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Texas Title II accessibility: April 2026 deadline + the 1 TAC 213 state standard

Texas has the largest public-entity footprint of any state outside California: 254 counties, more than 1,200 school districts, around 1,200 incorporated cities and towns, and roughly 3,400 special districts. All of them are subject to the federal DOJ Title II final rule (April 2024), which requires WCAG 2.1 Level AA conformance on websites by April 24, 2026 for entities serving populations of 50,000 or more (April 24, 2027 for smaller entities and all special-purpose districts). Texas does not have an Unruh-equivalent state statute that multiplies damages on ADA claims, so the federal rule is the load-bearing requirement for Texas public entities. The Texas Department of Information Resources (DIR) maintains state-level accessibility standards in 1 TAC chapter 213 that operate alongside the federal rule for state agencies.

Short answer: if your entity is a Texas state agency, county, city, town, school district, ISD, ESC, community college, university system campus, 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). Texas state agencies additionally fall under 1 TAC chapter 213 (the DIR accessibility standard) which has required WCAG conformance since 2006 and was updated to align with WCAG 2.1 AA in 2019. There is no Texas damage-multiplier statute analogous to California's Unruh Act; the federal Title II rule is the primary requirement. Site Brace audits any Texas 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 Texas

1. ADA Title II (federal)

The Americans with Disabilities Act Title II applies to all state and local government activities in Texas. The DOJ's April 2024 final rule made the web-content requirements explicit and set the April 2026 and April 2027 deadlines. For Texas, this is the regulation that drives most of the work.

2. Texas DIR accessibility standards (1 TAC chapter 213)

The Texas Department of Information Resources publishes the state-agency accessibility standard at 1 Texas Administrative Code chapter 213. The standard requires Texas state agencies to ensure their websites and applications conform to WCAG 2.1 Level AA. It pre-dates the federal Title II web rule (the DIR standard has required some level of WCAG conformance since 2006) and was updated to align with WCAG 2.1 AA in 2019.

The DIR standard applies to Texas state agencies, institutions of higher education in the state university systems, and entities that receive significant state funding. It does not directly apply to local-government entities (counties, cities, school districts), which are covered instead by the federal DOJ Title II rule.

3. Texas Human Resources Code chapter 121

Texas Human Resources Code chapter 121 prohibits discrimination against persons with disabilities in places of public accommodation. The chapter is enforced through civil action and provides for actual damages and attorney's fees. Texas state-court website-accessibility cases under chapter 121 exist but are far less common than federal ADA Title III filings; the Texas plaintiff-side bar has not built the same repeat-filer infrastructure that NY and California have. There is no statutory-damages multiplier comparable to California's Unruh Act.

For most Texas public entities, the federal Title II rule is the load-bearing requirement. The DIR standard adds detail for state agencies. Texas state-court remedies exist but are modest enough that the federal rule and federal-court ADA practice are where the practical compliance pressure sits.

Which Texas entities are covered

Coverage is broad:

  • All Texas state agencies (Department of Public Safety, Health and Human Services Commission, Department of Transportation, etc.)
  • 254 counties
  • Approximately 1,200 incorporated cities and towns
  • 1,200+ independent school districts (ISDs)
  • 20 Education Service Centers (ESCs)
  • 50 community college districts (75+ campuses)
  • The University of Texas System (14 institutions), Texas A&M University System (11 institutions), Texas State University System (8 institutions), University of Houston System, Texas Tech University System, University of North Texas System, Texas Woman's University, plus standalone publics
  • Approximately 3,400 special districts (water, hospital, navigation, conservation, MUDs, and others)

The federal population threshold determines which deadline applies. Major Texas metros (Houston, Dallas, San Antonio, Austin, Fort Worth, El Paso, and their county governments) and the larger ISDs serve populations well over 50,000 and fall under the April 24, 2026 deadline. Smaller rural counties, towns, and special districts have until April 24, 2027.

What we typically find on a Texas public-entity site

Across Texas public-entity sites Site Brace has scanned (or reviewed in published complaints), the same WCAG failures recur. The municipal CMS ecosystem in Texas is similar to the rest of the country; CivicPlus, Granicus, OpenCities, and OpenGov dominate the vendor market.

Findingaxe-core ruleTypical cause
Untagged PDFs (commissioners court agendas, ISD board packets, RFPs, permit applications) Manual finding PDFs exported from Word without accessibility tagging
Color contrast on navigation, calls to action, and data tables color-contrast Vendor-provided 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 label
Streaming-video commissioners court archives without captions Manual finding Live-streamed meetings posted without post-production captioning
"Open Records Request" (Texas Public Information Act) forms missing labels label Custom-built TPIA forms not tested for accessibility
Spanish-language toggle generates inaccessible markup label, color-contrast Translation tools inserted without accessibility verification; Texas Government Code chapter 2054 has language-access expectations for state agencies
aria-label on generic elements aria-prohibited-attr CMS theme customizations or accessibility-overlay injection. See aria-label on a div.
Heading hierarchy mistakes on department pages heading-order CMS WYSIWYG editors that allow staff to skip heading levels

Why overlays are a poor fit for Texas public entities

Accessibility-overlay vendors are marketed to Texas municipalities and ISDs. We have written about why accessibility overlays do not actually make sites WCAG-compliant in detail. For Texas public entities specifically, two considerations stand out:

  • Title II and the DIR standard are both substantiation regimes. DOJ can request evidence of WCAG conformance; DIR can audit state-agency conformance. An overlay subscription is not evidence; the underlying HTML is what the regulator tests.
  • The FTC fined accessiBe $1 million in April 2025 for marketing the kind of compliance claim the overlay category has been making. A Texas entity citing an overlay subscription as evidence of compliance would face the same substantiation problem.

How Site Brace audits a Texas public-entity site

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

  • Homepage
  • Department landing pages (top 4-6, varies by entity type)
  • Governing body page (Commissioners Court, City Council, ISD Board of Trustees, etc.)
  • Most-trafficked service pages (permits, utility billing, property tax, TPIA requests)
  • Public meeting calendar
  • Language access / Spanish toggle pages
  • ADA accessibility statement (if one exists)
  • Privacy policy, contact, employment

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 Texas public-entity audit, $149

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