Two US rules that set WCAG deadlines for 2026 were both pushed back a year in the spring. If you sell to American public bodies or health providers, or build for them, the dates in your contracts have probably moved. The standard, the scope and the exceptions have not. Here is the state of play.

ADA Title II: state and local government

The Department of Justice’s 2024 rule under Title II of the Americans with Disabilities Act requires state and local governments to make their web content and mobile apps conform to WCAG 2.1 Level A and AA, including content and apps provided for them by contractors. On 20 April 2026 the DOJ published an interim final rule in the Federal Register extending both compliance dates by one year:

  • Public entities serving a population of 50,000 or more: from 24 April 2026 to 26 April 2027.
  • Smaller entities and special district governments: from 26 April 2027 to 26 April 2028.

The DOJ said it had overestimated how quickly covered entities could comply, and that it plans further rulemaking on the rule’s substantive requirements. If no proposed rule follows and the dates are not extended again, the DOJ expects the rule to apply on the new dates. The interim rule changed nothing else: the technical standard, the coverage of apps and documents, and the exceptions for archived content, pre-existing documents, individualised password-protected documents, pre-existing social media posts and third-party content all stand. Reed Smith has a clear summary, and the DOJ’s fact sheet on the rule remains the best plain-language guide to what it covers.

HHS Section 504: health and human services

The Department of Health and Human Services’ May 2024 rule under Section 504 of the Rehabilitation Act applies the same WCAG 2.1 Level A and AA standard to the websites, mobile apps and kiosks of anyone receiving HHS financial assistance. That reaches most hospitals, physician practices, health centres, care facilities, health plans and medical schools. Accepting Medicare Part B reimbursement alone is enough to be covered.

On 7 May 2026 HHS’s Office for Civil Rights issued its own interim final rule, published in the Federal Register on 11 May, moving the digital deadlines back a year:

  • Recipients with 15 or more employees: from 11 May 2026 to 11 May 2027.
  • Recipients with fewer than 15 employees: from 10 May 2027 to 10 May 2028.

The stated reason was that a significant number of recipients reported they could not meet the original timeline, and the change brings HHS into line with the DOJ. Everything else in the 2024 rule stands, including the general duty not to discriminate, which has been in force since 8 July 2024 and does not wait for the web deadline. The rule also allows an alternative standard such as WCAG 2.2 where it gives substantially equivalent or greater accessibility. The Federal Register notice is the primary source.

What did not slow down

Private litigation. UsableNet’s running lawsuit tracker, which counts filings in federal court and the main state courts, shows 2026 filings ahead of the same period in 2025. With federal enforcement paused, private plaintiffs and state courts set the pace, and they do not wait for compliance dates.

How to use the extra year

  1. Do not re-plan to the new date. Teams that were on track for 2026 should finish. The deadline moved, the backlog did not.
  2. Inventory documents. Both rules reach PDFs, spreadsheets and presentations that are used to access services, not just HTML. Archived and pre-existing documents are exempt only while they stay unaltered and are not currently used to apply for, access or take part in a service.
  3. Fix contracts. Content a vendor provides on your behalf is your obligation. Put the standard, the edition and the evidence you expect into the agreement.
  4. Build to 2.2, report against 2.1. WCAG 2.2 Level AA is a superset of 2.1 Level AA apart from the removed parsing criterion, and it is where Europe has moved. Meeting 2.2 covers both.

Try it this week

Pick one public-facing form and check it against the three WCAG 2.2 criteria that most often trip up government services: redundant entry, accessible authentication and target size. Then read How WCAG, EN 301 549 and the EAA fit together for a map of which law points at which version.

Back to Blog