What the rule says for small towns
The Department of Justice's Title II web rule (28 CFR Part 35, Subpart H) requires state and local government web content and mobile apps to conform to WCAG 2.1 Level AA. An interim final rule effective April 20, 2026 extended the compliance dates by one year.
Governments with a total population of 50,000 or more must comply by April 26, 2027. Governments with a population under 50,000, and special district governments, have until April 26, 2028. A town's population is based on Census data, so most small towns fall in the later group. Ask your attorney to confirm your date.
The rule covers web content a town publishes or pays someone else to publish, such as the town website, online payment pages, meeting video, and mobile apps. Some narrow exceptions exist, for example for certain archived content and older documents, but material residents use to take part in town services is covered.
Where small town sites usually break
Small town websites tend to share the same weak spots. Meeting packets and agendas arrive as scanned PDFs with no readable text. Photos of the town hall and events have no descriptions. A table of fees is built from an image. The home page is a long wall of links. Old pages from former clerks remain linked and nobody knows who owns them. A payment page was set up years ago by a vendor and nobody has tested it with a keyboard.
None of that requires bad intent. It comes from limited staff and tight budgets. The good news is that a handful of changes fix a lot of it.
A practical order of work
- Scan the home page with the free scanner on this site to see what is visible.
- List what residents actually use. Usually that is payments, agendas and minutes, forms, contact details, and emergency notices.
- Make documents readable. New agendas and minutes should be created as accessible files from the start, not scanned.
- Fix the templates. Headings, link names, form labels, and color contrast can often be fixed once for the whole site.
- Test the key tasks by hand with a keyboard and a screen reader.
- Write down the plan. A dated list of what you checked and fixed shows good faith effort.
Budget and staff realities
We know a town may not have a technology line item. That is why we separate fixes by size. Some are an afternoon of work. Others, such as converting a decade of PDFs, need to be prioritized by what people still use. We scope in writing and tell you what can wait. If your current site cannot be fixed, we will say so, and our municipal website development is built for small staff.
General information, not legal advice. Automated testing cannot establish full ADA compliance or guarantee protection from lawsuits. It finds some kinds of barriers quickly. A person still has to test the rest. Ask a qualified attorney how the law applies to you.
Frequently asked questions
Is a town of 800 people really covered?
The DOJ rule covers state and local governments of every size. Population only affects the deadline. Confirm your exact date with your attorney.
Do volunteers and part time clerks count as the problem?
No one is blamed for it, but the rule applies to the government. Simple posting habits and templates make accessibility much easier for a small staff.
What if our website is run by a vendor?
The rule still applies to content the government makes available through contracts and vendors. Ask your vendor in writing how they test for WCAG 2.1 AA.
Are there any exceptions?
Yes. The rule has narrow exceptions and defenses, including for certain archived content, older documents, and fundamental alteration or undue burden. These have conditions, so rely on your attorney, not a general summary.