Deadlines and requirements

Last reviewed:

What the ADA Title II web rule and EPA's revised Consumer Confidence Report rule ask of utility districts and other local governments, in plain language.

We are not attorneys. This information is general guidance, not legal advice; consult your district's counsel.

Key dates

  1. ADA Title II deadline for larger entities

    Public entities serving 50,000 or more people: websites, documents and apps must meet WCAG 2.1 AA.

  2. First revised Consumer Confidence Report due

    The first report under EPA's revised rule, with the new summary section up front.

  3. Second report due for larger systems

    Systems serving 10,000 or more people deliver a second report, and twice a year after that.

  4. ADA Title II deadline for special districts

    Utility districts, other special districts and entities serving under 50,000 people: websites, documents and apps must meet WCAG 2.1 AA.

The ADA Title II web rule

Title II of the Americans with Disabilities Act (ADA Title II) is the part of the law that covers state and local governments. In 2024, the U.S. Department of Justice issued a rule under Title II (28 CFR Part 35, Subpart H) that sets a specific technical standard for government websites and mobile apps: WCAG 2.1 Level AA.

What WCAG 2.1 Level AA means

WCAG, the Web Content Accessibility Guidelines, is an international standard for making web content usable by people with disabilities. Level AA is a set of specific, testable requirements. For example:

  • Images have text descriptions that a screen reader can read aloud.
  • Text has enough contrast with its background to be read easily.
  • Every link, button and form works with a keyboard alone.
  • Forms have clear labels and helpful error messages.
  • Pages still work when text is enlarged or the screen is zoomed.
  • Videos have captions.

Who it covers

Every state and local government entity, including special district governments such as water and wastewater utility districts, fire districts and library districts.

When

  • Special district governments, including utility districts, whatever their size: April 26, 2028.
  • Other public entities serving fewer than 50,000 people: April 26, 2028.
  • Public entities serving 50,000 or more people: April 26, 2027.

These dates were extended by one year by the DOJ Interim Final Rule of April 20, 2026.

What it covers

  • Every page of your website.
  • Documents posted on your website, such as PDFs, Word files, spreadsheets and presentations.
  • Mobile apps your district offers.
  • Content you provide through contracts, licenses or other arrangements with vendors, such as an online bill-pay portal, outage map or agenda system. If a company posts content for you, it counts as yours.

Exceptions, and their conditions

The rule has five exceptions. Each one has conditions, and content that fails any condition must meet the standard. Your district's attorney can help you decide how they apply.

  1. Archived web content. Content created before your compliance date, kept only for reference, research or recordkeeping, stored in a clearly marked archive area, and not changed since it was archived.
  2. Older documents. PDFs, word processing files, presentations and spreadsheets posted before your compliance date, unless residents currently use them to apply for, get or take part in your services. A service application still in use, for example, must be made accessible.
  3. Content posted by the public. Content that members of the public post on your site, such as comments. This does not cover vendors or contractors working for you.
  4. Individual, password-protected documents. Documents about one specific person, property or account, such as a customer's own bill in a secure portal. You still need to provide an accessible version when someone asks.
  5. Older social media posts. Posts on your district's social media accounts made before your compliance date.

The rule also includes narrow provisions for situations where full compliance would be an undue burden or fundamentally change a service. These are limited and require specific steps; ask your attorney before relying on them.

The rule may change

In the Interim Final Rule of April 20, 2026, the Department of Justice extended the deadlines and said it plans further rulemaking that could change parts of the 2024 rule. Until that happens, the dates above and the WCAG 2.1 Level AA standard are in effect. We review this page regularly and will update it when anything changes.

Official sources

EPA's revised Consumer Confidence Report rule

A Consumer Confidence Report (CCR) is the annual water quality report that every community water system sends its customers. In 2024, EPA revised the rule to make these reports easier to read and use. The changes apply to reports delivered starting in 2027.

What's changing

  • A summary up front. Every report must start with a short summary of key information, including how to request a paper copy and how to get language assistance.
  • More information about lead and the system's efforts to reduce it.
  • Twice a year for larger systems. Systems serving 10,000 or more people deliver a second report each year.

When

  • First report under the revised rule: July 1, 2027.
  • Second report for systems serving 10,000 or more people: December 31, 2027, and twice a year after that.

Where accessibility comes in

The report you post on your website is web content under the ADA Title II rule, so it needs to meet WCAG 2.1 Level AA too. Designing the new report to be accessible from the start is simpler than fixing it afterward.

Tennessee

Tennessee districts should confirm state-specific CCR requirements with TDEC, the Tennessee Department of Environment and Conservation. Read TDEC's Consumer Confidence Report guidance (PDF).

Official sources

Frequently asked questions

We're a small district. Does this apply to us?

Yes. The rule covers special district governments, including utility districts, whatever their size. Your deadline is April 26, 2028.

An outside company runs our website. Who is responsible?

The district. Content provided through contracts counts as the district's content. Your vendor can do the work, but the district is responsible for making sure it gets done.

What about our online bill-pay portal?

It's covered too, because you provide it to the public through a contract. Ask the vendor for an accessibility conformance report, often called a VPAT or ACR, which describes how well the product meets the standard.

Do we have to fix every old PDF?

Not necessarily. Documents posted before your compliance date may fall under an exception, but only if residents aren't using them to get service. An inventory of your documents is the best first step: archive what you can, turn frequently used documents into web pages, and fix the rest.

Can we install an accessibility widget or overlay instead?

No overlay makes a website conform to WCAG 2.1 Level AA on its own. The work has to be done in the website and the documents themselves.

What happens if we miss the deadline?

The Department of Justice enforces the ADA, and people can also file complaints or lawsuits. Talk with your district's attorney about your situation. Whatever you decide, a written record of your progress is worth keeping.

If the rule might change, should we wait?

That's a decision for your board and attorney. The current dates are in effect until a new rule says otherwise. Much of the work, such as cleaning up old documents and fixing forms, makes your website easier for every resident to use whatever happens.

Is this legal advice?

No. We are not attorneys. This information is general guidance, not legal advice; consult your district's counsel.