Title II and 504 Deadline Extensions

The Justice Department and HHS have each given their covered organizations another year to meet the web accessibility rules, and neither agency changed the standard. The extra year only helps if you spend it: a team that pauses now will reach the new dates with the same backlog and less time to clear it.

DOJ published its interim final rule on April 20, 2026, moving the ADA Title II compliance dates for state and local government websites and mobile apps. HHS followed with a matching interim final rule for Section 504, published in the Federal Register on May 11, 2026, the same day its original deadline for larger recipients would have arrived. Below is what moved, what stayed put, and a quarter-by-quarter plan that gets a large public entity to April 26, 2027 with evidence in hand.

What the two interim rules changed

Both rules do one thing. They move dates.

Who	Rule	Technical standard	Compliance date
State and local governments with a total population of 50,000 or more	ADA Title II (DOJ)	WCAG 2.1 Level AA	April 26, 2027
State and local governments under 50,000, and all special district governments	ADA Title II (DOJ)	WCAG 2.1 Level AA	April 26, 2028
HHS-funded recipients with 15 or more employees	Section 504 (HHS)	WCAG 2.1 Level AA	May 11, 2027
HHS-funded recipients with fewer than 15 employees	Section 504 (HHS)	WCAG 2.1 Level AA	May 10, 2028

Three details matter more than they look.

Both rules are already in force. An interim final rule takes effect without the usual proposal-and-comment cycle; the agency takes comments afterward and can revise. DOJ's rule took effect on publication, and HHS's took effect a few days before it appeared in the Federal Register.
The tiers are about size, not readiness. Under Title II, the date depends on the total population of the government. A department that doesn't have its own population figure, such as a city library or police department, uses the population of the government it belongs to. A small library in a large county is in the earlier group.
Two agencies, two calendars. A county health department that runs a public website and receives HHS funds can sit under both rules, with different dates. Plan to the earlier one.

What the extensions did not change

The standard. Both rules still require WCAG 2.1 Level AA for web content and mobile apps. No criteria were removed or softened. If your team was testing against WCAG 2.1 AA in March, it should be testing against WCAG 2.1 AA now. For public entities we report against WCAG 2.1 AA and flag the newer 2.2 criteria separately, because 2.2 includes nearly everything in 2.1 and is where procurement is heading.

The exceptions. The DOJ rule's exceptions for archived web content, preexisting conventional electronic documents, certain third-party content, individualized password-protected documents, and preexisting social media posts are unchanged, and so are their conditions. Archived content, for example, must be kept only for reference, research, or recordkeeping, live in a clearly marked archive area, and stay unaltered. A page you still update is not an archive.

The obligations that already existed. Title II and Section 504 required effective communication and equal access to programs long before these rules. The rules added a specific technical standard and a date by which it applies; they did not create the underlying duty. DOJ's fact sheet is explicit that the exceptions don't change existing obligations to provide effective communication, reasonable modifications, and an equal opportunity to participate.

The ability to complain or sue. People can still file complaints with federal agencies, and private lawsuits under Title II and Section 504 remain possible. How a court weighs a website claim before the technical compliance date depends on your facts and your jurisdiction. That question is for your attorney, not for a blog post.

Why a year is shorter than it looks

Public-sector work runs on budget and procurement cycles, not sprints. Before a single fix ships, someone has to know what you publish, someone has to test it, someone has to approve the money, and vendors have to be under contract to change their platforms. Many state and local governments start their fiscal year on July 1, which means the budget that pays for most of this work is being written now.

Documents make it harder. Many public entities publish more PDFs than web pages, and documents posted after the compliance date don't qualify for the preexisting-document exception. Every agenda, budget, and permit form posted from that day forward has to conform. That is a change to how dozens of people do their jobs, and changes like that take training and time.

Then there are vendors. Payment portals, permit systems, agenda managers, library catalogs, patient portals, and learning platforms are covered when you provide them through a contract or license. You can't fix their code. You can only require them to.

A quarter-by-quarter plan for the next twelve months

This plan assumes a Title II entity in the 50,000-plus group, or an HHS recipient with 15 or more employees. Smaller organizations can stretch each phase, but shouldn't skip one.

May and June 2026: inventory and ownership

List every domain, subdomain, mobile app, and vendor platform that carries your name. Check your DNS records and registrar accounts, not just the main site's menu.
Give each property an owner who is a person, not a department.
Count your documents by type, age, and download volume, so you know which ones people actually use.
Write down your top tasks, the ten to twenty things residents or patients most often come to do: pay a bill, apply for a permit, find a meeting agenda, book an appointment.

July to September: audit and procure

Audit the top-task journeys against WCAG 2.1 AA with a keyboard and screen readers, not only a scanner. In a UK Government Digital Service test, the best of ten automated tools found 41% of the known barriers on its test page.
Ask every platform vendor for a current Accessibility Conformance Report and a dated remediation roadmap.
Write accessibility requirements into renewals and new contracts: the standard, how it will be tested, a fix window, and your right to test.

October to December: fix the shared parts

Fix shared components first: header, navigation, search, forms, modals, and the date picker. One template fix clears hundreds of pages.
Convert high-use documents to accessible HTML where you can, remediate the rest, and move genuine archives into a marked archive area.
Retest every fix against the original finding and keep the record.

January to March 2027: train, publish, and harden

Train content editors on headings, link text, alt text, and accessible documents, inside your own CMS.
Add automated accessibility checks to the publishing and deployment pipeline, so new content doesn't reopen closed issues.
Publish an accessibility statement with a working way to report barriers and a named person who responds.

From the compliance date onward: monitor

Monitor top-task pages and newly posted documents continuously, with manual checks every quarter.
Keep a dated log of findings, fixes, and retests. If anyone asks what you did and when, that log is the answer.

What vendors to public entities should do now

If you sell software or services to governments, hospitals, clinics, or public universities, your customers' deadline is your deadline. Procurement teams are rewriting contract language during this extension, and many will ask for proof before renewal.

Publish a current ACR. Base it on the latest VPAT®, 2.5Rev, and report against WCAG 2.1 AA at minimum, with 2.2 where you can. Write remarks a buyer can verify. "Supports" with no explanation helps nobody.
Ship a dated roadmap. For every "Partially Supports," name the component, the barrier, and the target release.
Expect to be tested. More buyers will test before signing. Give them a demo environment and a contact who can answer technical questions.
Fix what buyers see first. Login, search, forms, and data tables appear in every demo and every audit.

A vendor that arrives with evidence makes the buyer's job easier, and procurement teams remember who did.

Where to start this week

Pick the three journeys your residents or patients use most and test them with a keyboard and a screen reader before you buy anything. If you want a structured baseline, our WCAG 2.2 accessibility audit reports against WCAG 2.1 AA for public entities and flags the newer 2.2 criteria separately. Vendors facing new procurement questions can start with an Accessibility Conformance Report built on real testing.

Then put the next review on the calendar. The deadline moved; the work didn't.

The Title II and Section 504 extensions are a runway, not a reprieve