The DOJ has extended ADA Title II digital accessibility deadlines, giving public agencies more time, but not less responsibility.

That gap was the focus of PRISM’s recent webinar, “ADA Title II Myths vs. Reality: What Your Agency Actually Needs to Do,” featuring:

  • Brooke Porter, UsableNet
  • John W. Egan and Michael Steinberg, Seyfarth Shaw LLP

If you missed the session, here is what matters most and what your agency should be doing now.

The Core Issue: Awareness Is Not the Problem

Most agencies understand accessibility matters. What is less clear is:

  • What falls under compliance
  • Who owns the work
  • How to prioritize and execute

Delays and unclear ownership are where risk builds.

Updated Timeline: More Time, Same Expectations

Since the webinar, compliance deadlines have been extended:

  • April 26, 2027 for public entities serving populations of 50,000+
  • April 26, 2028 for public entities serving populations less than 50,000 and Special Districts

The standard remains:

  • WCAG 2.1 Level AA, with consideration for WCAG 2.2 to reduce future rework

The requirement has not changed. Only the timeline has.

This extension removes the need to rush, but it does not reduce the amount of work. It creates an opportunity to take a more structured and sustainable approach.

Myth vs. Reality: Where Agencies Get Stuck

Myth 1: “We just need to fix our website.”
Reality: Accessibility applies across your digital ecosystem.

  • Websites
  • Mobile applications
  • Social media
  • Digital documents
  • Third-party platforms

Myth 2: “Our vendor handles accessibility.”
Reality: Your agency is still accountable.

Vendors can support compliance, but they do not take on your risk. Procurement and contract language need to reflect that.

Myth 3: “We can wait until closer to the deadline.”
Reality: That approach creates future bottlenecks.

Remediation takes time. Content inventories are often larger than expected. Coordination across departments does not happen quickly.

Agencies that wait will still end up rushing, just later.

Myth 4: “Most of our existing content is fine.”
Reality: Legacy content is one of the largest workloads.

  • PDFs and forms
  • Public-facing documents
  • Frequently accessed content

Myth 5: “We have time, so risk is low.”
Reality: Risk exists regardless of deadlines.

Even with the extended timeline, other laws still apply to California public entities, including:

  • Section 504 of the Rehabilitation Act
  • California Government Code §11135
  • Unruh Civil Rights Act in certain contexts

Litigation and complaints related to digital accessibility continue.

The extension reduces time pressure, not exposure.

A Note on Exceptions and Defenses

The webinar also clarified when accessibility requirements may be limited due to fundamental alteration or undue financial and administrative burden.

To rely on these, agencies must:

  • Have the determination made by the head of the entity or designee
  • Consider all available resources
  • Document the decision in writing
  • Provide access to the maximum extent possible

These requirements are defined under ADA Title II regulations and require formal documentation.

These determinations can change over time. Budget and staffing shift, so deferred issues should be tracked and revisited.

Exceptions require documentation and ongoing effort. They do not eliminate responsibility.

For agencies looking for practical tools and guidance, explore our Accessibility Resource Library.

Missed the Webinar? Watch It On-Demand

If you were not able to attend, or want to share the session with others in your organization, the full webinar is available on PRISMtv.

Note: PRISMtv requires a separate registration from the PRISM website.  See instructions to register.  

Bottom Line

The deadline extension changes timing, not expectations. Agencies that use this time intentionally will be in a far stronger position than those that wait.