2026-05-17 · 9 min read

Michigan Government Website Accessibility: What the DOJ Title II Rule Means for Your Agency

# Michigan Government Website Accessibility: What the DOJ Title II Rule Means for Your Agency

Michigan has 83 counties. Add the state's hundreds of municipalities, township governments, independent school districts, transit authorities, and public universities, and Michigan has one of the most geographically distributed local government landscapes in the Midwest. The DOJ Title II Final Rule applies to every one of those entities that meets the population threshold — and the largest ones face a deadline less than a year away.

If you are a Michigan government IT director, this post gives you the specific compliance requirements, who is covered, what is covered, how Michigan's DTMB accessibility framework interacts with the federal rule, and the compliance picture across Michigan's major metro areas.

Who Is Covered

The federal rule applies to state and local government entities with a total population of 50,000 or more. The April 26, 2027 deadline applies to those jurisdictions. Entities under 50,000 have until April 26, 2028 — the standard is identical; only the timeline differs. ^[1]

In Michigan, that covers:

Michigan state government — the state of Michigan and all executive branch agencies are covered. That includes the Michigan Department of Technology, Management & Budget (DTMB), the Michigan Department of Transportation (MDOT), the Michigan Department of Education (MDE), the Michigan courts web presence, and dozens of other agencies, each with their own digital properties.

Major Michigan counties — Wayne County (~1.76 million), Oakland County (~1.27 million), Macomb County (~896,000), Kent County (~666,000), Genesee County (~394,000), Washtenaw County (~377,000), Ingham County (~300,000), and Kalamazoo County (~270,000) are the most populous. ^{[3] [4] [5]} All are well above the 50,000 threshold and face the April 26, 2027 deadline.

Major Michigan cities — Detroit (~620,000), Grand Rapids (~198,000), Warren (~135,000), Sterling Heights (~134,000), Ann Arbor (~124,000), Lansing (~112,000), Dearborn (~94,000), Livonia (~93,000), Flint (~79,000), and Westland (~80,000) are all above 50,000. Each city is an independently covered entity.

Transit authorities — the Suburban Mobility Authority for Regional Transportation (SMART), the Detroit Department of Transportation (DDOT), the Ann Arbor Area Transportation Authority (TheRide), and the Rapid (Grand Rapids Area Transit) are all independently covered entities. Transit websites, trip planners, mobile apps, and schedule PDFs are in scope. ^[11]

Public universities and community colleges — the University of Michigan (~47,000 students), Michigan State University (~52,000 students), Wayne State University, Western Michigan University, Eastern Michigan University, and other public institutions with populations above 50,000 are independently covered. Community colleges with smaller enrollment fall in the April 2028 tier.

School districts — Michigan has approximately 540 public school districts. Districts with enrollment above 50,000 face the April 2027 deadline; smaller districts have until April 2028. Compliance obligations extend to the district's website, parent portals, student information systems, and published documents.

Libraries, transit authorities, port authorities, and other special districts — Michigan has numerous independent special-purpose public entities. Each must assess whether its own population or service area places it in the April 2027 or April 2028 tier.

What Is Covered

The rule covers web content and mobile apps that a public entity makes available to the public or uses to offer services, programs, or activities. ^[2] For Michigan government entities, that includes:

• The main public website and all subdomains
• Web-based applications residents use: permit portals, utility payment systems, licensing applications, benefits portals, registration forms
• Mobile apps distributed to the public
• Documents published through any of the above: PDFs, Word files, spreadsheets, presentations

Third-party content procured or controlled by the agency falls under the obligation. If you contracted a vendor to build your permit portal, that system must meet WCAG 2.1 AA. The compliance responsibility transfers to you as the contracting entity. Every technology contract signed after your compliance date should include WCAG 2.1 AA conformance as a mandatory deliverable.

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Michigan's State Accessibility Framework: DTMB

Michigan adds a state-level compliance layer through the Department of Technology, Management & Budget (DTMB). DTMB is responsible for statewide IT policy and publishes an accessibility standard that requires Michigan executive branch agencies to conform to WCAG 2.1 Level AA. ^[6] DTMB's role encompasses procurement policy, vendor management, and technical standards for state agency digital properties.

For Michigan state agencies, this means two compliance frameworks run in parallel: the DTMB state standard and the DOJ Title II Final Rule. The substantive target — WCAG 2.1 Level AA — is the same under both. The enforcement mechanisms are distinct: the state framework is enforced through DTMB administrative channels; the federal rule is enforced through DOJ complaint investigations and, ultimately, federal court.

Michigan's DTMB accessibility framework also means that state agencies have had institutional exposure to WCAG 2.1 AA requirements longer than agencies in states without equivalent state policy. That institutional history does not guarantee compliance — agencies outside the DTMB procurement pathway, the Michigan courts, and state-affiliated entities may have uneven compliance — but it creates a baseline of policy awareness that is absent in some other states.

Local governments in Michigan — counties, cities, townships, transit authorities, school districts — are primarily subject to the federal DOJ rule rather than the DTMB state standard. The technical requirement is identical: WCAG 2.1 Level AA.

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What WCAG 2.1 Level AA Requires

WCAG 2.1 Level AA has 50 success criteria organized under four principles. ^[8]

Perceivable — content must be presentable in ways users can perceive. Alt text for informational images. Captions for video. Transcripts for audio. Sufficient color contrast: 4.5:1 for normal text, 3:1 for large text. Content that reflows to a single column at 320px without horizontal scrolling.

Operable — all functionality must work without a mouse. Keyboard navigation must reach every interactive element. No time limits that trap users. No content that flashes more than three times per second. Skip navigation links that allow users to jump past repeated header elements.

Understandable — the language of the page must be declared in HTML so screen readers pronounce content correctly. Forms must include visible labels, error messages that identify what is wrong, and suggestions for how to fix it. Navigation must be consistent across pages.

Robust — HTML must be valid, with proper ARIA roles and attributes so assistive technology can parse and interact with the interface.

The WebAIM Million 2024 report found that 95.9% of home pages had detectable WCAG 2 failures. ^[9] The five most common: low contrast text (81%), missing alt text (54.5%), missing form labels (48.6%), empty links (44.6%), and missing document language (17.1%). Michigan government sites follow the same failure patterns seen nationally.

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The Three Most Common Failure Categories for Michigan Government Sites

1. PDF accessibility. Michigan government entities publish extensive volumes of PDFs — budget documents, ordinances, meeting minutes, permit applications, public records requests, road plans, court forms, and regulatory guidance. Most of these are inaccessible. Scanned-image PDFs — common for older records — are unreadable by screen readers. Even digitally created PDFs typically lack the tag structure, reading order, and accessible form fields WCAG requires. The rule covers PDFs when they provide access to government services, programs, and activities. ^[7]

2. Accessible forms for government services. Michigan government permit portals, tax payment systems, licensing applications, benefits portals, and registration systems commonly fail WCAG 1.3.1 (form fields lack programmatically associated labels), 3.3.1 (errors not identified in text), and 3.3.3 (no suggestions provided for correcting errors). When a resident cannot complete a permit application or pay a utility bill because the form is inaccessible, it is a service failure, not just a technical gap.

3. Keyboard inaccessibility in complex interactions. Custom navigation menus, interactive maps, GIS-based interfaces, date pickers, and modal dialogs — common in Michigan permit portals, property search tools, and transit applications — frequently trap keyboard users or become unreachable without a mouse. WCAG 2.1.1 (Keyboard), 2.1.2 (No Keyboard Trap), and 2.4.7 (Focus Visible) are among the most common failures that automated scanners cannot detect.

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Compliance Timeline for Michigan Entities

Michigan covered entities have until April 26, 2027. A realistic WCAG compliance program for a mid-size Michigan government entity:

• Weeks 1–4: Scope the digital footprint — inventory all web properties, subdomains, mobile apps, and document repositories.
• Weeks 5–12: Commission an audit covering automated scanning, manual testing with assistive technology (NVDA, JAWS, VoiceOver), and document review.
• Weeks 13–24: Remediation planning — prioritize findings by severity and service impact, assign ownership, set milestones.
• Weeks 25–40: Remediation — developers fix code, document teams reformat PDFs, procurement adds WCAG requirements to new vendor contracts.
• Weeks 41–48: Validation testing — re-test against WCAG 2.1 AA to confirm remediation is complete.
• Weeks 49–52: Publish an accessibility statement, establish ongoing monitoring, train staff.

Entities that begin now have a realistic path to April 2027 compliance. Entities that delay past fall 2026 will not.

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Michigan's Major Metro Compliance Profiles

Wayne County / Detroit. Michigan's most populous county and largest city. Wayne County government, the City of Detroit (~620,000), SMART transit, DDOT, and Detroit Public Schools Community District all face the April 26, 2027 deadline. Detroit has historically been one of the most-sued cities for ADA violations in the country — enforcement risk here is not theoretical. The City of Dearborn (~94,000), City of Livonia (~93,000), and City of Sterling Heights (~134,000) are also independently covered Wayne County suburban cities. See the detailed Wayne County and Detroit compliance guide.

Oakland County / Pontiac. Michigan's second most populous county (~1.27 million). Oakland County government, the City of Pontiac (~61,000), Troy, Southfield, and other Oakland County cities above 50,000 are independently covered entities with April 2027 deadlines.

Macomb County / Sterling Heights. Macomb County (~896,000), the City of Sterling Heights (~134,000), and the City of Warren (~135,000) all face the April 2027 deadline as independently covered entities.

Kent County / Grand Rapids. Kent County (~666,000), the City of Grand Rapids (~198,000), and the Rapid transit authority are independently covered. Grand Rapids is Michigan's second-largest city, with a growing tech and healthcare industry workforce creating above-average enforcement awareness.

Genesee County / Flint. Genesee County (~394,000) and the City of Flint (~79,000) are independently covered with April 2027 deadlines. Flint's experience with digital service failures during the water crisis created lasting community scrutiny of government information systems.

Washtenaw County / Ann Arbor. Washtenaw County (~377,000), the City of Ann Arbor (~124,000), the University of Michigan (~47,000 students), and TheRide transit are all independently covered. The University of Michigan's large disability services infrastructure and active accessibility community create above-average enforcement awareness in the Ann Arbor area.

Ingham County / Lansing. Ingham County (~300,000) and the City of Lansing (~112,000) — Michigan's state capital — are independently covered with April 2027 deadlines. State agency presence in Lansing creates concentrated enforcement awareness.

Kalamazoo County. Kalamazoo County (~270,000) and the City of Kalamazoo (~71,000) are independently covered with April 2027 deadlines.

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Michigan County-Level Compliance Guides

Detailed compliance guidance for Michigan's major counties:

• Wayne County Michigan government website accessibility — Wayne County government, City of Detroit, SMART, DDOT, DPSCD, Dearborn, Livonia, Sterling Heights, and WCCCD

For comparison with Michigan's compliance picture, see:

• Ohio government website accessibility — 88 counties, GCRTA, COTA, Cincinnati Metro, and the full Title II compliance picture for a neighboring Great Lakes state
• Franklin County Ohio government website accessibility — the Ohio state capital county compliance profile
• Government website ADA compliance 2027 — the complete guide to the federal rule and April 2027 deadline

This post is informational and does not constitute legal advice. Each government entity should consult with qualified legal counsel regarding its specific compliance obligations.

Morton Technology Consulting LLC — WCAG 2.1 AA audits for Florida government agencies. Parallax audit → · WCAG Readiness Kit → · All posts →