What moved
DOJ published its Title II web accessibility rule in April 2024, setting WCAG 2.1 Level AA for state and local government websites and mobile apps on a two tier timeline. In April 2026 it issued an interim final rule pushing both tiers back a year.
| Entity tier | Original deadline | Current deadline |
|---|---|---|
| Population 50,000 or more | April 24, 2026 | April 26, 2027 |
| Population under 50,000, and special district governments | April 26, 2027 | April 26, 2028 |
The tier structure and the 50,000 threshold both survived. Only the dates changed. The rule itself is in the Federal Register.
Check the date on anything you read about this
Guidance published before April 2026 cites April 24, 2026 as a live deadline. It is not. A lot of vendor material and law firm commentary still carries the old dates, and some of it is getting quoted back by AI assistants. If a source does not mention the extension, it predates it.
Which tier is an appraisal district in
Take this one to your counsel. Any vendor who answers it confidently is overreaching, and that includes us.
The tiers turn on a Census Bureau classification. "Special district government" is a defined category, and entities in it land in the later tier regardless of the population they serve. A Texas appraisal district is a political subdivision created under Tax Code § 6.01, funded by its participating taxing units, run by its own board. Whether that makes it a special district government, or whether it gets assessed against the population of the county it serves, is what decides between April 26, 2027 and April 26, 2028.
While that gets sorted, keep two things in view. The gap between the tiers is one year, so the practical planning difference is smaller than the argument over classification suggests. And the extension does nothing about litigation exposure. Title II's underlying non-discrimination obligation predates this rule and can be sued on today. Waiting for the deadline manages a date. It does not manage the risk.
One more thing that trips people up. The ADA's 50,000 is a federal number and has nothing to do with the Tax Code's 120,000 and 500,000 brackets, which run off the decennial census under Government Code § 311.005(3). Different tests, different sources, different answers.
What WCAG 2.1 AA actually asks for
The gaps that show up on appraisal district sites, roughly in order of how often:
- Scanned PDFs. Agendas, minutes, notices, Comptroller forms, all posted as pictures of documents. This is the biggest accessibility problem on CAD websites by a wide margin, and no website platform fixes it. It gets fixed in how documents are produced.
- Color contrast on branded elements, usually text sitting over a hero photograph or fighting with the county seal's palette.
- Tables used for layout, or real data tables without proper headers. Common on valuation and rate pages.
- Keyboard navigation through menus, accordions, and map or property search embeds.
- Link text reading "click here" or "download," which a screen reader user encounters as a list of nothing.
- Third party embeds, property search portals especially, whose accessibility you inherit and do not control.
What no platform can do for you
A platform can guarantee the template layer: contrast, focus order, semantic structure, keyboard operation, headings. It cannot guarantee what a district uploads. A scanned 1998 agenda inside a compliant template is still an inaccessible document. Any vendor promising to make your district accessible without talking about your document workflow is selling you half of it.
How Valorem AI approaches it
Accessibility is built at the template layer, so it holds across all fourteen site designs instead of depending on which one a district picks or what an editor does inside a page. Because the statutory pages are generated from data blocks rather than hand assembled, headings, tables, and link text keep their structure as staff edit. Every design gets checked against long district names, mobile widths, and real district content before it ships.
That covers the template. Document remediation is a separate conversation, and a better one to have before a deadline than after a complaint.