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The ADA website rule for Texas local governments

A federal rule, often called the ADA Title II web rule, requires state and local government websites and mobile apps to meet a technical standard called WCAG 2.1 Level AA, with a few exceptions. Governments with a total population of 50,000 or more must comply by April 26, 2027. Smaller governments and all special districts have until April 26, 2028.

This page answers common questions about the rule, in plain language, for Texas cities, counties and special districts. It is a summary, not legal advice. The sources are listed at the bottom.

Who has to follow the rule?

Every state and local government, no matter how small. A town of 3,000 people is covered. Small towns get more time, not an exemption. This includes:

  • Cities and towns, and every department inside them.
  • Counties.
  • Special districts, such as water, utility, hospital and emergency services districts.
  • Public school districts and public colleges.

Your government is also responsible for websites, apps and online tools that contractors and vendors provide for it, such as a bill payment portal or an agenda system, even if the vendor built them or runs them.

When is the deadline?

  • April 26, 2027 for governments with a total population of 50,000 or more.
  • April 26, 2028 for governments with a total population under 50,000.
  • April 26, 2028 for special districts of any size.

For most cities and counties, population is the 2020 Census count. Independent school districts use the Census Bureau's school district estimates, and a department of a government uses the population of the government it belongs to. The rule calls your deadline your "compliance date."

On April 20, 2026, the U.S. Department of Justice pushed these deadlines back about one year, so older articles may show earlier dates. The extension is being challenged in federal court, and the Justice Department has said it may propose changes to the rule, so check ADA.gov before relying on any date.

Hospital districts and others that receive funding from the U.S. Department of Health and Human Services also fall under a separate HHS rule. For those with 15 or more employees, its deadline is May 11, 2027.

A deadline is not a pass until then. The ADA already applies today: if someone with a disability can't use part of your website, you must help them get the same information or service another way.

What if we miss the deadline?

The rule does not set fines. People can file a complaint with the U.S. Department of Justice or file a lawsuit. A government may then have to fix its website under a settlement or court order, and may have to pay legal costs.

What standard does the rule use?

WCAG 2.1 Level AA, the Web Content Accessibility Guidelines written by the World Wide Web Consortium (W3C). It is a set of about 50 checks. Level AA means meeting both the basic level (A) and the next level up (AA). Common ones:

  • Images have text descriptions, so people using screen readers (software that reads the screen aloud) know what they show.
  • Form fields have labels, so people know what to type.
  • Text has enough contrast with its background to be read by people with low vision.
  • Everything works with a keyboard alone, without a mouse.
  • Videos have captions.

WCAG 2.2 is a newer version that the rule does not require.

Does the rule cover PDFs and other documents?

Yes. Documents on your website, such as agendas, minutes, forms and reports, are covered. Scanned paper pages saved as PDFs usually can't be read by screen readers, so they need to be fixed or replaced.

There are three narrow exceptions:

  • PDF, Word, PowerPoint and spreadsheet files posted before your deadline, but only if no one uses them now to apply for, get access to or take part in a service. A permit application or fee schedule is still covered, and so is an older document you update after your deadline.
  • Archived content, if all four of these are true: it was created before your deadline (or is a copy of an older paper record), it is kept only for reference, research or recordkeeping, it is in a section clearly labeled as an archive, and it has not been changed since it was archived. Moving new content into an archive does not make it exempt.
  • Documents about one person, their property or their account, such as a utility bill, if they are PDF, Word, PowerPoint or spreadsheet files and are password-protected or otherwise secured.

What about social media and comments from the public?

  • Old posts: social media posts made before your deadline are exempt.
  • New posts: anything your government posts on social media on or after your deadline is covered. Add image descriptions and captions.
  • Comments and other content posted by members of the public are exempt.
  • Content your government or its contractors post is covered, and so are the tools the public uses to post, such as a comment form or message board.

Exempt does not mean ignore. If a person with a disability asks for an exempt document or post in a form they can use, you still have to provide it.

Will an accessibility toolbar or overlay make our website compliant?

No. Overlays are add-on tools that put an accessibility icon or toolbar on your site. They do not fix the problems in your pages and documents, which is what the rule covers. In 2025 the Federal Trade Commission ordered one overlay company to pay $1 million over claims that its tool could make any website meet WCAG.

What if we can't afford to fix everything?

A small budget is not an exemption. The rule has a narrow "undue burden" limit: your top official or their designee must decide it in writing, and you must still make as much accessible as you can.

Where should a small city start?

  1. Check your website for accessibility problems, starting with the pages people use most: the home page, paying a bill, agendas, permits and contact information.
  2. Fix the parts every page shares first, such as the header, menu and footer. One fix there clears many pages.
  3. List the documents and forms people use to get services, and make those accessible first.
  4. Ask your website, payment and agenda vendors for an Accessibility Conformance Report (often called a VPAT) and the date they will meet WCAG 2.1 Level AA. Put that requirement in new and renewed contracts.
  5. Publish an accessibility statement with a way for people to report problems. The rule does not require one, but it helps you find problems early.
  6. Check again after fixes, and before your deadline.

How Site Unseen can help

Our Website Accessibility Scan checks up to 25 pages of your website, starting from your home page, for $250. You get a plain-language Word report and a 30-minute call to walk through the results. Problems that matter only under WCAG 2.2 are labeled "WCAG 2.2 only", so you can fix what the rule requires first. A follow-up scan after fixes is $75. Larger websites, or vendor sites at a different address such as a bill payment portal, are priced by quote.

The scan is automated. It finds common problems, not every one, so a clean report does not mean your website meets the rule. It checks web pages only, not PDFs or mobile apps yet, so check those another way. It is not legal advice or a certification.

Or email jose@siteunseen.net.