The six Title II exceptions, and what each one actually requires
Six exceptions sound like six ways out. Most of them carry cumulative conditions, and failing any one condition removes the exception entirely — so the useful question is not whether one applies but which condition you would fail.
Your web compliance date is decided by the population you serve, and both dates moved a year later under a DOJ interim final rule. The standard is the same either way. If the date is all you came for, the extension is covered in full here.
Where they differ
Population 50,000 or more
Fewer than 50,000, and special districts
Web compliance date
26 April 2027
26 April 2028
Technical standard
WCAG 2.1 Level AA
WCAG 2.1 Level AA
The instrument that set the date
20 April 2026, interim final rule (91 FR 20902, doc. 2026-07663), published and effective 20 April 2026
20 April 2026, interim final rule (91 FR 20902, doc. 2026-07663), published and effective 20 April 2026
The six exceptions
Each one below is the value carried in this site’s claim register. The first line is what the exception does; the line under it is the condition set you would have to meet.
Archived web content
Four cumulative conditions; failing any one removes the exception
Archived web content is excepted from WCAG 2.1 AA only where all four conditions hold: created before the compliance date (or reproducing pre-compliance physical media), kept only for reference/research/recordkeeping, stored in a designated archive area, and unchanged since archiving
Preexisting documents
Exception lost the moment the document is still in active service use
Preexisting conventional electronic documents (word processing, presentation, PDF, spreadsheet) posted before the compliance date are excepted — but NOT where they are currently used to apply for, access, or participate in a service
Third-party content
Exception does not reach vendor-posted content or the posting tool itself
Content posted by third parties on a public entity's site is excepted, but not content the entity itself posts, not contractor- or vendor-posted content, and not the platform or tool that enables third-party posting
Password-protected documents
Conventional electronic document (word processing, presentation, PDF or spreadsheet), AND about a specific person, property or account, AND password-protected or otherwise secured
Individualized password-protected documents are excepted where all three conditions hold
Social media posts
No conditions attached — pre-compliance-date posts are out of scope; posts on or after the date are in scope
Social media posts made by a state or local government before its compliance date are excepted, unconditionally
Conforming alternate versions
Very limited circumstances only; not a general-purpose remedy
Conforming alternate versions may substitute for inaccessible content only in very limited circumstances — where technical or legal limitations prevent making the original accessible