ADA Title II, a guide for towns
The Justice Department's Title II rule says a town's website, documents, online forms and apps have to meet WCAG 2.1 AA, and most New Jersey towns have until April 26, 2028. This guide covers which date applies, what the rule reaches, what it leaves out and an order to work in. I'm not a lawyer, so the legal calls stay with your town attorney.
The rule in brief
The rule sets one standard and two deadlines, and population decides which one is yours. Most New Jersey municipalities are under 50,000, but check your own count.
April 26, 2027
Towns, counties and other public entities with a total population of 50,000 or more
April 26, 2028
Public entities under 50,000, and special district governments
The original dates were a year earlier. The Justice Department moved them in April 2026, and that extension is being challenged in court.
Dates checked on 5 November 2026 against the Justice Department's interim final rule in the Federal Register of April 20, 2026 (WCAG 2.1 Level AA).
The court case
In May 2026 the National Federation of the Blind sued the Justice Department in federal court in Maryland, asking the judge to set the extension aside. If that happens, the earlier dates could come back. As of early November 2026 I couldn't find a ruling.
You can read the extension itself in the Federal Register. I re-check it and the case before every quote, and I'll update this page when either changes. The safe plan is to work as if the date is sooner than it says.
What it covers
The rule reaches everything a town offers people online. That's the website, but also the PDFs and Word files posted on it, online forms, video, a mobile app if you have one, and services a vendor runs for the town under a contract, like an agenda system or a bill payment portal.
WCAG 2.1 AA sounds technical. In plain terms it asks for things like these.
- Images that carry information have a text description a screen reader can read out.
- Videos have captions, and recorded meetings posted as video count.
- Every link, button and form works with a keyboard alone, in a sensible order.
- Text has enough contrast to read, and still works when someone zooms in.
- Form fields have labels, and errors say what went wrong in words.
- Documents have real headings and readable text, not a scanned picture of a page.
What it leaves out
The rule doesn't make towns fix every old file on day one. It lists five exceptions, and each one only applies when its conditions are met.
- Archived content. Made before your compliance date, kept only for reference or records, stored in an area marked as an archive, and not changed since.
- Older documents. PDFs, word processing files, presentations and spreadsheets posted before your date, unless people still use them to apply for or take part in a service.
- Posts by others. Content a third party posts on your site, when that party isn't working for the town under a contract or other arrangement.
- Individual documents behind a login. Files about one person, their property or their account, like a tax bill, reached through a password-protected system.
- Older social media posts. Posts made before your compliance date.
Two things catch towns out. A permit application posted as a PDF years ago is still in scope if people use it today. And an exception doesn't end the duty to help someone who asks, so a resident who needs one of those files in a form they can use should still get it. Which exceptions your town relies on is for your attorney to decide.
Where to start
Fix what residents need most, and stop new problems going up, before working through the archive.
Do these first
- List your pages, documents, forms and vendor systems
- Fix bill pay, meeting pages and permit forms
- Post new agendas and minutes as web pages or tagged PDFs
- Ask each vendor in writing how and when they'll meet WCAG 2.1 AA
- Move old files into a marked archive and leave them unchanged
Don't count on these
- An overlay toolbar or plugin added on top of the site
- A vendor saying it's accessible without showing a test
- An automated scan alone, which misses much of what WCAG asks
- Fixing old files while new ones keep going up the old way
- A certificate that says the site is compliant
Your vendor
Most town sites are run by a vendor. Send them these in writing and keep the answers.
- Which WCAG version and level do you test against, and when did you last test our site?
- Can we see the results by page, and which issues are still open?
- Does the editor ask staff for image descriptions and keep headings in order?
- Which of the services you host for us, like forms or payments, have been tested, and by whom?
- If we leave, can we take our content and documents with us?
How I can help
I'm Rob, and I run Senova Systems, a small software studio in central New Jersey. For towns I check the site by hand with a keyboard and a screen reader as well as automated tools, fix what I find or rebuild where that makes more sense, and hand over a dated report you keep. The page for New Jersey towns covers how that works and what you get.
If cost is the next question, the guide to what custom software costs explains what moves the price, and our own accessibility statement shows how this site is tested.
Your quote
Every town gets its own written quote before any work starts. A list of your main pages, how many documents you post a month and which vendors run parts of the site makes it much more accurate.
The scope
What we'll build, page by page or screen by screen, and what's out of scope, in plain words.
A fixed price
One price for the agreed scope. It only changes if the scope does, and only with your OK.
A dated timeline
When the first preview arrives, when each part lands and when you go live.
What you'll own
The code, the design and every account, in your name from day one.
Running costs, itemised
Hosting, email and any other services listed one by one, paid to each provider at cost.
FAQ
If you're a state or local government, yes. That includes municipalities and counties, and also other public bodies like school boards and authorities. Your population, as the Census Bureau counts it, decides which of the two dates you get.