English
Get the app

Braillito Maps · Accessibility guides

ADA Title II: what state and local governments have to make accessible

Title II of the Americans with Disabilities Act, often searched as ADA Title 2, is the part that applies to state and local governments. Its regulation, 28 CFR part 35, covers all the services, programs and activities a public entity provides or makes available (ADA Title II regulations, 28 CFR 35.102(a)), so it reaches the city hall and the courthouse, but also the public library, the park, the pool, the sidewalk and the city’s website. Businesses open to the public follow Title III instead, explained in ADA compliance. This guide goes through what Title II asks for, from the oldest building to the newest app, with the section of the regulation behind each rule and the web accessibility deadlines in force today.

This guide summarizes the sources it cites; it is not legal advice. The official texts are the reference.

Who Title II covers

The regulation calls the governments it covers public entities. A public entity is (ADA Title II regulations, 28 CFR 35.104):

  • any state or local government, such as a state, a county, a city or a town;
  • any department, agency, special purpose district or other instrumentality of a state or local government; the definitions of the same section name counties, municipalities, townships and independent school districts among public entities;
  • Amtrak and commuter rail authorities, the National Railroad Passenger Corporation and any commuter authority.

The definition sets no minimum size. What changes with size are some paperwork duties, described below, and the web deadline. Public transportation is the main exception: to the extent that transit services are covered by subtitle B of Title II, they are not subject to part 35 (ADA Title II regulations, 28 CFR 35.102(b)), and they are not summarized here.

The practical difference with Title III is the starting point. A business open to the public removes barriers in an existing building where that is readily achievable, easily accomplishable without much difficulty or expense (ADA Title III regulations, 28 CFR 36.304(a)). A public entity looks at each of its programs as a whole and asks whether it is open to people with disabilities, and that question applies even to programs housed in buildings that were never altered (ADA Title II regulations, 28 CFR 35.150(a)).

Existing buildings: program access

The central rule for older facilities is program access. A public entity has to operate each service, program or activity so that, when viewed in its entirety, it is readily accessible to and usable by individuals with disabilities (ADA Title II regulations, 28 CFR 35.150(a)). That does not necessarily mean making every existing building accessible, and it does not require action that would threaten or destroy the historic significance of a historic property (ADA Title II regulations, 28 CFR 35.150(a)(1) and (2)).

The regulation lists ways to get there: redesigning or acquiring equipment, moving a service to an accessible building, assigning aides, home visits, delivering the service at another accessible site, altering existing facilities or building new ones. Structural changes are not required where other methods work, and among the methods, priority goes to the ones that offer the program in the most integrated setting appropriate (ADA Title II regulations, 28 CFR 35.150(b)(1)). So a town whose council chamber is up a flight of stairs can meet the rule by moving the meetings to an accessible room, and a library with one inaccessible floor can bring the books down.

There is a limit. A public entity does not have to take an action it can show would fundamentally alter the program or impose undue financial and administrative burdens. The burden of proof is on the entity, the decision has to be made by its head or a designee after considering all the resources available, and it needs a written statement of the reasons. Even then, the entity has to take any other action that still gets people with disabilities the benefits or services (ADA Title II regulations, 28 CFR 35.150(a)(3)).

  • Safe harbor: elements not altered on or after March 15, 2012 that comply with the 1991 Standards or with the Uniform Federal Accessibility Standards (UFAS) do not have to be modified to meet the 2010 Standards (ADA Title II regulations, 28 CFR 35.150(b)(2)(i)).
  • Transition plan: where structural changes are needed for program access, a public entity with 50 or more employees has to write a transition plan that identifies the physical obstacles, describes the methods, sets a schedule with yearly steps if it runs longer than a year, and names the official responsible. People with disabilities and their organizations must be able to comment, and the plan is open to public inspection (ADA Title II regulations, 28 CFR 35.150(d)(1) and (3)).
  • Deadlines: structural changes for program access were due within three years of January 26, 1992, and in any event as expeditiously as possible (ADA Title II regulations, 28 CFR 35.150(c)).
  • Upkeep: accessible features have to be kept in operable working condition. Isolated or temporary interruptions for maintenance or repairs are allowed (ADA Title II regulations, 28 CFR 35.133(a) and (b)), so an elevator out of service for a day is not the same as one left broken for months.

New construction and alterations: the 2010 Standards

Anything a public entity builds, or has built for its use, after January 26, 1992 has to be readily accessible. The only exception is structural impracticability, which the regulation reserves for rare cases where the unique characteristics of terrain prevent accessibility features, and even then every part that can be made accessible must be (2010 ADA Standards, 28 CFR 35.151(a)). Alterations that affect usability have to make the altered part accessible to the maximum extent feasible (2010 ADA Standards, 28 CFR 35.151(b)(1)).

Which standard applies depends on when physical construction or the alteration started. Before September 15, 2010, the 1991 Standards or UFAS; from that date to March 14, 2012, a choice of the 1991 Standards, UFAS or the 2010 Standards; on or after March 15, 2012, the 2010 Standards (2010 ADA Standards, 28 CFR 35.151(c)). For state and local governments, the 2010 Standards are the Title II rules in 28 CFR 35.151 together with the 2004 ADAAG, and where the two differ, 35.151 prevails (2010 ADA Standards, introduction, Title II facilities).

An alteration to an area that contains a primary function, such as offices, meeting rooms or the dining area of a cafeteria, also brings the path of travel to it into the work: the route, and the restrooms, telephones and drinking fountains that serve the area, unless the cost is disproportionate, which the regulation sets at more than 20 % of the cost of the alteration to the primary function area. When money runs short, the order of priority is an accessible entrance, then the route to the altered area, at least one accessible restroom for each sex or a single unisex one, telephones, drinking fountains, and then parking, storage and alarms (2010 ADA Standards, 28 CFR 35.151(b)(4)).

Rules in 28 CFR 35.151 that apply to state and local government facilities on top of the 2010 Standards.
Facility What the Title II regulation adds Section
Shelters, group homes, halfway houses residential facility rules; in sleeping rooms with more than 25 beds, 5 % of beds with clear floor space; with more than 50 beds and shared bathing, at least one roll-in shower with a seat 2010 ADA Standards, 28 CFR 35.151(e)
Student housing transient lodging rules, with sleeping rooms treated as guest rooms 2010 ADA Standards, 28 CFR 35.151(f)
Stadiums, arenas, grandstands wheelchair spaces and companion seats on every level that has seating served by an accessible route, and, as a rule, not on temporary platforms 2010 ADA Standards, 28 CFR 35.151(g)
Medical care facilities where the facility does not specialize in conditions that affect mobility, accessible patient bedrooms spread in proportion to each medical specialty 2010 ADA Standards, 28 CFR 35.151(h)
Streets and sidewalks curb ramps or other sloped areas at intersections, in new or altered streets and walkways 2010 ADA Standards, 28 CFR 35.151(i)
Jails and prisons mobility features in at least 3 %, and no fewer than one, of all the cells in the facility, with cells with mobility features in each classification level 2010 ADA Standards, 28 CFR 35.151(k)(1)

Streets, sidewalks and curb ramps

Title II is the part of the ADA that reaches the street corner. Newly built or altered streets, roads and highways must have curb ramps or other sloped areas at any intersection with curbs or other barriers to entry from a pedestrian walkway, and newly built or altered walkways must have them where they meet streets (2010 ADA Standards, 28 CFR 35.151(i)). For the streets that already exist, the transition plan of a public entity responsible for streets, roads or walkways has to include a schedule for curb ramps where pedestrian walks cross curbs, starting with walkways that serve government offices, transportation, businesses open to the public and employers, and then the others (ADA Title II regulations, 28 CFR 35.150(d)(2)).

A curb ramp on an accessible route follows section 406 of the 2010 Standards, which brings in parts of the ramp rules (2010 ADA Standards, 406.1). In short: a running slope no steeper than 1:12, a cross slope no steeper than 1:48 and a clear width of at least 36 inches (915 mm) (2010 ADA Standards, 405.2, 405.3 and 405.5); a counter slope of the gutter no steeper than 1:20, flared sides no steeper than 1:10, and a landing at the top at least 36 inches (915 mm) long (2010 ADA Standards, 406.2, 406.3 and 406.4). How each one is measured, and how they compare with the newer guidelines for public streets, is in ADA curb ramps. The sidewalk itself, its width, passing spaces and slope, is in ADA sidewalk requirements, and the signals that tell blind pedestrians when to cross in accessible pedestrian signals.

Parks, pools, playgrounds and historic sites

A city park, a public pool or a state historic site is a program like any other, so program access applies to it. One detail matters for recreation: the safe harbor for older elements does not apply where the 1991 Standards had no specifications at all. The regulation lists those elements, and most of them are recreation facilities (ADA Title II regulations, 28 CFR 35.150(b)(2)(ii)):

  • play areas, swimming pools, wading pools and spas;
  • fishing piers and platforms, recreational boating facilities, golf and miniature golf facilities;
  • exercise machines, saunas and steam rooms, shooting facilities and amusement rides;
  • team or player seating, and the accessible route to bowling lanes and in court sports facilities;
  • and the dwelling units of residential facilities.

The play area rules cover play areas for children ages 2 and over, and where a site has separate play areas for different age groups, each one complies (2010 ADA Standards, 240.1); what they ask is in accessible playgrounds. For pools built before March 15, 2012, the pool rules of the 2010 Standards did not apply until January 31, 2013 when a public entity chose to make structural changes only to meet program access (ADA Title II regulations, 28 CFR 35.150(b)(4)); pool lifts and the other ways into the water are in ADA pool lift.

Historic preservation programs give priority to physical access. Where a historic property cannot be physically altered, the regulation allows audio-visual materials that show the parts that cannot be made accessible, guides who take visitors with disabilities into or through those parts, or other innovative methods (ADA Title II regulations, 28 CFR 35.150(b)(3)). What a museum offers blind and deaf visitors is in accessible museums, and the day out in general in accessible tourist attractions.

Programs, communication and the paperwork

  • Policies: a public entity makes reasonable modifications in policies, practices or procedures when they are needed to avoid discrimination, unless it can show they would fundamentally alter the service, program or activity (ADA Title II regulations, 28 CFR 35.130(b)(7)(i)).
  • Effective communication: communication with people with disabilities, applicants, participants, members of the public and their companions has to be as effective as with others, with auxiliary aids and services where necessary. The entity gives primary consideration to what the person asks for, and it cannot require someone to bring their own interpreter (ADA Title II regulations, 28 CFR 35.160(a)(1), (b) and (c)(1)).
  • Service animals: as a rule, a public entity modifies its policies to allow a service animal (ADA Title II regulations, 28 CFR 35.136(a)). The questions staff may ask are in guide dogs.
  • Signs: people, including those with impaired vision or hearing, must be able to find out where the accessible services and facilities are. Every inaccessible entrance has a sign that directs to an accessible entrance or to where information is available, and every accessible entrance has the International Symbol of Accessibility (ADA Title II regulations, 28 CFR 35.163); the symbol is in accessibility symbols.
  • Self-evaluation and notice: every public entity had to evaluate its services, policies and practices and fix what did not comply, with a chance for people with disabilities to comment; entities with 50 or more employees keep the record on file for public inspection for three years. Each one also tells the public about the rule and its rights under it (ADA Title II regulations, 28 CFR 35.105 and 35.106).
  • ADA coordinator and grievance procedure: an entity with 50 or more employees designates at least one employee to coordinate compliance, makes their name, office address and phone number available, and publishes a grievance procedure for prompt and equitable resolution of complaints (ADA Title II regulations, 28 CFR 35.107).

The 2024 web rule: WCAG 2.1 AA and the new deadlines

In April 2024, the Department of Justice added Subpart H to the Title II regulation. A public entity has to make the web content and the mobile apps it provides or makes available readily accessible, whether it runs them itself or through contractual, licensing or other arrangements (ADA Title II regulations, 28 CFR 35.200(a)), so content a vendor supplies under contract counts too. The technical standard is WCAG 2.1, Level A and Level AA success criteria and conformance requirements (ADA Title II regulations, 28 CFR 35.200(b)).

The deadlines changed. An interim final rule that took effect on April 20, 2026 moved the first one from April 24, 2026 to April 26, 2027, and the second from April 26, 2027 to April 26, 2028 (2026 extension of the Title II web rule). These are the dates in the regulation as it stands today:

Compliance dates of the ADA Title II web and mobile app rule, as amended on April 20, 2026.
Public entity Must comply with WCAG 2.1 AA by Section
Total population of 50,000 or more, other than a special district government April 26, 2027 ADA Title II regulations, 28 CFR 35.200(b)(1)
Total population of less than 50,000 April 26, 2028 ADA Title II regulations, 28 CFR 35.200(b)(2)
Any special district government, whatever its size April 26, 2028 ADA Title II regulations, 28 CFR 35.200(b)(2)

Total population is, in most cases, the entity’s population in the most recent decennial Census; a school district uses the Census Small Area Income and Poverty Estimates, and an agency of a state or local government uses the population of the government it belongs to. A special district government is one, other than a county, municipality, township or independent school district, set up under state law for one or a few functions, whose population the Census Bureau does not calculate (ADA Title II regulations, 28 CFR 35.104).

The Department said it plans further rulemaking on the substance of the 2024 rule and may propose changes during the extension; it also said that, whatever the dates, public entities keep their existing Title II obligations to make the services, programs and activities they offer through websites and apps accessible (2026 extension of the Title II web rule).

Some of the WCAG 2.1 success criteria the rule incorporates.
Success criterion What it asks Level
1.1.1 Non-text content a text alternative for images and other non-text content, serving the equivalent purpose A (WCAG 2.1, 1.1.1)
1.2.2 Captions (prerecorded) captions for all prerecorded audio in synchronized media, such as a recorded council meeting A (WCAG 2.1, 1.2.2)
1.4.3 Contrast (minimum) a contrast ratio of at least 4.5:1 for text, and 3:1 for large-scale text AA (WCAG 2.1, 1.4.3)
1.4.10 Reflow vertically scrolling content usable without scrolling in two directions at a width equivalent to 320 CSS pixels, without losing information or functionality AA (WCAG 2.1, 1.4.10)
2.1.1 Keyboard all functionality operable through a keyboard interface A (WCAG 2.1, 2.1.1)

The rule has five exceptions (ADA Title II regulations, 28 CFR 35.201 and 35.104):

  1. Archived web content created before the compliance date, kept only for reference, research or recordkeeping, not altered afterwards, and stored in an area clearly marked as archived.
  2. Preexisting documents in PDF, word processor, presentation or spreadsheet formats posted before the compliance date, unless they are still used to apply for, gain access to or take part in a service or program.
  3. Content posted by a third party, unless the third party posts it under a contract or other arrangement with the entity.
  4. Individualized, secured documents about a specific person, their property or their account, when they are password-protected or otherwise secured.
  5. Social media posts published before the compliance date.

A conforming alternate version, a separate accessible version of the same content, is allowed only where technical or legal limits make it impossible to make the content itself accessible (ADA Title II regulations, 28 CFR 35.202(a)). The fundamental alteration and undue burden defense exists here too, with the same written statement, and the entity still has to get people with disabilities the benefits to the maximum extent possible (ADA Title II regulations, 28 CFR 35.204). An entity that is not in full compliance is deemed to meet the rule only in the limited case where it can show that the noncompliance has so minimal an impact on access that people with disabilities can still get the same information, take part in the same interactions and transactions and otherwise benefit from the same services, with substantially equivalent timeliness, privacy, independence and ease of use (ADA Title II regulations, 28 CFR 35.205).

How to file a Title II complaint

Anyone who believes they, or a specific class of people, faced disability discrimination by a public entity can file a complaint, on their own or through an authorized representative. It has to be filed within 180 days of the discrimination, unless the agency extends the time for good cause, and it can go to the federal agency designated for that area, to any federal agency that funds the public entity, or to the Department of Justice, which refers it (ADA Title II regulations, 28 CFR 35.170).

Using the city’s or the school district’s own grievance procedure first is optional. The Department of Justice’s guidance says exhausting it is not a prerequisite, and that the delay of following it may count as good cause to extend the 180 days (ADA Title II regulations, appendix B, section 35.170).

Checking a public building with Braillito Maps

Title II judges a program as a whole, from the transition plan to the website. A visitor needs something simpler: whether the library, the courthouse or the recreation center they are going to today will work for them. Braillito Maps is a community map that answers ten questions about each place: step-free entrance or ramp, wide doorway, accessible restroom, accessible parking, tactile paving, braille signage, braille menu, audible signals, guide dogs welcome and a quiet environment.

Several of them line up with this page. The entrance, the route through the doorway and the restroom come first in the order of priority for an altered building, and parking comes after them; braille signage and tactile paving help blind visitors find their way; audible signals are alerts that can be heard, not only seen. Each question is answered yes or no, or stays without data until someone knows. The score of a place is the number of yes answers out of ten, and its color is always shown next to the number, never on its own.

The map is not a compliance test: a yes means that a visitor found it there, not that the building meets the 2010 Standards. It is a way to know before you go, and to leave that knowledge for the next person when you add a public building you visited. Meet Braillito Maps.

Frequently asked questions

What is ADA Title II?

Title II of the Americans with Disabilities Act prohibits disability discrimination by public entities. Its regulation, 28 CFR part 35, applies to all the services, programs and activities that state and local governments provide or make available (ADA Title II regulations, 28 CFR 35.101(a) and 35.102(a)).

Who has to comply with Title II?

Any state or local government, any of their departments, agencies, special purpose districts or other instrumentalities, and Amtrak and commuter rail authorities (ADA Title II regulations, 28 CFR 35.104). Businesses open to the public follow Title III.

When is the ADA Title II web accessibility deadline?

April 26, 2027 for public entities with a total population of 50,000 or more, and April 26, 2028 for those under 50,000 and for every special district government (ADA Title II regulations, 28 CFR 35.200(b)). The dates were extended by one year by an interim final rule effective April 20, 2026 (2026 extension of the Title II web rule).

Which WCAG version does Title II require?

WCAG 2.1, the W3C Recommendation of June 5, 2018, at Level A and Level AA, for web content and mobile apps (ADA Title II regulations, 28 CFR 35.104 and 35.200(b)).

Does Title II require every government building to be accessible?

Not every existing building. Each program, viewed in its entirety, has to be accessible, which can be done by moving a service to an accessible building or other methods, while new construction and alterations follow the 2010 Standards (ADA Title II regulations, 28 CFR 35.150(a) and (b); 2010 ADA Standards, 28 CFR 35.151(c)).

Does Title II require curb ramps?

Yes. New or altered streets, roads and highways need curb ramps or other sloped areas at intersections with curbs, and new or altered walkways need them where they meet streets (2010 ADA Standards, 28 CFR 35.151(i)). For existing streets, the transition plan includes a schedule for curb ramps (ADA Title II regulations, 28 CFR 35.150(d)(2)).

More accessibility guides

  • ADA compliance: a checklist for small businesses, with the 2010 Standards section behind each item.
  • ADA curb ramps: curb ramp slope, counter slope, width, flared sides, the top landing, diagonal ramps, islands and detectable warnings.
  • ADA sidewalk requirements: clear width, passing spaces, grade, cross slope, surface, protruding objects and street furniture, on public sidewalks and on site.
  • Accessible playgrounds: how many play components must be accessible under the ADA, the route, the ground surface and transfer platforms.
  • ADA pool lift requirements: how many means of entry a pool needs, and the seat, height, capacity and controls of a pool lift.
  • Accessibility symbols: what the wheelchair symbol means, where it is required and the other access symbols.
  • Guide dogs: how they work, where they can go under the ADA, and how to act around one.
  • Accessibility laws by country: the ADA, the UK Equality Act, the Accessible Canada Act, Australia’s DDA and the EU rules, and what each covers.
  • 2010 ADA Standards: what each of the ten chapters covers, since when the Standards apply and to which buildings, with the guide for each element.
  • ADA paratransit: who qualifies, the 3/4 mile service area, fares up to twice the bus fare, next-day booking, companions and how to apply.
  • Accessible medical equipment: exam tables that lower to 17–19 inches, wheelchair scales, how many a clinic or hospital needs, and the 2024 deadlines.
  • All accessibility guides

Sources

Every figure in this guide comes from one of these official texts, which we read in October 2026.

  1. Americans with Disabilities Act Title II Regulations (28 CFR part 35). U.S. Department of Justice, in the Electronic Code of Federal Regulations, current text with its appendices, as amended April 20, 2026; read October 2026.
  2. Extension of Compliance Dates for Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities. U.S. Department of Justice, Federal Register, 91 FR 20902 (interim final rule), published and effective April 20, 2026.
  3. 2010 ADA Standards for Accessible Design. U.S. Department of Justice, published September 15, 2010; required for new work since March 15, 2012.
  4. Americans with Disabilities Act Title III Regulations (28 CFR part 36). U.S. Department of Justice (ADA.gov), current text with its appendices, read October 2026.
  5. Web Content Accessibility Guidelines (WCAG) 2.1. World Wide Web Consortium (W3C), W3C Recommendation, June 5, 2018.

Braillito Maps

Find places with ramps, accessible toilets or tactile paving near you in Braillito Maps

In Braillito Maps, every place answers ten questions: step-free entrance or ramp, wide doorway, accessible restroom, accessible parking, tactile paving, braille signage, braille menu, audible signals, guide dogs welcome and a quiet environment. It is built by the people who need it, and every place gets a score out of ten.

Download on the App Store Meet Braillito Maps

Free · No ads · For iPhone