Morton Digital

2026-05-17 · 8 min read

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

Abstract dark editorial illustration: a Texas state government compliance network rendered in fine copper line work on dark slate, with WCAG accessibility markers at county nodes representing Harris, Dallas, Bexar, Tarrant, and Travis counties. No text.

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

Texas has 254 counties — more than any other state. Add the state's thousands of independent school districts, transit authorities, community college districts, river authorities, and municipal utility districts, and Texas has one of the most complex local government landscapes in the United States. The DOJ Title II Final Rule applies to every one of those entities that meets the population threshold. The April 26, 2027 deadline is eleven months away.

If you are a Texas government IT director and you have not started your WCAG 2.1 accessibility program, this post gives you the specific compliance requirements, who is covered, what is covered, what the Texas state law adds, and the compliance picture for the state'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 — but the standard is identical; only the timeline differs. [1]

In Texas, that covers:

State government — The state of Texas itself and all state agencies are covered. Texas state government entities include the Texas Department of Transportation (TxDOT), Texas Health and Human Services (HHSC), the Texas Education Agency (TEA), the Office of the Secretary of State, the Texas Department of Motor Vehicles, Texas courts, and dozens of other agencies — each with their own web properties.

Major counties — Harris County (~4.7M), Dallas County (~2.6M), Bexar County (~2.1M), Tarrant County (~2.1M), and Travis County (~1.3M) are the five most populous. Collin County (~1.1M), Denton County (~920K), El Paso County (~870K), Hidalgo County (~880K), and Fort Bend County (~830K) follow. All are clearly covered with the April 2027 deadline. [10]

Independent school districts — Texas has more than 1,000 ISDs. Houston ISD (~175K students), Dallas ISD (~140K students), Cypress-Fairbanks ISD, Northside ISD, Fort Worth ISD, and dozens of other large ISDs are independently covered entities. The school district's own websites, parent portals, student information systems, and published documents all fall under the rule. [13]

Transit authorities — The Metropolitan Transit Authority of Harris County (METRO), Dallas Area Rapid Transit (DART), VIA Metropolitan Transit (San Antonio), Capital Metropolitan Transportation Authority (CapMetro, Austin), and Trinity Metro (Fort Worth) are each independently covered. Transit websites, trip planners, mobile apps, and schedule PDFs are all in scope. [11]

Community college districts — Houston Community College (~70K students), Dallas College (formerly Dallas County Community College District), Lone Star College System, Austin Community College, Tarrant County College, and San Antonio College are public entities independently covered by the rule. [14]

Special districts — Water authorities, hospital districts, flood control districts, port authorities, and housing authorities are Title II entities. The Harris County Flood Control District, the Port of Houston Authority, and similar entities have compliance obligations for their own digital properties.

If a Texas government entity had any doubt about whether it is covered, the answer is almost certainly yes.

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. For Texas government entities, that includes: [12]

Third-party content procured or controlled by the agency falls under the obligation. If you contracted a vendor to build your permit system, that system must meet WCAG 2.1 AA — the compliance responsibility transfers to you as the contracting entity, not to the vendor alone.

This is the most commonly missed compliance obligation in government procurement. Every technology contract executed after your compliance date should include WCAG 2.1 AA conformance as a mandatory deliverable with testing requirements and remediation timelines.

What WCAG 2.1 Level AA Requires

WCAG 2.1 Level AA has 50 success criteria organized under four principles. [7]

Perceivable — content must be presentable in ways users can perceive, regardless of ability. This means 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), and content that can be resized to 200% without horizontal scrolling.

Operable — all functionality must work without a mouse. Keyboard navigation must reach every interactive element. No time limits should trap users. Content that flashes more than three times per second must be eliminated or controlled. Skip navigation links must allow users to jump to main content without tabbing through the entire header.

Understandable — the language of the page must be identified in the 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 use of 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. 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%). [8] [9] Government sites are not outliers — they follow the same failure patterns.

Texas State Law: Chapter 2054, Subchapter M

Texas adds a state-law compliance layer that predates the federal rule. Texas Government Code Chapter 2054, Subchapter M requires Texas state agencies to make their electronic and information resources (EIR) accessible to people with disabilities. [5]

The Texas Department of Information Resources (DIR) oversees this requirement and publishes accessibility standards, technical guidance, templates, and compliance resources for state agencies. [6] The DIR framework aligns with Section 508, which in turn incorporates WCAG 2.1 AA — so the state and federal compliance targets are substantively the same, even though they derive from different legal authorities.

For Texas state agencies, this means two compliance obligations run in parallel: the Texas EIR accessibility requirement (enforced by DIR and the Texas Governor's Committee on People with Disabilities) and the DOJ Title II Final Rule. The substantive standard is the same; the enforcement mechanisms are additive.

Local government entities — counties, cities, ISDs, transit authorities, community colleges — are primarily subject to the federal DOJ rule rather than the Chapter 2054 state obligation, which applies specifically to state agencies. But the standard they must meet is the same.

The Three Most Common Failure Categories for Texas Government Sites

Based on the WebAIM Million data and the structural characteristics of Texas government digital footprints, three failure categories appear most frequently:

1. PDF accessibility. Texas government entities publish enormous volumes of PDFs: budget documents, meeting minutes, ordinances, permit applications, transportation plans, emergency management documents, court filings, benefits summaries. Most of these are not accessible. Scanned-image PDFs — common for older documents — are completely inaccessible to screen readers. Even digitally created PDFs typically lack the tagged structure, reading order, alternative text for charts, and accessible form fields that WCAG requires. The rule covers PDFs when they are used to provide access to government programs, services, and activities. [12]

2. Forms without accessible labels. Texas government permit portals, licensing systems, benefits applications, and registration systems commonly fail WCAG 1.3.1 (form fields lack programmatically associated labels), 3.3.1 (errors are not identified in text), and 3.3.3 (no suggestions are provided for how to fix errors). When a resident cannot complete a permit application, pay a utility bill, or register for a government service because the form is inaccessible, it is a service access failure — not just a technical compliance gap.

3. Keyboard inaccessibility in complex interactions. Custom navigation menus, date pickers, modal dialogs, dropdown selectors, and map-based interfaces — common in Texas permit portals, property search tools, and GIS-based 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.

Compliance Timeline for Texas Entities

Texas covered entities have until April 26, 2027. From today, that is approximately eleven months.

A realistic WCAG compliance program for a mid-size Texas government entity takes this shape:

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

Texas County-Level Compliance Guides

The rule applies uniformly, but compliance complexity varies by the size and scope of a government's digital footprint. Detailed compliance guidance for Texas's major counties is available here:

For a comparison with another large-state compliance picture, see Florida government website accessibility, which has 67 counties and 411 municipalities under the same rule.

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

Sources

  1. [1] Federal Register — Interim Final Rule extending Title II compliance dates (April 20, 2026) — "The compliance date for State and local government entities with a total population of 50,000 or more is extended from April 24, 2026, to April 26, 2027"
  2. [2] ADA.gov — DOJ Fact Sheet: New Rule on Accessibility of Web Content and Mobile Apps — "State and local governments must make sure that their web content and mobile apps meet WCAG 2.1, Level AA"
  3. [3] U.S. Census Bureau — QuickFacts Texas — "Texas has 254 counties, more than any other state."
  4. [4] U.S. Census Bureau — QuickFacts Harris County, Texas — "Harris County, Texas — Population estimates, July 1, 2023: 4,728,030"
  5. [5] Texas Department of Information Resources — EIR Accessibility Policy — "Texas Government Code, Chapter 2054, Subchapter M, requires state agencies to make their electronic and information resources (EIR) accessible to people with disabilities."
  6. [6] Texas Department of Information Resources — Accessibility — "DIR provides accessibility resources, standards, and tools to help state agencies meet their obligations under Texas law and federal requirements."
  7. [7] W3C Web Accessibility Initiative — WCAG 2.1 Specification — "Web Content Accessibility Guidelines (WCAG) 2.1 covers a wide range of recommendations for making Web content more accessible. Following these guidelines will make content more accessible to a wider range of people with disabilities."
  8. [8] WebAIM — The WebAIM Million: An Annual Accessibility Analysis of the Top 1,000,000 Home Pages (2024) — "In 2024, 95.9% of home pages had detectable WCAG 2 failures. The average error count was 56.8 errors per page."
  9. [9] WebAIM — The WebAIM Million 2024 — "The most common WCAG 2 failures were: low contrast text (81.0%), missing alternative text (54.5%), missing form labels (48.6%), empty links (44.6%), and missing document language (17.1%)."
  10. [10] U.S. Census Bureau — QuickFacts Texas — "Dallas County estimated population 2,606,617; Tarrant County 2,110,640; Bexar County 2,096,671; Travis County 1,310,975; Collin County 1,097,621; Denton County 920,423."
  11. [11] ADA.gov — DOJ Fact Sheet: New Rule on Accessibility of Web Content and Mobile Apps — "Transit authorities are state and local government entities covered by Title II of the ADA and must comply with the web accessibility rule."
  12. [12] ADA.gov — DOJ Fact Sheet: New Rule on Accessibility of Web Content and Mobile Apps — "The rule covers all web content and mobile apps that a public entity makes available to the public or uses to offer its services, programs, or activities, including documents posted to a website."
  13. [13] U.S. Census Bureau — QuickFacts Texas — "Texas has over 1,000 independent school districts serving approximately 5.4 million public school students."
  14. [14] ADA.gov — DOJ Fact Sheet: New Rule on Accessibility of Web Content and Mobile Apps — "Public universities and community colleges are state and local government entities covered by Title II of the ADA."

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