ADA Title II · Pennsylvania
What the ADA Title II web rule means for Pennsylvania local government.
A plain-language guide for county, municipal, authority, and school district staff: what the rule requires, when it applies to you, how conformance is actually shown, and what to do before your date.
Updated · 6 minute read
In short
- Web content and mobile apps from Pennsylvania counties, municipalities, authorities, and school districts must conform to WCAG 2.1 Level AA.
- Entities serving 50,000 or more must comply by April 26, 2027. Smaller entities and special districts have until April 26, 2028.
- The rule sets a result, not a paperwork requirement. No certificate, VPAT, or mandated audit is required, but a documented testing record is your best evidence.
01What the rule requires
One technical standard for everything you publish online.
Title II of the Americans with Disabilities Act has always required state and local governments to make their services accessible. In April 2024 the Department of Justice added a specific technical standard for the web. WCAG 2.1 Level AA now applies to the web content and mobile apps a public entity provides or makes available, codified at 28 CFR Part 35, Subpart H.
The rule covers content a vendor builds or hosts for you as well as your own. It applies whether or not anyone has complained. In practice, WCAG 2.1 AA means people can use your site by keyboard alone and with a screen reader, at 200% zoom, and without relying on color or sound. It also means images have text alternatives, forms have labels and readable errors, and videos have captions.
02Your date in Pennsylvania
Population decides the deadline.
The 2024 rule set compliance dates in 2026 and 2027. On April 20, 2026, an Interim Final Rule moved each date back one year. DOJ said it fully anticipates enforcing the new dates.
After your date, the obligation continues. New content has to conform as it goes up.
| Entity | Comply by |
|---|---|
| Counties of 50,000 or more44 of Pennsylvania’s 67 counties, Lancaster County among them. | Apr 26 2027 |
| Cities and townships of 50,000 or moreA short list that includes the City of Lancaster. Check your 2020 Census population. | Apr 26 2027 |
| Boroughs, townships, and cities under 50,000Nearly every municipality in the Commonwealth. | Apr 26 2028 |
| Counties under 50,000Pennsylvania’s 23 smaller counties. | Apr 26 2028 |
| Special district governmentsTypically includes municipal authorities, such as water, sewer, and parking authorities, regardless of the population they serve. | Apr 26 2028 |
03What counts
More than the homepage, and fewer exceptions than people hope.
Covered
- Every page on your website, including subdomains and microsites
- PDFs, Word files, and spreadsheets posted on or after your compliance date
- Older documents people still use to apply for or access a service, like permit applications and license forms
- Agenda and minutes platforms, payment portals, GIS maps, calendars, and online forms from outside vendors
- Video and audio, which need captions and, where needed, audio description
- Mobile apps you provide or arrange, including parking and payment apps
The five exceptions
- Archived content
- Created before your compliance date, kept only for reference or recordkeeping, stored in a clearly marked archive, and unchanged since.
- Preexisting documents
- PDFs and office files posted before your date. This exception does not apply if the public still uses the document to apply for or access a service.
- Content posted by the public
- Comments and posts from residents. Your own vendors and contractors do not count as the public.
- Individual secured documents
- Password-protected files about one person, property, or account, such as a resident’s water bill PDF.
- Older social media posts
- Posts published before your compliance date.
Exceptions do not end your obligation to a resident who asks. If someone with a disability needs excepted content, you still owe them effective communication, which means providing it in a format they can use, promptly.
04How conformance is shown
There is no certificate. The site itself is the evidence.
The rule does not require a third-party audit, a set testing schedule, a published accessibility statement, or a VPAT. It requires that your content conform. If a resident files a complaint or DOJ opens an inquiry, the question is whether your pages and documents actually meet WCAG 2.1 AA.
Records still matter. The rule allows an entity to show that a failure was so minor it did not affect anyone's access, but the entity has to prove it. A dated record of testing, findings, and fixes is how you make that case. It also shows good faith in a complaint.
Where a VPAT fits
A VPAT is a template vendors use to document how their product conforms. Once filled in, it is called an Accessibility Conformance Report, or ACR. ACRs come from federal procurement under Section 508. Their best use for you is evaluating the agenda platforms, payment portals, and other tools you buy. An ACR is a self-reported claim, not proof. Test the product before you rely on it.
A testing program we recommend
- Automated and manual checks every quarter, and after any redesign or new feature
- An independent evaluation once a year, from someone who did not build the site
- A dated public accessibility statement and a way to report barriers
- A log of what was found, when, and how it was fixed
These are best practice, not legal requirements.
05What to do now
Eight steps you can start this quarter.
01
Confirm your date
Use your 2020 Census population. A department such as a police force or library uses the population of the government it belongs to. Most Pennsylvania school districts are independent districts, so their date follows the Census Bureau’s Small Area Income and Poverty Estimates.
02
Inventory what you publish
List your main site, subdomains, vendor portals, mobile apps, and document libraries. Most entities find more than they expected, especially years of agenda packets.
03
Get a baseline audit
An evaluation that combines automated scanning with manual keyboard and screen reader testing shows where you stand and what to fix first. Automated tools alone check only about a third of WCAG.
04
Fix the tasks residents depend on
Start with paying a bill, applying for a permit, finding meeting agendas, reporting a problem, and contacting staff. Then work outward.
05
Stop adding new barriers
Train the staff who post content. Publish information as web pages where you can, and make every new PDF accessible before it goes up. Documents posted after your date get no exception.
06
Hold your vendors to the standard
Ask each vendor for a current Accessibility Conformance Report against WCAG 2.1 AA, and add conformance and remediation terms to contracts at renewal. Content they provide for you is your responsibility.
07
Archive deliberately
Move outdated material into a clearly labeled archive section and leave it unchanged, so it qualifies for the archived content exception.
08
Keep testing, and keep records
Check after significant changes and on a regular schedule, publish an accessibility statement, give residents a way to report barriers, and respond quickly when they do.
06Where Bluenilla can help
Two ways to start, depending on who maintains your site.
You have a web team
Get a free audit and hand it to them.
We evaluate your key pages against WCAG 2.1 AA and give you a report to share with your developer or web manager, ranked by what to fix first. No cost and no obligation.
You want it off your plate
Talk about a redesign.
We rebuild your site to WCAG 2.1 AA and take over as your web developer. That includes keeping it conformant, keeping the testing record, and remediating your PDFs.
Sources
- Final rule, 89 Fed. Reg. 31320 (April 24, 2024) · 28 CFR Part 35, Subpart H
- Interim Final Rule, 91 Fed. Reg. 20902 (April 20, 2026)
- DOJ fact sheet on the web and mobile app rule
- W3C, Web Content Accessibility Guidelines 2.1
This guide is general information, not legal advice. Confirm how the rule applies to your entity with your solicitor.