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Pennsylvania Title II accessibility: April 2026 deadline + PA Human Relations Act

Pennsylvania public-entity websites are subject to 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). The Pennsylvania Human Relations Act (43 P.S. section 951 et seq.) prohibits disability discrimination in public accommodations and is enforced by the Pennsylvania Human Relations Commission. Philadelphia and Pittsburgh add local fair-practices ordinances enforced by city-level human-rights commissions. Pennsylvania has roughly 2,500 municipalities (one of the highest counts of any state), so a large fraction of the state's compliance burden falls on small townships and boroughs that lack in-house IT capacity.

Short answer: if your entity is a Pennsylvania state agency, county, city, township, borough, school district, intermediate unit, PASSHE university, state-related university (Penn State, Pitt, Temple, Lincoln), community 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 PA Human Relations Act adds a state-court remedy; Philadelphia and Pittsburgh add local ordinances. No state damage-multiplier statute equivalent to California's Unruh Act. Site Brace audits any PA 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 Pennsylvania

1. ADA Title II (federal)

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

2. Pennsylvania Human Relations Act (43 P.S. section 951 et seq.)

The PA Human Relations Act prohibits discrimination based on disability in places of public accommodation, including state and local government entities. Enforcement is through the Pennsylvania Human Relations Commission (PHRC), which can investigate complaints, hold hearings, award damages, and order injunctive relief. The PA Human Relations Act provides for compensatory damages and attorney's fees but no statutory-damages multiplier comparable to California's Unruh Act. State-court actions under PHRA exist alongside federal-court ADA practice.

3. Philadelphia Fair Practices Ordinance and Pittsburgh Code of Ordinances (local)

For entities operating in Philadelphia or Pittsburgh, the city-level fair-practices ordinances add a local enforcement layer through the Philadelphia Commission on Human Relations and the Pittsburgh Commission on Human Relations, respectively. These ordinances generally track the state PHRA in scope but have separate procedural rules and faster timelines. City-level enforcement has been more active on physical-access cases historically; digital-accessibility enforcement is increasing but is not yet at the level of NYC.

4. Pennsylvania state IT accessibility framework

The Pennsylvania Office of Administration, Office of Information Technology maintains state IT accessibility expectations. Procurement of information technology for state-agency use is supposed to consider accessibility. The framework is less prescriptive than Texas's 1 TAC 213 or Florida's Section 282.604 but operates in the same direction.

For most PA public entities, the federal Title II rule is the load-bearing requirement; the PHRA adds a state-court remedy; the Philadelphia and Pittsburgh ordinances add local enforcement for entities in those cities.

Which Pennsylvania entities are covered

Coverage is broad:

  • All Pennsylvania state agencies (Department of Education, Department of Human Services, PennDOT, etc.)
  • 67 counties
  • Approximately 2,500 municipalities (cities, boroughs, townships, towns - PA has unusually granular local government)
  • 500 school districts
  • 29 Intermediate Units (IUs)
  • Pennsylvania State System of Higher Education (PASSHE: 10 universities)
  • State-related universities (Penn State, Pittsburgh, Temple, Lincoln)
  • 14 community colleges
  • Special districts (water and sewer authorities, port authorities, transit authorities, redevelopment authorities, and others)

The federal population threshold determines which deadline applies. Philadelphia (~1.5M residents), Pittsburgh (~300k), Allegheny County (~1.2M), and the larger PASSHE campuses fall under April 24, 2026. Many of Pennsylvania's small boroughs and townships have populations under 5,000 and fall under April 24, 2027, but the rule still applies; smallness does not exempt.

What we typically find on a Pennsylvania public-entity site

The municipal CMS ecosystem in Pennsylvania is similar to the rest of the country: CivicPlus, Granicus, OpenCities, OpenGov dominate, with custom WordPress / Drupal common at the larger entities.

Findingaxe-core ruleTypical cause
Untagged PDFs (council and supervisor agendas, RFPs, permit forms, school board packets) 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 service-request forms label Custom form builders and vendor form tools that style placeholder text as the label
Small-borough sites with severely outdated CMS Various PA's high municipality count means many entities are on circa-2010 platforms; entire-site accessibility debt rather than per-component findings
Streaming-video supervisor or council archives without captions Manual finding Live-streamed 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.
Tax-collector and assessor sites separate from main borough site Various PA's tax-collection structure varies by municipality class; separate sites have separate accessibility profiles
Heading hierarchy mistakes on department pages heading-order CMS WYSIWYG editors that allow staff to skip heading levels

The small-borough problem

Pennsylvania's roughly 2,500 municipalities include around 950 boroughs, many with populations under 2,000. These entities typically have one part-time IT contractor (or no dedicated IT), a website built in 2010 or earlier, and minimal budget for accessibility work. The April 24, 2027 deadline applies to these entities the same as to any other public entity, but the practical compliance path differs. For a small borough, the realistic path is a one-time $149 audit followed by either selective remediation of the worst findings or replatform to a modern CMS that ships closer to WCAG-conformant out of the box. Site Brace can support either path.

Why overlays are a poor fit for Pennsylvania public entities

Accessibility overlays are heavily marketed to PA municipalities. We have written about why accessibility overlays do not actually make sites WCAG-compliant in detail. For PA specifically, the small-borough situation makes overlays especially poor fit: an overlay subscription on top of a 2010-era CMS does not address the underlying markup, and the recurring cost compounds over time on entities with tight budgets. The FTC's April 2025 settlement with accessiBe makes overlay compliance claims a documented liability.

How Site Brace audits a Pennsylvania public-entity site

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

  • Homepage
  • Department landing pages (top 4-6, varies by entity type)
  • Governing body page (Borough Council, Township Supervisors, City Council, School Board, etc.)
  • Most-trafficked service pages (permits, utility billing, tax, right-to-know requests)
  • Public meeting calendar
  • Tax collector or assessor page (if separate)
  • 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 Pennsylvania public-entity audit, $149

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