Does Title III apply to our city website?

No. Cities and townships are public entities under Title II. Title III is for private businesses open to the public.

What yardstick does Title II use for the public website?

The 2024 web rule names WCAG 2.1 Level AA for covered public web content and mobile apps. ActaPack does not certify conformance.

Title II vs Title III for city websites

title-ii

title-iii

Title II

The ADA rule that city and township public websites must work for people with disabilities. What Title II is

of the ADA is the part of federal law that covers cities, towns, and townships. Title III covers private businesses open to the public. When someone asks whether the city website must work for people with disabilities, they usually mean Title II — not a storefront rule.

Who this is for

A clerk, administrator, or website vendor who heard “ADA website compliance” and isn’t sure whether that means Title II (public entities) or Title III (stores, hotels, banks).

Same statute. Different titles. Different duties.

The short split

	Title II	Title III
Who	State and local government	Private businesses open to the public
Website job	Public entity websites and apps under the 2024 web rule	Often discussed in commercial “ADA website” marketing
City or township site	This title covers your public website	Not the rule for government sites

Read What Title II is for the one-screen why. Read Who it is for and Who it isn’t when a vendor pitch sounds like a storefront checklist.

Why the mix-up happens

Vendors who sell overlays and widgets often write for Title III shoppers (“does my website have to be ADA compliant?”) and then reuse the same language for cities. A clerk who Googles that phrase lands on commercial pages that never name Title II, 28 CFR 35.200, or the 2027 / 2028 start dates by population.

For dates and duties, start with the ADA.gov fact sheet on the web rule and the Title II regulations. Vendor posts often mix in Title III fine charts meant for stores — cities should read If you miss instead.

What to do with the mix-up

Name Title II and the public website in the same sentence when you brief council.
Ask the website vendor whether their quote is for a widget, a suite, or a dated file of the content.
Keep a monthly dated record. The start dates do not wait for a stamp.

ActaPack’s written offer stays: $8,400/year. Dated monthly file and ticket list for your public site. We do not certify compliance.

For implementers

Scope tickets to public pages and in-scope public PDFs. Do not treat overlay widgets as the WCAG method. Cite 28 CFR 35.200 when a product page says “ADA compliant” without naming Title II.

This month

Keep a dated record that someone looked at the public pages this month. Forward tickets to the website vendor. We do not certify that the site meets the federal standard.

Questions people ask

Does Title III apply to our city website?: No. Cities and townships are public entities under Title II. Title III is for private businesses open to the public.
What yardstick does Title II use for the public website?: The 2024 web rule names WCAG 2.1 Level AA for covered public web content and mobile apps. ActaPack does not certify conformance.