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Compliance Deadline — April 24, 2026
The U.S. Department of Justice's final rule under ADA Title II requires all covered state and local government entities serving populations over 50,000 to conform to WCAG 2.1 Level AA by April 24, 2026. Entities serving 50,000 or fewer have until April 26, 2027. Non-compliance exposes agencies to DOJ complaints, civil litigation, and loss of federal funding.
The Web Content Accessibility Guidelines (WCAG) 2.1, Level AA is an internationally recognized technical standard published by the World Wide Web Consortium (W3C). It defines how digital content — websites, web applications, mobile apps, and electronic documents — must be designed so that people with visual, auditory, motor, and cognitive disabilities can perceive, understand, navigate, and interact with them equally.
For years, WCAG 2.1 AA was a best practice. In 2024, the DOJ made it law for state and local governments under the Americans with Disabilities Act (ADA) Title II. The rule, published in the Federal Register on April 24, 2024, establishes WCAG 2.1 Level AA as the mandatory conformance target for all covered government digital services — with no grandfathering for legacy systems.
Texas government agencies, DIR contract holders, and public universities are all affected. Compliance is not optional, and the deadline is not a soft target.
26%
of Americans live with some form of disability (CDC, 2023)
96.3%
of top 1 million websites had detectable WCAG failures (WebAIM 2024)
4,605
ADA web accessibility lawsuits filed in federal court in 2023
Apr 24
2026 — hard compliance deadline for large government entities
The DOJ rule applies to all state and local government entities subject to ADA Title II. In Texas, this includes:
As a Texas DIR contract holder, PMCS Services is positioned to help covered entities achieve and maintain WCAG 2.1 AA conformance through our active DIR contracts.
WCAG 2.1 AA is organized around four foundational principles — often called POUR. Every requirement in the standard maps back to one of these:
Perceivable
Information and user interface components must be presented to users in ways they can perceive — not just visually.
Operable
Users must be able to navigate and operate the interface — including those who cannot use a mouse.
Understandable
Content and interface operation must be understandable to all users.
Robust
Content must be robust enough to be interpreted reliably by a wide variety of current and future assistive technologies.
WCAG 2.1 Level AA includes 50 success criteria across the four POUR principles. The most commonly failed — and highest-impact — requirements for government websites are:
Normal text must have a contrast ratio of at least 4.5:1 against its background. Large text (18pt or 14pt bold) requires 3:1. UI components and focus indicators must also meet 3:1 against adjacent colors.
Every feature available via mouse must also be operable by keyboard alone — including navigation menus, modals, date pickers, file uploads, and custom widgets. Focus order must be logical and visible at all times.
All non-text content (images, charts, icons, CAPTCHAs, audio) must have a text alternative. Decorative images must be hidden from assistive technology. Complex images (maps, infographics) require extended descriptions.
Every form input must have a visible, programmatically associated label. Required fields must be identified. Errors must name the field, describe the problem, and suggest how to fix it — not just highlight the field in red.
Pre-recorded video must have synchronized captions for all speech and meaningful sound. Live video of real-time events requires real-time captions. Pre-recorded videos where audio does not fully convey the visual content need audio descriptions.
Content must reflow at 400% zoom without requiring two-dimensional scrolling (except for content that inherently requires scrolling, such as maps or data tables). This is one of the most commonly failed criteria on legacy government sites.
Any element that receives keyboard focus must display a visible focus indicator with sufficient contrast. Removing the browser's default outline without providing a superior custom indicator is a direct WCAG 2.1 AA violation.
The risks of missing the April 24, 2026 deadline are concrete and escalating:
Achieving WCAG 2.1 AA is not a one-time project — it is an ongoing program. For agencies starting or accelerating their journey, the following phased approach is recommended:
Audit & Inventory
Remediation
Validation & Conformance Reporting
Sustain & Monitor
Texas state agencies face layered accessibility obligations that go beyond the federal ADA Title II rule:
These state requirements apply independently of the federal ADA Title II rule, meaning Texas agencies and their vendors must satisfy both sets of obligations.
PMCS Services delivers end-to-end WCAG 2.1 AA compliance services to Texas DIR agencies, public universities, and regulated industries through our active DIR contracts. Our capabilities span the full compliance lifecycle:
As a certified Minority Business Enterprise (MBE), Disadvantaged Business Enterprise (DBE), Small Business Enterprise (SBE), and Historically Underutilized Business (HUB), PMCS Services helps agencies meet both accessibility and supplier diversity goals simultaneously.
These services are available through our active Texas DIR contracts — no new procurement vehicle required.
W3C Web Content Accessibility Guidelines
The primary technical standard. 50 success criteria across Perceivable, Operable, Understandable, and Robust principles.
Learn more → (opens in new tab)DOJ Final Rule (April 2024)
Mandates WCAG 2.1 AA for state and local government web content and mobile apps. Effective April 24, 2024; compliance required April 24, 2026.
Learn more → (opens in new tab)Rehabilitation Act § 508
Requires federal agencies and their contractors to make ICT accessible. Incorporates WCAG 2.0 Level AA by reference (36 CFR Part 1194).
Learn more → (opens in new tab)Texas Administrative Code
Texas-specific EIR accessibility standards enforced by DIR for all state agency websites and technology procurements.
Learn more → (opens in new tab)Whether you need a full audit, targeted remediation, or an ongoing compliance program, PMCS Services delivers through active Texas DIR contracts — no new procurement required.
