ADA Title II and Section 504
Federal rules now require state and local government websites and apps, and those of healthcare and human-services providers that receive HHS funding, to meet WCAG 2.1 Level AA. In 2026, both deadlines were pushed back a year. The requirements themselves didn’t change.
Last updated October 2026. General information, not legal advice.
| Who | Rule | Deadline |
|---|---|---|
| State and local governments, population 50,000 or more | ADA Title II | April 26, 2027 |
| State and local governments under 50,000, and special districts | ADA Title II | April 26, 2028 |
| HHS-funded providers with 15 or more employees | Section 504 | May 11, 2027 |
| HHS-funded providers with fewer than 15 employees | Section 504 | May 10, 2028 |
These dates come from interim rules the Justice Department and HHS issued in April and May 2026. The extensions are being challenged in federal court; if they’re overturned, the original dates, two of which have already passed, would apply again. As of October 2026, the court has not ruled. Check ADA.gov and HHS.gov for the latest.
WCAG is a long technical standard. For most public websites, the work comes down to a handful of things:
Images have text descriptions, so people using screen readers know what they show.
Every form field has a label, and errors are explained in words.
Everything works with a keyboard alone: menus, forms, pop-ups and payment pages.
Text has enough contrast to read, and pages still work when zoomed to 200%.
Videos have captions.
Documents (PDFs, agendas, forms) can be read by assistive technology, or have an accessible alternative.
The rule makes an exception for archived content: material created before the compliance date, kept only for reference, research or recordkeeping, left unchanged, and stored in a dedicated archive section. On older public sites, separating what can be properly archived from what’s still in use is often the fastest way to shrink the job. A readiness review gives you the inventory to make that call.
If a vendor builds or runs content for you (your website, a payment portal, an agenda system), it generally still counts as your content under the rule. Put those systems on your list and ask each vendor how it meets WCAG 2.1 AA.
Overlay widgets promise a one-line fix. In 2025, the Federal Trade Commission ordered a major overlay vendor to pay $1 million over claims that its AI tool could make any website WCAG-compliant.
Main site, sub-sites, payment portals, agenda and document systems, apps.
A readiness review shows where you stand and what to fix first.
And fix what’s still in use.
One template fix can repair hundreds of pages at once.
New content brings new problems; check monthly.
This page is general information, not legal advice.
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