Jon Avila

Author: Jon Avila

Two major digital accessibility compliance deadlines in the U.S. have shifted.

On April 20, the Department of Justice (DOJ) published an “interim final rule” extending the compliance dates with the rule for web, mobile, and digital content accessibility under Title II of the Americans with Disabilities Act (ADA) by one year.

This means colleges, cities, counties, states, and other entities serving populations over 50,000 now have until April 2027 to comply. Entities serving fewer than 50,000 have until 2028. Public comments on the updated rule will be collected for 60 days, but they won’t affect this extension.

Shortly after, on May 7, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) issued its own Interim Final Rule extending digital accessibility compliance deadlines for recipients of HHS federal funding under Section 504 of the Rehabilitation Act of 1973. Under the revised timeline, recipients with 15 or more employees now have until May 11, 2027, and those with fewer than 15 employees have until May 10, 2028.

The good news is, while pushing toward recent deadlines, many organizations have already strengthened their accessibility programs, procurement practices, and governance.

Our recommendation is: now is the time to strengthen accessibility efforts, not stop them.

That’s because the core obligation hasn’t changed: accessible digital services are a civil right, and demand for inclusive, equitable online experiences keeps accelerating. Title II has been in effect since 1990, and the Rehabilitation Act has been in effect since 1973. Individuals with disabilities retain the ability to enforce their rights, and DOJ enforcement under existing the laws continues.

These updates also don’t reduce the rising scrutiny around digital accessibility—or the growing expectation that digital services should be accessible by design. And even with these federal extensions, many states continue to enforce their own digital accessibility laws.

The added time lets organizations build programs that are thoughtful, durable, and audit-ready—and gives state and local governments and HHS funding recipients more room to plan, resource, and deliver sustainable accessibility.

In short, the timeline may have shifted, but the mission hasn’t: ensuring every member of the public can access vital digital experiences, including education, healthcare, and government services.

If you’re wondering what this extension means for your organization, specifically, here’s guidance based on your situation.

State and local government entities and HHS funding recipients who were already set to meet the deadline

If you were prepared to meet this month’s deadline, this extension shouldn’t impact you much. You’re in great shape to provide access to programs, services, and activities that meet the rule’s requirements and the needs of people with disabilities. The key now is to keep up the effort to ensure new content is accessible—a year can go by quickly. Continue to check in with vendors to ensure accessibility remains a part of their design and development process to ensure products you acquire remain compliant. Now is also a good time to focus on refining your own accessibility processes. Work to ensure your efforts are sustainable in the long term and share your knowledge with other organizations—you are an example!

State and local government entities and HHS funding recipients who were working on accessibility, but not set to meet the deadline

The extensions provide additional time to comply with the requirements of the 2024 rules, however, both the ADA title II and Section 504 laws (without specific technical standards) remain in effect. Your state may also have its own accessibility requirements which may impact you. That means now is definitely still the time to continue your accessibility efforts, both internally and with your vendors. This extension may allow you to give more flexibility to your vendors and to focus on prioritizing issues that impact users with disabilities the most. This is also an opportunity to continue to build out your accessibility capabilities, tools, training, and practices and launch your processes like posting accessible social media and accessible documents. Don’t let up: pausing or stalling now means you could fall behind the deadline again.

State and local government entities and HHS funding recipients who hadn’t begun work toward compliance

Let this be your wake-up call. Now is the time to start your accessibility program in earnest. Accessibility is an effort that requires thoughtful implementation, coordination with vendors, budget, and culture change within your organization. This is a great opportunity to build a program that is sustainable, proactive, and part of the way you work, rather than something that is bolted on at the last minute. Refer to our quick start guide for help beginning your efforts.

Software vendors selling into the US public sector or healthcare industry

If you’re already in conformance with accessibility standards, you have a meaningful competitive advantage. Keep up the effort, and continue to build accessibility directly into your products.

If your products are not fully conformant, this is an opportunity to work with the organizations you serve to find out if there is flexibility with the extension now in effect. Keep in mind that your buyers still need to meet their existing ADA Title II or Section 504 obligations, along with obligations under any applicable state laws.

While there is an extension, the expectation under these laws remains unchanged: public entities and HHS funding recipients must ensure their programs, services, and activities are accessible to people with disabilities and conformant with standards.

Continued accessibility work is good for business, and having updated accessibility audits and conformance documentation ready will retain current customers and attract new prospects.

We’re here to help

We’ll continue to pay close attention to updates around Title II and Section 504, as we do with all major accessibility legislation and enforcement. If you work in state and local government, check out our ADA Title II hub for more resources and support, no matter where your team is at along its compliance journey.

In the meantime, we’re always here for further questions. Contact your Customer Success Manager or send us a note at info@levelaccess.com.

Frequently asked questions

What exactly did the DOJ extend under ADA Title II?

The Department of Justice extended the compliance dates for the 2024 ADA Title II rule that establishes technical accessibility requirements for state and local government web, mobile, and digital content. Public entities serving populations of 50,000 or more now must comply by April 2027, and entities serving fewer than 50,000 people must comply by April 2028. The scope of the rule and its technical requirements were not changed—only the implementation timeline was extended. 

ADA Title II itself remains fully in effect, independent of the extended compliance dates for the 2024 rule. State and local governments continue to be legally required to provide people with disabilities equal access to their programs, services, and activities—including those delivered digitally. Individuals may still bring complaints or legal actions under existing ADA Title II requirements, DOJ enforcement authority remains unchanged, and state‑level digital accessibility laws may continue to apply regardless of the federal timeline. 

The two extensions cover different legal frameworks and different sets of covered entities, but align on WCAG 2.1 Level AA as the technical standard and share a common goal of consistency. The DOJ ADA Title II extension applies to state and local government entities (cities, counties, colleges, state agencies) and sets deadlines based on population served: April 2027 for entities serving 50,000 or more, and April 2028 for smaller entities. The HHS Section 504 extension applies to recipients of HHS federal funding (hospitals, health centers, social service organizations) and sets deadlines based on organization size: May 11, 2027 for those with 15 or more employees, and May 10, 2028 for smaller organizations. Some entities may be covered by both rules and should ensure they meet the requirements of each.

Share