We Analyzed 189 Comments About the DOJ’s ADA Title II Extension
In 2024, the Department of Justice updated Title II of the Americans with Disabilities Act (ADA), spelling out specific requirements for state and local governments to make their websites and mobile apps accessible to people with disabilities. The rule pointed governments toward WCAG 2.1 Level A and AA, a technical standard used in the vast majority of existing accessibility legislation.
Title II covers the services, programs, and activities of state and local governments. In practice, that includes the websites and apps that residents use to pay a bill, apply for benefits, register for or attend school, find public information, or generally just participate in civic life.
Entities serving populations of 50,000 or more originally had until April 24, 2026, to comply. Entities serving populations under 50,000 and special district governments originally had until April 26, 2027.
Only four days before the first deadline, the DOJ published an interim final rule extending both dates. We covered the IFR in more detail here. The new deadline for larger entities is April 26, 2027. The new deadline for smaller entities and special districts is April 26, 2028. The interim final rule also raised the possibility of revisiting the substance of the 2024 rule later.
Anyone impacted by the rule was offered two months to make their voices heard. Now that the submission deadline has passed, we had the chance to analyze responses submitted between April 23 and June 25, 2026, to docket DOJ-CRT-2026-0067.
The TL;DR
There were 189 comments submitted on the DOJ’s Title II extension announcement, and we reviewed them all. Interestingly, there were many clear patterns. This post talks about them in detail. In short:
- There is clear consensus that the rule should remain in place. Only four comments called for repeal.
- Opposition to delaying the accessibility requirements was the largest position. Eighty-five comments opposed the extension, compared with 41 that supported it.
- People who described lived experience with disability were especially likely to oppose the extension. Twenty-nine of those 42 commenters opposed it, while only one supported it.
- Supporters of the extension focused mostly on implementation burdens like costs, instructional materials, PDFs, vendors, lawsuits, and the risk that public entities would remove information instead of fixing it.
- Opponents of the extension most often said that entities have already had enough time to prepare. Fifty-five of the 85 opposing comments raised this point. The second most common reason, stated by 38, described accessibility as a civil rights issue.
Reading and Categorizing the Comments
Some of the 189 comments focused mainly on the extension. Others used the extension as an opening to discuss the underlying rule.
It is not enough to sort the comments into those for or against the extension.
A commenter could support an extra year while still supporting the rule. Someone else could support the same extra year because they wanted the rule weakened or removed. Someone could support the rule in theory while objecting to how it would be implemented. Someone else could support the rule and oppose the extension. And obviously, someone could think the rule itself should be scrapped.
To capture that difference, we categorized each comment along two separate axes. The first asks whether the commenter opposed, supported, or was unclear about the extension. The second asks what the commenter thought should happen to the underlying rule: keep or strengthen it, weaken or exempt parts of it, repeal it, or take no position.
We also recorded the type of commenter, whether they described a lived disability, the action they requested, and the themes they raised.
Throughout this article, we deliberately use the words “commenter” and “entity” rather than “person” or “individual.” This is because the 189 comments do not represent 189 individuals. Many submissions came from representative bodies like the National Association of Counties, the National League of Cities, the American Council of Engineering Companies, and the World Wide Web Consortium. A percentage of comments is therefore not a percentage of individuals. If 45% of the comments support a position, that does not mean 45% of people support it.
When we started compiling this data, our first thought was, “Why only 189 comments? Shouldn’t there be more?” We have since spoken with numerous institutions that opted to work with these representative organizations to make their voices heard instead of submitting their own comment, believing in the old motto that says, “We are stronger together.” Anecdotally, based on the DOJ’s approach thus far, there is wisdom here.
1. Sentiment About the Extension
The largest group opposed the extension. A substantial group did not take a clear position on timing, often because they were discussing accessibility barriers, implementation questions, or the underlying rule without saying whether the deadline should move
| Stance on extension | Comments | Share |
| Oppose extension | 85 | 45.0% |
| Support extension | 41 | 21.7% |
| Neutral or unclear | 63 | 33.3% |
| Total | 189 | 100% |
Many comments described access as a current civil rights issue or explained what happens when a government website or online application is inaccessible. Hand-picked quotations can be found in the final section.
2. Sentiment by Commenter Group
The position on the extension varied substantially by the commenter group. The table below includes the largest groups and combines the smallest categories into “Other categories.” These categories describe the role or identity represented in a submission. They are not representative samples of the public.
| Commenter group | Oppose | Support | Neutral or unclear | Total |
| Individual, general public | 26 | 7 | 14 | 47 |
| Disabled individual | 26 | 0 | 10 | 36 |
| Higher education faculty | 0 | 7 | 14 | 21 |
| Disability advocacy organization | 19 | 1 | 0 | 20 |
| Accessibility professional | 10 | 0 | 3 | 13 |
| Government staff | 1 | 5 | 6 | 12 |
| Higher education accessibility staff | 2 | 3 | 5 | 10 |
| Trade or government association | 0 | 6 | 2 | 8 |
| City or county official | 0 | 4 | 2 | 6 |
| Assistive technology or remediation vendor | 0 | 3 | 1 | 4 |
| Other categories | 1 | 5 | 6 | 12 |
Disabled individuals and disability advocacy organizations were much more likely to oppose the extension. Higher education faculty, government staff, city and county officials, trade associations, and vendors were more likely to support it or raise implementation concerns.
We cannot assume that one’s position directly informs their stance. That said, there was a notable divide in the preferred outcome between comments that described an access barrier and those representing an organization responsible for delivering, maintaining, or remediating digital services.
3. Positions on the Underlying Rule
The second question was not about the deadline but the 2024 rule itself. Did the commenter want the rule kept or strengthened, weakened or narrowed, repealed, or left unaddressed?
Most comments that took a position on the rule favored keeping or strengthening it. Some of those commenters still supported a limited delay while arguing that the rule should remain in place.
| Position on underlying rule | Comments | Share |
| Keep or strengthen | 103 | 54.5% |
| Weaken or exempt | 51 | 27.0% |
| Repeal | 4 | 2.1% |
| No position | 31 | 16.4% |
| Total | 189 | 100% |
In plain language, more than twice as many comments favored keeping or strengthening the rule as favored repeal. The comments were more divided over how the rule should be implemented than over whether accessibility is important.
Given that the primary goals for accessibility advocates over the past few decades have been to spread awareness, show that accessibility matters, and get people to think about it, the fact that few comments questioned its importance reflects considerable progress on its own.
4. Extension Stance and Underlying Rule Position
| Extension stance | Keep or strengthen | Weaken or exempt | Repeal | No position | Total |
| Oppose extension | 85 | 0 | 0 | 0 | 85 |
| Support extension | 5 | 27 | 2 | 7 | 41 |
| Neutral or unclear | 13 | 24 | 2 | 24 | 63 |
| Total | 103 | 51 | 4 | 31 | 189 |
All 85 comments opposing the extension also favored keeping or strengthening the rule. The 41 comments supporting the extension were divided. Five supported the delay while also supporting the rule. Twenty-seven wanted the rule weakened or exempted. Two wanted repeal, and seven did not take a position on the rule.
Opposition to delay was concentrated among commenters who wanted the rule to be kept or strengthened. Support for delay reflected two different positions. Some commenters wanted time to implement the existing rules. Others wanted exemptions, narrower requirements, or repeal.
5. People Describing Lived Disability
Forty-two commenters described living with a disability. Their positions were:
- Twenty-nine opposed the extension.
- One supported it.
- Twelve did not take a clear position on timing.
That means 69% of commenters describing lived disability opposed the extension, compared with 38.1% of commenters who did not describe lived disability. This category includes commenters who described their own lived experience. It does not identify all disabled people who submitted a comment.
The comments from disabled individuals often connected the policy decision to daily consequences, including inaccessible government portals, barriers to employment, and difficulty participating in community life.
6. Major Arguments and Pain Points
The themes below were not mutually exclusive. Many comments expressed more than one concern simultaneously.
Arguments Against Delay
| Theme | Comments | Share of comments |
| Entities had enough time already | 57 | 30.2% |
| Accessibility is a civil rights issue | 42 | 22.2% |
| A specific accessibility barrier was described | 24 | 12.7% |
| Delay rewards entities that did not prepare | 18 | 9.5% |
| The AI premise is wrong | 14 | 7.4% |
| WCAG is a stable standard | 14 | 7.4% |
| Administrative Procedure Act objection | 12 | 6.3% |
| Disability is universal | 11 | 5.8% |
The most common argument was that governments had already had enough time to prepare. Many commenters framed the delay as an extension of an existing access problem rather than a neutral administrative adjustment.
Arguments for Delay or Exemptions
| Theme | Comments | Share of comments |
| Unfunded mandate or compliance cost | 29 | 15.3% |
| Risk of removing information instead of fixing it | 27 | 14.3% |
| Instructional materials or learning management systems | 25 | 13.2% |
| Fear of lawsuits | 23 | 12.2% |
| PDF or archive burden | 17 | 9.0% |
| Technical or STEM content | 16 | 8.5% |
| Third-party content or vendors | 12 | 6.3% |
| Captioning or video burden | 5 | 2.6% |
| AI will solve some accessibility problems | 4 | 2.1% |
| WCAG is a moving target | 3 | 1.6% |
These comments focused on implementation. The most common pain points differed by group.
| Commenter group | Most common pain points | What commenters described |
| Individual, general public | Enough time already, civil rights, disability is universal | The need for accessible public services and the belief that delay prolongs discrimination |
| Disabled individual | Lived barriers (21), enough time (12), civil rights (11) | Repeated difficulty using government websites and participating in work or community life |
| Higher education faculty | Instructional or learning management system content (17), technical or STEM content (9) | The burden on instructors and the difficulty of remediating specialized course materials |
| Disability advocacy organization | Enough time (18), civil rights (14), Administrative Procedure Act objections (9) | The legal and practical harms of delaying access for disabled people |
| Accessibility professional | Enough time (7), civil rights (6), delay penalizes entities that prepared (4) | Concerns that entities were treating an established standard as optional |
| Government staff | Compliance cost (7), content removal risk (5), litigation fear (4), vendor limits (4) | Limited staff and budgets, dependence on vendors, and pressure to remove content |
| Higher education accessibility staff | Instructional or learning management system content (5), content removal risk (3) | The gap between accessibility expectations and the tools or support available to faculty |
| Trade or government association | Litigation fear (7), compliance cost (6), PDF or archive burden (5) | The effect of remediation costs and legal exposure on small public entities |
| City or county official | Compliance cost (4), content removal risk (3), vendor limits (3) | The practical limits faced by local governments with small teams |
7. Most Common Recommendations
The requested actions show what commenters wanted DOJ to do next. Many comments had more than one request. For those checking our math, this is why the counts do not add up to 189.
| Requested action | Oppose extension | Support extension | Neutral or unclear | Total |
| Restore the original deadlines | 69 | 0 | 0 | 69 |
| Provide clearer guidance | 4 | 20 | 13 | 37 |
| Oppose weakening or reopening the rule | 18 | 3 | 3 | 24 |
| Exempt course content | 0 | 9 | 12 | 21 |
| Add a safe harbor or cure period | 0 | 16 | 4 | 20 |
| Weaken or delay further | 0 | 13 | 4 | 17 |
| Provide funding | 2 | 3 | 4 | 9 |
| Make the new dates final, with no further delay | 5 | 3 | 0 | 8 |
| No specific action requested | 9 | 10 | 24 | 43 |
| Other requested actions | 1 | 4 | 10 | 15 |
The strongest recommendation among opponents was to restore the original deadlines without weakening or reopening the rule. Opponents also argued that granting an extension only days before the original deadline sets a bad precedent, because entities should already have prepared.
Supporters of the extension most often asked for clearer guidance, safe harbors, and further time. In this context, clearer guidance meant practical material that entities could use during implementation, including FAQs, testing protocols, operational playbooks, procurement templates, and instructions for holding vendors accountable. Commenters also wanted DOJ to explain how the rule applies to legacy documents, third-party platforms, archived PDFs, and situations where an entity claims an undue financial or administrative burden.
The requested safe harbor was generally a notice and cure period. Under this approach, a public entity that was making a “good-faith effort” to comply would receive notice of a problem and a reasonable opportunity to fix it before facing litigation. Some commenters also wanted the entity to be able to provide an accessible alternative format while it corrected the original content. The proposal was intended to distinguish between an entity working through a documented remediation plan and one that had made no effort to address an accessibility barrier.
The request for further time did not refer to one consistent period. The current extension already adds one year, moving the deadline for larger entities to April 26, 2027, and the deadline for smaller entities and special districts to April 26, 2028. Some commenters asked for at least one additional year beyond those dates. Others proposed a phased approach, with high-impact and high-traffic services addressed first and more difficult instructional or technical content, along with legacy and archived material, given more leeway.
Many wanted that extra time tied to interim progress requirements, not to be treated as permission to wait until the next final deadline. Many wanted exemptions for course content or other material (like math/STEM) that have historically been difficult to make accessible. Some supported the extension while still asking DOJ to make the new dates firm and avoid another delay.
8. Representative Voices and Quotes
Opposition and Lived Barriers
“Delaying 508 compliance is like making folks climb stairs in a wheelchair because elevator approval is delayed one year.” (0022, disabled individual)
“If an online application is the only ‘door’ to an appointment or benefit, a one-year delay effectively locks them out of essential government support.” (0047, individual, general public)
“Accessibility is not a future goal. It is a current civil right.” (0053, accessibility professional)
“I went from a competent employee to one who could not complete any work task in one day.” (0061, disabled individual)
“I urge the Department to maintain the original deadlines and ensure that accessibility protections are implemented without further delay.” (0007, disabled individual)
Implementation Concerns
“However, the current timeline would force us to choose between updated, compliant websites and current breadth of information.” (0072, city or county official)
“The extension should be viewed as a grace period for implementation, not a signal to weaken the rule.” (0075, disability advocacy organization)
“Without any flexibility, the League is concerned many cities without the resources will simply take down their websites resulting in less transparency between cities and the communities they serve.” (0113, trade or government association)
“The additional year is necessary, but the underlying problem the extension addresses will not solve itself with time alone.” (0171, higher education faculty)
“Establish interim expectations for progress during the extension period to prevent delays in implementation.” (0015, higher education accessibility staff)
“Without formalized, practical guidance from the DOJ, public entities face ongoing litigation risks and compliance confusion despite the extended timeline.” (0187, government staff)
Comments Unclear about Timing
“Most instructors at my institution just had to go in and delete everything out of the learning management system because they were not able to make it all compliant on their own.” (0074, higher education faculty)
“Accessibility should not be viewed as a compliance event with a fixed endpoint.” (0138, accessibility professional)
“It is an ongoing organizational responsibility that requires leadership commitment, operational integration, and continuous improvement.” (0138, accessibility professional)
“Please provide clearer guidance on document accessibility requirements, or a reliable reference that defines the requirements for PDFs, Word, Excel, PowerPoint, Google Docs, Google Sheets, Google Slides, etc.” (0149, individual, general public)
“If a non-hub US airport (with Federal grant obligations) contracts with a third-party vendor to provide airport parking services through a mobile application, does the airport remain legally responsible for ensuring that the third-party application complies with WCAG 2.1 Level AA and all DOJ Title II accessibility requirements?” (0179, government staff)
“It seems unreasonable and infeasible to require that such handwritten, math-heavy notes be converted into fully accessible digital files before they may be shared with students.” (0051, higher education faculty)
“As a result, faculty face a difficult and unclear situation.” (0099, higher education faculty)
9. What This Means for You
Comments overwhelmingly stated that in the long term, the rule is a good thing, in that only good can come from ensuring that digital materials can be accessed by more people. Few commenters argued that accessibility itself should be abandoned.
That said, many influential bodies raised concerns that the DOJ will find it difficult to ignore the risk of removing information instead of remediating it, difficult instructional and technical materials, litigation exposure, and dependence on third-party vendors.
Those concerns are more likely than not going to shape future guidance, enforcement, and perhaps some targeted changes to the rule. They do not, however, point to accessibility requirements going away. We see no reason that the rule won’t remain, and public entities should expect the work of making their websites, apps, documents, and services accessible to continue.
The safest response is the one you’ve heard already, which is to say that the work should start or continue. Organizations that delay because they expect a bailout, broad exception, or another extension may find that they have made a costly assumption.
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Author: Carter Temm
