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Michigan Title II accessibility: April 2026 deadline + PWDCRA + DTMB IT accessibility

Michigan public-entity websites face the federal DOJ Title II rule (April 2024) with 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). Michigan adds two state-level layers. The Persons with Disabilities Civil Rights Act (PWDCRA, MCL 37.1101 et seq.) prohibits disability discrimination in employment, education, and public accommodations and is enforced by the Michigan Department of Civil Rights. The Michigan Department of Technology, Management and Budget (DTMB) maintains a state-IT accessibility policy that references WCAG conformance for state-agency systems. Michigan does not have a damage-multiplier statute equivalent to California's Unruh Act; the PWDCRA provides actual damages and attorney's fees but no statutory multiplier.

Short answer: if your entity is a Michigan state agency, county, municipality, township, school district, intermediate school district (ISD), community college, public university, library system, 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 PWDCRA adds a state-law cause of action. DTMB's state-agency IT policy applies to state agencies but not directly to local entities. Site Brace audits any Michigan 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 Michigan

1. ADA Title II (federal)

The DOJ April 2024 final rule is the load-bearing requirement for Michigan public entities. Coverage and deadlines as above. See the DOJ Title II primer for the federal-rule overview.

2. Michigan Persons with Disabilities Civil Rights Act (PWDCRA, MCL 37.1101 et seq.)

The PWDCRA prohibits discrimination based on disability in employment, education, public services, and public accommodations. Enforcement is through the Michigan Department of Civil Rights (MDCR). Remedies include actual damages, injunctive relief, and attorney's fees; there is no statutory-damages multiplier. A Michigan entity sued for website inaccessibility typically faces a federal Title II claim with an optional PWDCRA claim layered alongside.

3. DTMB state-IT accessibility policy

The Michigan Department of Technology, Management and Budget consolidates IT services for the state-government executive branch. DTMB's accessibility standard references WCAG conformance and is enforced through procurement review and state-agency IT governance. The policy applies to state-government agencies served by DTMB and does not directly cover counties, municipalities, townships, school districts, or special districts, which fall under the federal DOJ Title II rule for their own websites.

For most Michigan public entities, the federal Title II rule and the PWDCRA are the load-bearing pieces. State agencies have the DTMB policy on top. Michigan does not stack a damage-multiplier layer the way California does.

Which Michigan entities are covered

Coverage is broad:

  • All Michigan state agencies served by DTMB
  • 83 counties
  • Approximately 280 cities
  • Approximately 260 villages
  • 1,240 townships (Michigan is one of the strongest township-government states; many townships run their own websites)
  • 540 school districts (K-12) plus 56 intermediate school districts (ISDs) and approximately 400 charter-school authorities
  • 28 community colleges in the Michigan Community College system
  • 15 public universities (University of Michigan and its regional campuses, Michigan State, Wayne State, Western Michigan, Eastern Michigan, Central Michigan, Northern Michigan, Michigan Tech, Lake Superior State, Ferris State, Saginaw Valley State, Oakland, Grand Valley State, plus the affiliated schools)
  • Public library systems and library cooperatives
  • Special districts: airport authorities, drain commissions, road commissions, mass-transit authorities (DDOT in Detroit, SMART for the suburbs, The Rapid in Grand Rapids), port authorities, conservation districts

The federal population threshold determines which deadline applies. Wayne County (1.79M), Oakland County (1.27M), Macomb County (875K), Kent County (665K), Genesee County (400K), and Washtenaw County (375K) fall under April 24, 2026. The metros of Detroit (630K), Grand Rapids (200K), Warren (140K), Sterling Heights (135K), Ann Arbor (125K), Lansing (115K), Flint (80K), Dearborn (110K), Livonia (95K), and Westland (80K) also fall under April 24, 2026 either through their own population or through county-level coverage. Smaller villages, townships, and rural counties have until April 24, 2027.

What we typically find on a Michigan public-entity site

The municipal CMS ecosystem in Michigan looks like the rest of the country. CivicPlus, Granicus, OpenCities, Revize, and Streamline serve a large share of Michigan counties and cities; townships often run lighter custom WordPress or older platforms. The 1,240 townships in particular are heterogeneous in platform and accessibility baseline.

Findingaxe-core ruleTypical cause
Untagged PDFs (board agendas, RFPs, public-records requests, permit forms) Manual finding PDFs exported from Word without accessibility tagging
Color contrast on navigation, calls to action, and table cells color-contrast Vendor CMS template colors that fail 4.5:1
Form fields without labels on permit and public-records request forms label Custom form builders and vendor form tools that style placeholder text as label
Township-site clutter from older CMS or legacy custom builds Various Michigan has 1,240 townships, many on circa-2010 platforms with significant accessibility debt
Streaming-video board archives without captions Manual finding Live-streamed council and township-board meetings posted without post-production captioning
aria-label on generic elements aria-prohibited-attr CMS theme customizations or overlay injection. See aria-label on a div.
Heading hierarchy mistakes on department and program pages heading-order CMS WYSIWYG editors that allow staff to skip heading levels
Document libraries with non-descriptive link text link-name Long lists of "Click here" or "Download" links rather than meaningful titles

Notes on Michigan's largest metros and the township layer

Detroit, Grand Rapids, and Ann Arbor each have dedicated city web teams that have iterated on accessibility for years. Recent city-level redesigns generally ship cleaner accessibility baselines than older county or township platforms. The metro Detroit ecosystem covers a parent city plus the larger suburban cities (Warren, Sterling Heights, Dearborn, Livonia, Troy, Farmington Hills, Westland, Southfield), each operating its own website under Title II. The Wayne, Oakland, and Macomb county sites add another large surface area. Township sites are a meaningful share of Michigan public-entity web content because of the active township-government layer, and a township site is just as covered as a city site of the same population.

Why overlays are a poor fit for Michigan public entities

Accessibility overlays are heavily marketed to Michigan townships and rural counties. We have written about why accessibility overlays do not actually make sites WCAG-compliant in detail. For Michigan specifically: DTMB's state-agency policy is a substantiation regime, and an overlay subscription does not substantiate. Local entities face the same Title II substantiation expectation. The FTC's April 2025 settlement with accessiBe makes overlay compliance claims a documented liability that Michigan municipal attorneys are tracking.

How Site Brace audits a Michigan public-entity site

The standard page mix for a Michigan public-entity audit:

  • Homepage
  • Department landing pages (top 4-6, varies by entity type)
  • Governing body page (City Council, Township Board, County Board of Commissioners, Board of Education, etc.)
  • Most-trafficked service pages (permits, utility billing, property tax, public-records requests)
  • Public meeting calendar
  • Document library or board-agenda archive
  • ADA accessibility statement (if one exists)
  • Privacy policy, contact

That mix covers up to 25 pages depending on the entity. The 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 Michigan public-entity audit, $149

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