Who makes a city website ADA Title II compliant in 2026 — the platform vendor, or the city?

A clerk who has just read that the deadline is 26 April 2027 for entities serving 50,000 or more, or 26 April 2028 for entities under 50,000 and for special district governments, usually asks the same question next: our site is run by a vendor, so is this their problem? This page answers that one question, using the rule’s own words, read from the ADA.gov fact sheet on 7 August 2026.

Does your website vendor’s compliance make your city compliant?

No. The ADA Title II web rule is written to state and local governments, and the obligation to meet WCAG 2.1 Level AA sits with the public entity whoever built or hosts the site. A vendor can be contractually required to deliver accessible software, and a good one will be. That is a contract between the entity and the vendor. It is not a transfer of the entity’s obligation under the rule, and no enforcement action lands on the vendor instead of the entity because the entity outsourced the work. ADA.gov states the standard without qualification: “WCAG 2.1, Level AA is the technical standard for state and local governments’ web content and mobile apps.” It does not say “unless you use a platform.” The practical consequence is that a city on a hosted platform still needs to know what is wrong with its own site, in its own name, before the compliance date — and a vendor’s general assurance is not that record.

What the third-party content exception actually excludes

The rule does contain an exception for content posted by third parties, and it is regularly misread as covering a govtech vendor. It does not. ADA.gov states the exception plainly — “Content that is posted by third parties on a state or local government’s website or mobile app would not need to meet WCAG 2.1, Level AA” — and then removes exactly the cases a platform customer would want it for: “This exception only applies to content posted by a third party. Content that is not posted by a third party usually needs to meet WCAG 2.1, Level AA.” The fact sheet then lists what that includes: third-party content posted by the state or local government itself, content posted by a government’s contractor or vendor, and the tools and platforms that allow third parties to post content. A permit portal, an agenda management system and a public comment tool are all in that last category. The exception covers a resident’s comment. It does not cover the box the resident typed it into.

The document exception a permit portal breaks

The rule’s exception for preexisting documents is the other one a platform customer tends to rely on, and it has a carve-out with the same shape. ADA.gov: documents meeting both conditions — word processing, presentation, PDF or spreadsheet files, and available on the site before the entity’s compliance date — “usually do not need to meet WCAG 2.1, Level AA, except in some situations.” The situation is stated directly: “Documents that are currently being used to apply for, access, or participate in a state or local government’s services, programs, or activities do not fall under the exception even if the documents were posted before the date the government has to comply with the rule.” A building permit application PDF posted in 2019 and still linked from the permits page is in scope. It is also, in most small entities, hosted by the platform vendor and authored by staff, which is precisely the split that makes ownership unclear until somebody writes it down.

What two govtech platforms publish, checked 7 August 2026

The document that would let an entity put a vendor’s accessibility into its own evidence record is an Accessibility Conformance Report — a VPAT — naming the product, the version, the standard and the date. Two large platforms serving US local government were checked for one on 7 August 2026. Neither published a downloadable report.

Read that table for what it is. Neither finding says either platform is inaccessible — neither was tested here, and a company can run a rigorous internal accessibility programme and publish nothing about it. What the table says is narrower and more useful: on the day it was checked, an entity that wanted to put its vendor’s conformance into a Title II evidence binder could not do it by downloading a document, and would have to ask. Neumo says it serves “4,500+ city, county, state, and federal agencies,” so that ask is not a rare one. Note also the wording: a goal to comply is a statement of intent, not a conformance claim, and an undated statement cannot be tied to the version of the product a given city is running. Only these two platforms were checked on this date; others will be added as they are read from source, and none is listed here on memory.

What to ask your platform vendor before the deadline

Five questions get an entity from “our vendor handles it” to something it can put in a file. Each has a documentary answer, so a verbal reassurance is a failed answer.

• Will you send a current VPAT or ACR, naming the product version and the test date? A report about a release from three years ago describes software the city is not running.
• Which standard and level does it report against? Title II requires WCAG 2.1 Level AA. A report against WCAG 2.0, or against Level A only, does not answer the question the rule asks.
• Does it cover the modules we actually use? A conformant content management system says nothing about the payments portal, the agenda system or the forms builder bolted onto it.
• Who remediates the documents already on the site? Agendas, minutes and budget PDFs are usually authored by staff and hosted by the vendor. Contracts frequently leave this unassigned, and it is the most expensive line in a small entity’s scope.
• What in our contract commits you to any of this? If accessibility appears nowhere in the agreement, the entity is carrying the whole obligation and paying someone else to hold the keys to fixing it.

Does a vendor VPAT satisfy ADA Title II on its own?

No, even when the vendor supplies a good one. A VPAT is evidence about a product under test conditions. A Title II obligation attaches to a live website — its content, its posted documents, its templates as configured by the entity, and any third-party embeds the entity chose to add. Two cities on the same platform can have very different defect counts because the defects are largely in what was put into the platform: images without alternative text, headings used for visual size, contrast overridden in a theme, scanned PDFs with no text layer. That is why the rule’s exceptions matter more than the vendor’s paperwork for most small entities, and why the evidence record has to be about the entity’s own site. The Municipal Web Accessibility Index publishes automated WCAG 2.1 AA scans of US local-government sites so an entity can see the shape of its own problem before it opens a vendor conversation.

Related reading

If the vendor question is settled and the budget question is not, what Title II website compliance actually costs covers all five of the rule’s exceptions and what each removes from scope, and which Title II vendors publish a price reports what five accessibility vendors charge, read from their own sites. How to compare Title II vendors for local government sets out the four shapes of provider, and the deadline extension in full gives the dates with the Federal Register citation. Request a free preliminary report to see your own site’s defects before you ask your vendor about theirs.

Every quotation of the rule on this page was read from the ADA.gov fact sheet on 7 August 2026, and the compliance dates and the WCAG 2.1 Level AA standard were re-read from the same source the same day. The Neumo and Granicus findings are from their own accessibility pages, fetched 7 August 2026; both are statements about what those companies published on that date, not assessments of their products, and vendors add and revise conformance documents without notice — follow the source links before relying on either. Nothing here is legal advice.