DOJ Issues Interim Final Rule on Title II Digital Accessibility Compliance Dates
Jeff Bishop
On April 20, 2026, the U.S. Department of Justice published an Interim Final Rule under Title II of the Americans with Disabilities Act addressing the compliance dates for the 2024 web and mobile accessibility rule. The new DOJ action moves the compliance dates back by one year. It does not remove the rule’s accessibility requirements, and it does not change the technical standard adopted in 2024.
In the DOJ’s words, the new Interim Final Rule will “extend the compliance dates,” and “[t]he amendments do not alter any other provisions of the 2024 final rule.”
The 2024 DOJ rule adopted WCAG 2.1 Level AA as the technical standard for the web content and mobile apps that state and local government entities provide or make available. Under the new Interim Final Rule, the compliance date for public entities with a total population of 50,000 or more has moved from April 24, 2026 to April 26, 2027. For public entities with a total population under 50,000, and for special district governments, the date has moved from April 26, 2027 to April 26, 2028.
DOJ guidance published after the 2024 rule explains that a state university uses the population of the state of which it is a part, rather than student enrollment, for purposes of the rule’s timeline. That guidance gives a state university as an example and states that student headcount does not determine the deadline. Arizona’s 2020 Census population was 7,151,502, which means the University of Arizona would generally be understood to fall within the larger-public-entity timeline described above.
It is also important for the University community to understand what has not changed. DOJ states that, regardless of the new compliance dates, covered entities still have an ongoing obligation to make their services, programs, and activities offered through web content and mobile apps accessible under existing Title II requirements. The 2024 rule likewise explains that the underlying obligation to make digital services accessible is not new.
For the University of Arizona community, the message is straightforward: this federal action changes the timeline, but it does not change the direction. Accessibility remains a shared institutional responsibility. Websites, digital documents, course materials, forms, videos, mobile experiences, and third-party digital tools should continue moving toward accessible design and accessible delivery. Accessibility work done now still matters, and it still directly supports equitable participation for students, employees, faculty, and members of the public.
The Interim Final Rule is effective April 20, 2026, and DOJ is accepting public comments through June 22, 2026.
Key facts for the University community
- DOJ has extended the Title II web and mobile app compliance dates by one year.
- The 2024 rule’s technical standard, WCAG 2.1 Level AA, remains in place.
- Existing ADA Title II obligations for accessible digital services continue now.
- Based on DOJ guidance for state universities, the University of Arizona would generally be understood to fall under the larger-public-entity timeline.
Our commitment
The University of Arizona remains committed to inclusive access and to supporting our campus community in building digital experiences that are usable, welcoming, and effective for everyone.