Every county, municipality, school district, and special district in New Mexico must bring its website and mobile applications into conformance with WCAG 2.1 Level A and Level AA by April 26, 2028. RLEDC provides audit, remediation planning, and implementation support for local governments across the seven-county Eastern Plains region.
On April 24, 2024, the U.S. Department of Justice published a final rule under Title II of the Americans with Disabilities Act establishing a specific technical standard for the websites and mobile applications of state and local governments. The rule is codified at 28 CFR Part 35, Subpart H. It was amended by AG Order No. 6742-2026, published at 91 FR 20912 on April 20, 2026. The operative section is reproduced in full below.
28 CFR § 35.200 — Requirements for web and mobile accessibility
Title 28, Chapter I, Part 35, Subpart H — Web and Mobile Accessibility. Source: AG Order No. 5919-2024, 89 FR 31337, Apr. 24, 2024. Authority: 5 U.S.C. 301; 28 U.S.C. 509, 510; 42 U.S.C. 12134, 12131, and 12205a. Current as of July 23, 2026.
(a) General. A public entity shall ensure that the following are readily accessible to and usable by individuals with disabilities:
(1) Web content that a public entity provides or makes available, directly or through contractual, licensing, or other arrangements; and
(2) Mobile apps that a public entity provides or makes available, directly or through contractual, licensing, or other arrangements.
(b) Requirements.
(1) Beginning April 26, 2027, a public entity, other than a special district government, with a total population of 50,000 or more shall ensure that the web content and mobile apps that the public entity provides or makes available, directly or through contractual, licensing, or other arrangements, comply with Level A and Level AA success criteria and conformance requirements specified in WCAG 2.1, unless the public entity can demonstrate that compliance with this section would result in a fundamental alteration in the nature of a service, program, or activity or in undue financial and administrative burdens.
(2) Beginning April 26, 2028, a public entity with a total population of less than 50,000 or any public entity that is a special district government shall ensure that the web content and mobile apps that the public entity provides or makes available, directly or through contractual, licensing, or other arrangements, comply with Level A and Level AA success criteria and conformance requirements specified in WCAG 2.1, unless the public entity can demonstrate that compliance with this section would result in a fundamental alteration in the nature of a service, program, or activity or in undue financial and administrative burdens.
(3) WCAG 2.1 is incorporated by reference into this section with the approval of the Director of the Federal Register under 5 U.S.C. 552(a) and 1 CFR part 51. All material approved for incorporation by reference is available for inspection at the U.S. Department of Justice and at the National Archives and Records Administration ("NARA"). Contact the U.S. Department of Justice at: Disability Rights Section, Civil Rights Division, U.S. Department of Justice, 150 M St. NE, 9th Floor, Washington, DC 20002; ADA Information Line: (800) 514-0301 (voice) or 1-833-610-1264 (TTY); website: www.ada.gov. For information on the availability of this material at NARA, visit archives.gov/federal-register/cfr/ibr-locations.html or email fr.inspection@nara.gov. The material may be obtained from the World Wide Web Consortium ("W3C") Web Accessibility Initiative ("WAI"), 401 Edgewater Place, Suite 600, Wakefield, MA 01880; phone: (339) 273-2711; email: contact@w3.org; website: w3.org/TR/2018/REC-WCAG21-20180605/.
[AG Order No. 5919-2024, 89 FR 31337, Apr. 24, 2024, as amended by AG Order No. 6742-2026, 91 FR 20912, Apr. 20, 2026]
The rule splits public entities into two compliance dates by population. Every public entity in the seven-county Eastern Plains region falls on the later date.
| Entity Type | Population Threshold | Deadline | Applies in the Region |
|---|---|---|---|
| County or municipal government | 50,000 or more | April 26, 2027 | No entity in the seven counties reaches this threshold |
| County or municipal government | Less than 50,000 | April 26, 2028 | All seven counties and all 22 incorporated municipalities |
| Special district government | Any population | April 26, 2028 | School districts, conservancy and irrigation districts, and other special districts |
Curry County, the region's most populous, was estimated at 46,655 residents as of July 1, 2025 — below the 50,000 threshold. Every county, municipality, school district, and special district in the region therefore has the same compliance date: April 26, 2028.
RLEDC provides web accessibility audit and compliance support to local governments in the Eastern Plains region as part of its government services program. The work is structured in five phases so an entity can stop at any point, take the deliverables, and complete the remaining work internally or with its own vendor.
Automated testing of every page against the full WCAG 2.1 Level A and AA rule set, plus manual keyboard-only navigation, screen reader review, contrast measurement, and reflow testing at mobile widths. Documents linked from the site are inventoried and sampled. Vendor-hosted and third-party content is identified and tested separately.
A written report listing every failure, the specific WCAG success criterion it violates, where it occurs, how severe it is, and what it takes to fix. Findings are ranked so the entity can address the barriers that affect the most residents first. The report is written to be usable by a council or board, not only by a developer.
A sequenced plan with realistic effort estimates, a schedule that lands ahead of April 26, 2028, and a clear split between what the entity's existing vendor should fix under contract and what requires new work. Includes recommended procurement language for future contracts and renewals.
Where an entity has no web vendor or the vendor cannot perform the work, RLEDC can carry out the remediation directly — corrected markup, contrast-compliant styling, keyboard and screen reader support, accessible document templates, and an accessibility statement page.
Re-testing after remediation, a conformance summary recording the standard tested against and the date, and a documented file the entity can produce if its compliance is ever questioned. Documentation is as important as the fix: an entity that cannot show its work is in a weak position.
Accessibility degrades as content is added. RLEDC offers periodic re-testing and staff training on posting accessible agendas, minutes, notices, and documents, so conformance is maintained rather than rebuilt every few years.
| Deliverable | Contents |
|---|---|
| Audit results | Machine-readable and written results of automated WCAG 2.1 A and AA testing across all pages, with the testing date, tool, and rule set recorded. |
| Manual test record | Keyboard navigation, focus order, screen reader, contrast, reflow, and target size findings that automated tools cannot detect. |
| Document inventory | A list of linked PDFs and office documents, flagged for tagging, reading order, and scanned-image text. |
| Third-party inventory | Every vendor-hosted or embedded system serving content on behalf of the entity, with its conformance status and the contract implications. |
| Prioritized remediation plan | Sequenced tasks, effort estimates, responsible party, and a schedule with margin ahead of April 26, 2028. |
| Procurement language | Draft contract and RFP clauses requiring WCAG 2.1 AA conformance and evidence, for use at renewal or new solicitation. |
| Accessibility statement | A published statement page identifying the conformance standard, known limitations, alternate format procedures, and a feedback channel. |
| Verification summary | Post-remediation re-test results and a dated conformance summary for the entity's records. |
RLEDC will run an initial automated scan of an entity's public website and return a short summary of what the rule requires and roughly where the site stands. This is offered to local governments in the seven-county region at no cost as a first step.
Site size, document volume, vendor arrangements, and internal capacity determine what the work involves. RLEDC will scope the engagement against the entity's actual situation and budget cycle before any commitment.
April 26, 2028 falls late in most local fiscal years. Entities that identify the work now can place it in a budget cycle rather than treating it as an emergency. RLEDC can also assist in identifying grant funding for the work.