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ADA Title II 2027: do your published Google Docs and Slides need to meet WCAG 2.1 AA?

Short answer

Yes, if a state or local government entity provides them to the public as web content. The DOJ rule (28 CFR part 35, subpart H) requires WCAG 2.1 Level AA for web content, which includes documents posted or linked on a website, with exceptions such as archived content and some preexisting documents. After the 2026 extension, entities serving a population of 50,000 or more must comply by April 26, 2027; smaller ones and special district governments by April 26, 2028. Sources: Federal Register 2024-07758 and 2026-07663.

The Department of Justice's 2024 rule under Title II of the ADA sets a technical standard for the web content and mobile apps of state and local governments. In April 2026 DOJ moved the compliance dates. If your office shares Google Docs or Slides with the public — agendas, forms, handouts, presentations — this is what applies and when.

Quick steps

  1. List what is public. Collect the Docs and Slides your office links from its website or shares by public link. Note which ones are current and which are archived.
  2. Check each document. Run an accessibility check on each current document: alt text, headings, link text and colour contrast are the most common failures.
  3. Fix and recheck. Fix the issues in the document, then check again until nothing is left in the Fix list.
  4. Review what tools can't see. Check by hand what an add-on cannot read: table header rows, document language, reading order, captions.
  5. Keep a record. Write down the date, document and what was fixed. Keep it with the document's owner.

Dates after the 2026 extension

  • State and local governments, total population 50,000 or more: April 26, 2027.
  • Population under 50,000, and special district governments: April 26, 2028.
  • Separately, HHS moved the Section 504 web accessibility date for recipients of HHS funding with 15 or more employees to May 11, 2027 (fewer than 15: May 11, 2028).

What counts as web content

The rule covers content a public entity makes available on its websites and mobile apps, including content provided through contractors. Documents such as word-processing files and presentations posted or linked for the public are web content under the rule.

The rule lists exceptions, among them archived web content, preexisting conventional electronic documents (unless they are used to apply for or take part in a service), content posted by third parties, and individualized password-protected documents. Read the exceptions in the rule text before you decide a document is out of scope.

What WCAG 2.1 AA asks of a document

  • 1.1.1 Non-text content: images need a text alternative (alt text), or must be marked decorative.
  • 1.3.1 Info and relationships: headings, lists and tables must be real structure, not just bold or large text.
  • 1.4.3 Contrast: text needs a contrast ratio of at least 4.5:1, or 3:1 for large text.
  • 2.4.4 Link purpose: link text should say where the link goes.
  • 2.4.2 Page titled: for slides, each slide needs a title.

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Sources: DOJ final rule, Federal Register 2024-07758 · DOJ compliance date extension, Federal Register 2026-07663 · HHS Section 504 extension, Federal Register 2026-09266 · W3C WCAG 2.1. Not legal advice — disclaimer.

FAQ

Does the rule apply to private businesses?

Title II covers state and local government entities. Private businesses fall under Title III, which this rule does not change. HHS's Section 504 rule covers recipients of HHS funding, such as many clinics and hospitals.

Is a Google Doc shared by link 'web content'?

If the public gets to it through the entity's website, app or a link the entity provides, it is content the entity makes available. Check the rule's definitions and exceptions for your case; this guide is not legal advice.

Does passing an automated check mean the document conforms?

No. Automated checks find common problems. WCAG conformance also depends on things a tool cannot judge, such as whether alt text is meaningful or whether reading order makes sense.

Updated 2026-10-27.

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