Below is a notice from the Michigan Department of Treasury discussing the new web accessibility requirements. As you are no doubt aware, the Justice Department has issued regulations requiring State and Local Government entities to comply with specific ADA accessibility requirements for websites and mobile applications by April 24, 2026 (if the population served is 50,000 or more), or by April 27, 2027 ( for special districts or if the population served is under 50,000). (See Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments | ADA.gov ).

Please note the highlighted portion at the end of the notice. Documents , forms and other materials submitted to the Michigan Department of Treasury (such as Audit reports, Audit packages, and any Audit finding responses, forms- such as L-4029 forms, and any other document or form submitted to treasury by or on behalf of a public library will have to comply with the new accessibility requirements.

The Department of Treasury will issue additional guidance as the deadlines draw closer.

Libraries are urged to consult their library attorneys and/or financial professionals for further information and assistance on determining how Treasury’s announcement below will affect their library’s operations.

Library of Michigan, 702 W. Kalamazoo, Lansing, MI 48915
quicks1@michigan.gov | 517-335-0126

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Local government Update

ADA Compliance Update: New Web Accessibility Rules for State and Local Governments

January 7, 2026

The U.S. Department of Justice has finalized new ADA Title II regulations requiring state and local governments to make their websites, mobile applications and digital services accessible to people with disabilities. These rules formally adopt the Web Content Accessibility Guidelines (WCAG 2.1 Level AA) as the standard for federal compliance.

WCAG 2.1 Level AA outlines how digital content must be structured, labeled and presented so it can be used by individuals with visual, auditory, mobility and cognitive disabilities. The regulations apply to new content as well as some existing digital materials that remain available to the public that is required in order to apply for, gain access to, or participate in the public entity’s services, programs or activities.

Compliance deadlines vary by jurisdiction size:

Large jurisdictions (50,000+ population): April 24, 2026
Smaller jurisdictions and special districts: April 26, 2027

What This Means for Local Governments

Local units will be required to ensure all public-facing digital content meets WCAG 2.1 AA, including websites, PDFs, forms and mobile applications. Meeting these requirements often involves reviewing existing materials, updating workflows and coordinating across departments. Because compliance involves both technical changes and content updates, preparation needs to begin well before the federal deadlines.

Treasury Submission Requirement

Beginning April 24, 2026, all documents and digital content submitted to the Michigan Department of Treasury must comply with the updated ADA Title II rules and meet WCAG 2.1 Level AA. This applies to reports such as audited financial statements, forms and other digital materials provided by or on behalf of state and local governments.

Treasury will share additional information and implementation details as federal timelines move closer.

For more information, please refer to the ADA Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments

The research and resources above are for informational purposes only and not for the purpose of providing legal advice. You should contact your attorney to obtain advice with respect to any particular issue or problem.

“the State may not, consistently with the spirit of the First Amendment, contract the spectrum of available knowledge.” Griswold v. Connecticut, 381 U.S. 479, 482 (1965).