Each deadline moved by about one year:

The interim final rule itself says what did and did not change:

• Substance unchanged - the rule "does not alter the substantive requirements adopted in the 2024 final rule, including the scope of coverage."
• Possible future rulemaking - during the extension, the Department "will consider issuing an NPRM" on the substance of the 2024 rule. No such proposal has been published in the Federal Register as of this article's date.
• Obligations continue now - "Regardless of the compliance dates, covered entities have an ongoing obligation" to make services offered through web content and mobile apps accessible.
• Pending lawsuit - the National Federation of the Blind challenged the extension in National Federation of the Blind v. Department of Justice, No. 1:26-cv-02007 (D. Md.), filed May 21, 2026. The docket shows the case still open.

Plan against the dates in the table, and check the Federal Register and the court docket before any milestone, because either can change them.

ADA Title II Web Rule Coverage

ADA.gov lists all state and local governments, their departments and agencies, special purpose districts, and Amtrak and other commuter authorities. In practice that means:

• Public schools, community colleges, and public universities
• Courts, police, and elections offices
• Benefits offices, public hospitals, libraries, and parks
• Public transit authorities

Federal agencies are not covered by Title II. Their websites and software fall under Section 508 of the Rehabilitation Act, which uses WCAG 2.0 Level A and AA instead; the Section 508 compliance guide covers those requirements.

The rule also reaches past the entity's own staff. ADA.gov states that governments that contract with others to provide public services must ensure those contractors follow Title II, so a payment portal, permit system, or learning platform a vendor runs for an agency is part of that agency's compliance.

ADA Title II Exceptions and Their Conditions

The rule has five exceptions, and each comes with conditions. ADA.gov summarizes them as follows:

• Archived web content - exempt only when all four conditions hold: created before the compliance date (or a copy of pre-date physical media), kept only for reference, research, or recordkeeping, stored in a special archive area, and unchanged since it was archived.
• Preexisting conventional electronic documents - Word, PDF, spreadsheet, and presentation files available before the compliance date, unless they are still used to apply for or access a service.
• Third-party content - content posted by members of the public, such as a message board post. Content posted by the government, its contractors, or through tools it provides does not qualify.
• Individualized, password-protected documents - documents about a specific person, property, or account that are password-protected or otherwise secured.
• Preexisting social media posts - posts made before the compliance date.

An exception does not remove the entity's other ADA duties, such as effective communication and reasonable modifications for a person who asks.

ADA Title II Checklist in Seven Steps

Work through these in order. The early steps shrink the scope; the later ones produce the evidence.

• Inventory every domain, subdomain, app, and document set (Step 1).
• Tag each item that meets an exception and record why (Step 2).
• Scan every page against WCAG 2.1 AA (Step 3).
• Manually test the 27 criteria no automated rule covers (Step 4).
• Fix forms, documents, and mobile apps (Step 5).
• Collect a current ACR from every vendor (Step 6).
• Rescan after every release (Step 7).

Step 3: Run Automated Scans Against WCAG 2.1 AA

Automated scans are the fastest way to find missing alt text, low contrast, and unlabeled controls across hundreds of pages. Set the rule set to WCAG 2.1 AA so results match the legal standard.

I ran one scan on the TestMu AI cloud grid against the Selenium Playground input form, with the accessibility capability set to WCAG 2.1 AA, and ran axe-core in the same session for the raw rule output:

Session ID: 0a218be2598812f3aca5d6663e46c5e8
axe-core 4.12.1 | rules passed: 26 | needs review: 2 | rules failed: 2
  SC 1.4.3      color-contrast               serious   1 element(s)
  SC 4.1.2      select-name                  critical  1 element(s)

The TestMu AI dashboard for build 108748957 summarized the run as 5 total issues across 3 issue types against WCAG 2.1 AA:

The page under test is a form, yet the scan reports nothing about 3.3.1 Error Identification or 3.3.3 Error Suggestion, because no axe-core rule covers either. Silence on those rows is not a pass.

WCAG 2.1 AA Checklist: Automated vs Manual

Every WCAG 2.1 Level A and AA success criterion, grouped by area. The automated column lists criteria with at least one axe-core 4.14.0 rule. Those still need a manual check for quality, such as whether alt text is meaningful. The manual column lists criteria with no rule at all.

4.1.1 Parsing is the 50th criterion. W3C has since marked it obsolete, so it needs no testing.

Start This Week With an Inventory and a Baseline Scan

Build the inventory from step 1 this week, then run a sitemap-based WCAG 2.1 AA scan of your highest-traffic domain to get a baseline. The baseline shows where the 22 rule-backed criteria fail, and the 27 manual criteria become your test plan for the months before your deadline.

TestMu AI Accessibility Testing covers WCAG 2.0, 2.1, and 2.2 across web pages, automated test suites, and native apps on real devices, so one platform holds the evidence from every step above.