Communicating Clearly: Serving People with Disabilities and Limited-English-Proficient Residents 

What Title II Means for Cities & Towns in 2025

Local governments connect with the public more than any other level of government—whether through council livestreams, permit portals, emergency alerts, or town-hall flyers. Nearly 1 in 4 U.S. adults lives with a disability, and roughly 25 million people are limited-English-proficient (LEP). Failing to reach either group risks civil-rights liability, erodes public trust, and can put lives at risk during emergencies. 

Title II of the Americans with Disabilities Act (ADA) bars state and local governments from discriminating on the basis of disability in all programs, services, and activities—online and off. Its communication provisions (28 C.F.R. § 35.160-164) require that information be “as effective” for people with disabilities as it is for everyone else and that auxiliary aids or services be provided at no extra charge and in a timely manner. 

In April 2024 the Department of Justice issued a sweeping update that finally makes digital accessibility explicit: 

• Technical Standard – WCAG 2.1 Level AA applies to all public-facing web content and mobile apps. 
• Deadlines – 
• Pop. ≥ 50 k: compliance by April 24, 2026 
• Pop. ≤ 49 ,999 and special districts: April 26, 2027  

Municipalities should budget now for remediation, procurement updates, and staff training to avoid a last-minute scramble. 

What “Effective Communication” Looks Like: 

Under § 35.160, the person with the disability—not the agency—chooses the aid that works best, unless an equally effective option exists. 

On March 1 2025, Executive Order 14224 revoked EO 13166 and declared English the official language of the United States. Important: Title VI of the Civil Rights Act still outlaws national-origin discrimination. Agencies that receive federal funds (almost every city or town) must still provide “meaningful access” for LEP residents, guided by the long-standing four-factor test (number/proportion of LEP persons served, frequency of contact, nature/importance of the program, and resources/costs). 

DOJ has signaled that new guidance will replace the rescinded EO 13166 documents; until then, the Title VI regulation and 2002 LEP Guidance remain the best road map. 

Checklist for Municipal Communicators 

Risk 

• ADA Title II – Complaints go to DOJ; settlements have required six-figure remediation plans and monitoring. 
• Title VI – Non-compliance can trigger loss of federal grants. Recent DOJ agreements with state courts (June 2024) required robust language-access overhauls, showing continued enforcement vigor. 

Inclusive communication is not just a legal checkbox—it improves civic participation, reduces service calls, and builds trust. By weaving accessibility and language equity into every touchpoint now, cities and towns will be better prepared for tomorrow’s regulatory landscape—and, more importantly, for their residents. 

Start planning today—because clear, inclusive communication is the cornerstone of good government. 

Resources 

• ADA Title II Web Rule Fact Sheet – ADA.gov  
• ADA “First Steps Toward Compliance” Guide – ADA.gov  
• 28 C.F.R. Part 35 Subpart E – Effective Communication Rules 
• DOJ LEP Resource Page – LEP.gov justice.gov 
• Federal Register 67 Fed. Reg. 41455 (2002) – Four-Factor Test Guidance – federalregister.gov