ADA Title II and the WCAG version question
The 2024 rule requires WCAG 2.1 AA, not 2.2. Here is exactly what it says, the current deadlines, and how 2.2 fits in.
This page covers only the WCAG-version question. For the full Title II picture — who must comply, coverage, document obligations, and exceptions — see our sister reference wcag21aa.org.
The rule adopts 2.1, not 2.2
The Department of Justice published its final rule under ADA Title II on April 24, 2024, adopting WCAG 2.1 Level AA as the technical standard for the web content and mobile apps of state and local government entities, codified at 28 CFR 35.200–35.205 (Source: DOJ ADA Title II web rule, ada.gov ) . The rule discusses WCAG 2.2 but explains it adopted 2.1 because 2.2 was finalized (October 2023) after the rule’s comment period had closed.
Compliance deadlines
The original deadlines were extended by roughly one year in an interim final rule published April 20, 2026 (Source: Federal Register, 2026 compliance-date extension ) . The current dates are:
| Entity | Original deadline | Current deadline |
|---|---|---|
| Population 50,000 or more | April 24, 2026 | April 26, 2027 |
| Population under 50,000, or special district government | April 26, 2027 | April 26, 2028 |
Deadlines apply to the WCAG 2.1 AA standard. For the operational detail of what compliance involves, see wcag21aa.org.
Future versions are not automatic
The rule incorporates WCAG 2.1 by a fixed, dated reference. New W3C versions are not pulled in automatically; the Department would have to conduct separate rulemaking to adopt WCAG 2.2 or a later version. As of this review there is no public signal that DOJ is moving Title II to WCAG 2.2, so any claim that “the ADA is about to require 2.2” should be treated as speculation.
Title III names no version
ADA Title III, which covers private businesses and public accommodations, is a separate matter. DOJ takes the position that the ADA applies to the websites of public accommodations, but there is no regulation specifying a WCAG version for them; businesses have flexibility in how they comply (Source: DOJ, Guidance on Web Accessibility and the ADA ) . So no business is required by regulation to meet WCAG 2.2 or even 2.1 under Title III, though courts have often used WCAG 2.1 AA as a practical benchmark.
What this means for 2.2
For a Title II entity, the compliance obligation is WCAG 2.1 AA by the deadlines above. Targeting 2.2 AA is permitted and prudent: it satisfies the required 2.1 AA, adds protections that auditors increasingly check, and means no rework if the standard is updated later. It is a best-practice choice, not a current legal requirement.
A note on legal advice
Common questions
Which WCAG version does the ADA Title II rule require?
WCAG 2.1 Level AA. The Department of Justice adopted WCAG 2.1 AA in its April 2024 final rule for state and local government web content and mobile apps. It did not adopt WCAG 2.2.
What are the ADA Title II web compliance deadlines?
After a 2026 extension, entities serving 50,000 or more people must comply by April 26, 2027, and entities serving fewer than 50,000 people or that are special district governments must comply by April 26, 2028.
Can a Title II entity use WCAG 2.2 instead of 2.1?
Yes. Nothing in the rule prevents meeting a newer standard, and because 2.2 is backward-compatible, conforming to 2.2 AA also satisfies the required 2.1 AA.