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Florida Title II accessibility: April 2026 deadline + Sunshine Act PDF exposure

Florida public-entity websites are subject to the federal DOJ Title II rule (April 2024) and its April 24, 2026 WCAG 2.1 Level AA deadline for entities serving 50,000 or more (April 24, 2027 for smaller entities and special-purpose districts). Florida adds two state-specific dynamics. First, the Government in the Sunshine Act and Florida Public Records Law (Chapter 119 Fla. Stat.) require extensive document publication; the resulting volume of PDFs is the single largest accessibility exposure most Florida public entities have. Second, Section 282.604 Florida Statutes establishes state-procurement accessibility expectations that apply to state-agency websites and applications. The Florida Civil Rights Act (Chapter 760 Fla. Stat.) covers disability discrimination at the state level but lacks a damage-multiplier provision analogous to California's Unruh Act.

Short answer: if your entity is a Florida state agency, county, municipality, school district, university, college, or special district, you are covered by DOJ Title II and must meet WCAG 2.1 Level AA on your website by April 24, 2026 (population 50,000+) or April 24, 2027 (smaller). The Government in the Sunshine Act drives heavy PDF publishing in Florida; tagged-PDF remediation is often the largest single workstream after the HTML audit. Section 282.604 Fla. Stat. is the state-agency accessibility framework. No damage-multiplier statute equivalent to California's Unruh Act. Site Brace audits any Florida public entity for $149 flat. Try a free single-page check on your homepage first.

The federal Title II deadlines:

  • April 24, 2026: public entities serving populations of 50,000 or more.
  • April 24, 2027: public entities serving populations under 50,000, and all special-purpose districts regardless of population.

Both deadlines apply to website content and mobile apps. WCAG 2.1 Level AA is the named conformance standard. Source: 28 CFR Part 35, published in the Federal Register April 24, 2024.

The rules that apply in Florida

1. ADA Title II (federal)

The DOJ's April 2024 final rule is the load-bearing requirement for Florida public entities. Coverage and deadlines as above.

2. Section 282.604 Florida Statutes (state agencies)

Section 282.604 directs state agencies to ensure information technology procured by the state is accessible. The Florida Digital Service (FDS), housed within the Department of Management Services, oversees state-agency IT accessibility expectations and references WCAG conformance in its procurement guidance. The statute does not directly cover counties, municipalities, or school districts (those entities are covered by the federal Title II rule), but it does establish the baseline for state-agency website procurement and any technology used by state agencies.

3. Florida Civil Rights Act (Chapter 760 Fla. Stat.)

The Florida Civil Rights Act prohibits discrimination based on disability in public accommodations and is enforced by the Florida Commission on Human Relations (FCHR). The act provides for actual damages and attorney's fees but has no statutory-damages multiplier comparable to California's Unruh Act. Florida state-court website-accessibility actions exist but federal-court ADA Title III filings dominate Florida accessibility litigation volume.

4. Government in the Sunshine Act (Chapter 286 Fla. Stat.) and Public Records Law (Chapter 119 Fla. Stat.)

Florida's open-government laws require public entities to publish agendas, minutes, public-meeting materials, contracts, and requested records. Most of those documents are PDFs, and most of the PDFs are not tagged for screen readers. This is not an accessibility law per se, but it is the single biggest driver of accessibility exposure for Florida public entities, because every PDF the entity publishes is covered by Title II.

For most Florida public entities, the federal Title II rule does most of the work; the Sunshine Act amplifies the PDF exposure; and Section 282.604 sets the state-agency procurement baseline.

Which Florida entities are covered

Coverage is broad:

  • All Florida state agencies (Department of Health, Department of Transportation, Department of Children and Families, etc.)
  • 67 counties
  • Approximately 410 municipalities
  • 67 school districts (one per county, the Florida pattern)
  • State University System of Florida (12 institutions including UF, FSU, USF, FIU, UCF, etc.)
  • Florida College System (28 colleges)
  • Special districts (water management, mosquito control, port authorities, community development districts, and many others)
  • Constitutional officers operating their own websites (sheriffs, tax collectors, property appraisers, supervisors of elections, clerks of court)

The federal population threshold determines which deadline applies. Major Florida metros (Miami-Dade, Broward, Palm Beach, Hillsborough, Orange, Duval, Pinellas counties and the cities within them) serve populations well over 50,000 and fall under the April 24, 2026 deadline. Smaller rural counties, municipalities, and most special districts have until April 24, 2027.

What we typically find on a Florida public-entity site

The municipal CMS ecosystem in Florida is similar to the rest of the country; CivicPlus, Granicus, OpenCities, and OpenGov dominate, with a meaningful number of Florida-built custom WordPress and Drupal sites.

Findingaxe-core ruleTypical cause
Untagged PDFs at high volume (agendas, minutes, public records, RFPs, permit forms) Manual finding Sunshine Act drives publishing volume; PDFs exported from Word without accessibility tagging
Color contrast on navigation, calls to action, and data tables color-contrast Vendor CMS template colors and Florida-blue brand colors that fail 4.5:1
Form fields without labels on permit, license, and Public Records Request forms label Custom form builders and vendor form tools that style placeholder text as the label
Constitutional-officer site has different accessibility level than the main county site Various Florida's constitutional officers (sheriff, tax collector, etc.) often run separate websites with separate vendors
Streaming-video commission archives without captions Manual finding Live-streamed meetings posted to the site without post-production captioning
Hurricane-season alert banners with color-only urgency color-contrast Red/orange storm-warning banners that fail contrast or rely on color alone
Spanish-language toggle generating inaccessible markup label, color-contrast Translation tools inserted without accessibility verification; Florida's bilingual population makes this widespread
aria-label on generic elements aria-prohibited-attr CMS theme customizations or overlay injection. See aria-label on a div.

The PDF category dominates Florida's accessibility workload because the Sunshine Act and Public Records Law require so much document publication. A typical mid-size Florida county publishes hundreds of new PDFs per month. PDF tagging is a separate workstream from the HTML audit; Site Brace's audit will identify the PDF download links so the entity knows where the PDF exposure sits.

Why overlays are a poor fit for Florida public entities

Accessibility overlays are marketed heavily to Florida cities and counties. We have written about why accessibility overlays do not actually make sites WCAG-compliant in detail. For Florida specifically: overlays do not touch PDFs (the dominant exposure for Florida public entities under the Sunshine Act), and Section 282.604 Fla. Stat. is a procurement-substantiation regime. An overlay subscription does not substitute for accessible procurement.

How Site Brace audits a Florida public-entity site

The standard page mix for a Florida public-entity audit covers the high-risk surfaces:

  • Homepage
  • Department landing pages (top 4-6, varies by entity type)
  • Governing body page (County Commission, City Council, School Board, etc.)
  • Most-trafficked service pages (permits, utility billing, property tax search, public records requests)
  • Public meeting calendar
  • Constitutional-officer site landing pages (for counties)
  • Spanish-language toggle pages
  • Hurricane preparedness / emergency information page
  • ADA accessibility statement (if one exists)
  • Privacy policy, contact

That mix covers up to 25 pages depending on the entity. Audit runs axe-core 4.10, captures element-level screenshots of every contrast failure, and packages findings into a written report with copy-paste fix code and 12 re-scans included over 12 months.

Pricing is $149 flat, one-time. To see what the report looks like, view a sample report we built for a fictional municipality.

Want to check your own site first? Run a free single-page check on your homepage or your most-trafficked service page - one URL, about a minute, no signup needed to see the result.

Start a Florida public-entity audit, $149

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