In April 2024, the U.S. Department of Justice (“US DOJ”) updated the Americans with Disabilities Act (“ADA”) to establish Website Content Accessibility Guidelines (WCAG)  2.1, Level AA as the technical standard for making public entities’ content of public-facing websites, mobile apps, and digital documents usable for people with visual, auditory, cognitive, and mobility disabilities.  Examples of public-facing content include newsletters, student/parent portals and governing board agendas. 

School districts serving a county or city with a population of 50,000 or more were initially required to have their websites and other public facing online tools updated to ensure compliance with the ADA no later than April 24, 2026.  For school districts serving counties or cities with populations of less than 50,000, compliance was initially due by April 26, 2027. To the extent a school district is an independent school district, WCAG 2.1, Level AA dictates using the population in the 2022 Small Area Income and Poverty Estimates (“SAIPE”).

One week before the first deadline, the US DOJ pre-filed an Interim Final Rule, extending the deadline for school districts with a population of 50,000 or more from April 24, 2026, to April 26, 2027, and those with a population under 50,000’s deadline extended from April 26, 2027 to April 26, 2028. It is anticipated that this Interim Final Rule will take effect on Monday, April 20, 2026.

To the extent you have questions or would like to discuss WCAG’s guidelines or this extension, please do not hesitate to reach out to your F3 attorney.