Web Accessibility Compliance Deadlines for 2027 and 2028

On April 20, 2026, the U.S. Department of Justice (DOJ) extended digital accessibility guidelines by one year(opens in a new tab). Four days before state and local governments were due to bring their websites into compliance, the DOJ pushed the date back to 2027 and 2028, respectively. Weeks later, the Department of Health and Human Services(opens in a new tab) (HHS) did the same for healthcare organizations that receive federal funding.

While it’s easy to read the extension as a reprieve, this one is not. The dates moved; obligations to make online content accessible did not. People can still take legal action against organizations with inaccessible content during the extension, and the DOJ has said it fully anticipates enforcing the rule when the new deadline arrives.

The extra year is a time to build, not a time to wait. 

Below, you’ll learn which deadline applies to your organization, what each rule actually requires, and what the risks of missing the deadline are.

What the Extensions Changed, and What They Didn’t

What each rule delayed is narrow: only the date by which conformance to the Web Content Accessibility Guidelines(opens in a new tab) (WCAG) 2.1 Level AA becomes specifically required. Everything underneath that date is untouched and currently active. 

Title II has banned disability discrimination for years, and courts have used it to support web accessibility claims long before any technical standard existed. Section 504's nondiscrimination duty is just as active. The practical result: people can sue over an inaccessible site right now, during the extension. They do not have to wait for 2027 or 2028.

The DOJ also explained its viewpoint on the extension. In the Interim Final Rule, it stated that it “fully anticipates implementing the regulation at the new deadline”, language legal observers have read as a clear signal that enforcement actions are likely once the 2027 and 2028 dates arrive. 

The Standard is WCAG 2.1 Level AA

Both ADA Title II and the HHS rule adopt the same technical standard: WCAG 2.1 Level AA. This is the specific, measurable benchmark your web content and mobile apps must meet. These guidelines include roughly 50 success criteria covering accessibility features like alt text for images, captions for videos, keyboard operability, assistive technology compatibility, sufficient color contrast, and more. 

It helps to be precise about what WCAG is. WCAG is not itself a law. It is a technical standard, and the ADA and Section 504 are the laws that now require you to meet it. So when people ask whether WCAG is "the law," the accurate answer is that WCAG is the standard the law makes mandatory.

That standard also reaches further than many organizations expect. Title II covers not just the content your own team builds, but content delivered through vendors, licensors, embedded tools, and documents like PDFs. If it lives on your site, it counts, even if someone else made it.

Legal document with accessibility icon on the top; a gavel is to the left of the document and two large books on the right.

What the Deadline Means for Your Type of Organization

State and Local Governments Serving 50,000+ 

Larger jurisdictions face the earliest Title II deadline: April 26, 2027. Cities, counties, and the agencies they run must bring their websites and mobile apps into compliance with WCAG 2.1 AA by that date. A year disappears fast when you're applying accessibility fixes to a site at scale. Audits, fixes, and re-testing take months, and the work only grows the longer it waits.

Read more about State and Local Government ADA requirements.

Smaller Governments and Special Districts 

Governments serving fewer than 50,000 people, along with all special district governments, have until April 26, 2028 to meet ADA Title II requirements. Special districts are easy to overlook: water authorities, transit agencies, fire protection districts, and school districts all fall under Title II. If your district runs a website where the public pays a bill or submits a form, you must comply with Title II.

Read more about ADA Title II requirements for smaller entities.

Higher Education

Public colleges and universities are considered government entities under Title II, and their deadlines are based on the populations they serve. Their digital footprint is among the largest of any covered entity, spanning everything from their main site to student portals and course materials, which is why starting early matters more in this industry than almost anywhere. 

Read more about accessibility requirements for higher education.

K-12 Schools and Libraries

Public school districts and public libraries are government entities under Title II and generally fall under the April 26, 2028 deadline. Both manage sprawling digital services, from school portals and payment systems to library catalogs and database access, that all need to meet WCAG 2.1 AA. 

Read more about requirements for K-12 schools and libraries. 

Healthcare Providers Receiving Federal Funding

Healthcare is the one area where a second rule applies. The HHS Section 504 rule covers recipients of federal funding, including hospitals, community health centers, clinics, and most organizations that accept Medicare or Medicaid. Providers with 15 or more employees must meet WCAG 2.1 AA by May 11, 2027, and smaller providers by May 10, 2028.

Here is the point healthcare organizations cannot afford to miss: meeting one rule does not satisfy the other. Many HHS-funded organizations are also Title II public entities. A public hospital, a state or local health department, and a public university medical center are each covered by both the DOJ Title II rule and the HHS Section 504 rule. These are two separate legal obligations from two separate agencies, and both remain fully in force. Title II compliance does not discharge your Section 504 duty, and Section 504 compliance does not discharge your Title II duty. A dual-covered organization has to meet both.

The good news is that meeting both is one body of work, not two. HHS deliberately aligned its extended dates with the DOJ’s, and both rules require the same technical standard, WCAG 2.1 Level AA. So a dual-covered organization does not build to two different targets. It builds to WCAG 2.1 AA once and works to the earlier deadline that applies to it, satisfying both rules at the same time. The practical risk is not conflicting requirements. It assumes that clearing one rule means you are done, even when a second deadline is still on your calendar. 

Read more about accessibility requirements for healthcare facilities. 

Generic data visualization of a bar chart and line graph with a hand holding a gavel in front.

What Happens if You Miss the Deadline?

Missing a compliance deadline does not trigger an automatic penalty, but it raises your exposure on two fronts. 

The first is federal enforcement. The DOJ can investigate complaints and bring enforcement actions under Title II, and HHS can act under Section 504, where consequences can include the loss of federal funding.

The second front is private litigation. Because the underlying nondiscrimination obligations are already in effect, individuals and advocacy organizations can file web accessibility lawsuits now, during the extension period. An organization that treats the extended deadline as permission to stop working on accessibility is exposed in the meantime.

The bottom line: continuing to enhance the accessibility of your digital content and documenting that work remains the right path, regardless of how far away your formal deadline sits.

Could the Accessibility Deadlines Change Again?

The short answer: it’s possible. Both agencies left the door open to additional rulemaking. 

For example, the HHS opened a public comment period on its interim final rule and specifically invited input on cost, feasibility, and whether further changes are warranted to reduce the burden on small recipients. 

Organizations covered by either rule should continue to track both, because further substantive changes from either department remain possible. This is another reason to treat accessibility as an ongoing process rather than a one-time scramble against a fixed date: the date may move again, but the obligation to provide accessible digital services will not go away.

Get Deadline-Ready with AudioEye

The deadline extensions changed the date, not the destination. Every organization covered by these laws, whether under ADA Title II, Section 504, or both, still has to reach the same place: digital content that’s accessible to all users. The only real variable is whether you arrive there on your own timeline or in a chaotic scramble against the clock.

That is where starting now pays off. And with AudioEye, getting started is easier than ever. AudioEye combines AI-powered automation, expert audits, and expert-written custom fixes into one platform, resolving ~97% of issues and delivering 400% more protection from valid legal claims than automation-only solutions. Government, education, and healthcare organizations have everything they need to achieve conformance and stay there, well ahead of their 2027 and 2028 deadlines.

The deadlines are not moving. The sooner you start, the more time you have to get it right.

See how accessible your digital content is — run a free accessibility scan to identify high-impact issues that could stand between your organization and compliance. 

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