Guide · Updated October 27, 2026
Section 504 and ADA Title II: what the 2027 deadlines mean for your documents.
Two federal rules require web content and mobile apps, including the PDFs, Word files and slide decks you post, to meet WCAG 2.1 AA. Here’s who’s covered, when, and where to start.
Both deadlines were pushed back a year in 2026, and a lawsuit asks a court to undo that. Plan for the dates below, not for another delay.
ADA Title II: April 26, 2027
Section 504: May 11, 2027
Standard: WCAG 2.1 AA
The deadlines
Four dates to know.
Which date applies depends on what kind of organization you are and how big it is.
April 26, 2027. ADA Title II: state and local governments with a total population of 50,000 or more, including their agencies, public universities and public hospitals.
May 11, 2027. Section 504: organizations that receive HHS funding and have 15 or more employees, including most hospitals, health systems and health centers.
April 26, 2028. ADA Title II: governments with a population under 50,000, and all special district governments.
May 10, 2028. Section 504: HHS-funded organizations with fewer than 15 employees.
For Title II, population means the census population of the government you belong to, not your enrollment or patient count. A state university follows its state. A county community college or county hospital follows its county.
Who’s covered
Is your organization on the list?
State and local governments (ADA Title II)
Every state and local government and its departments and agencies, including public universities, community colleges, public hospitals and state and county health departments.
HHS-funded organizations (Section 504)
Organizations that receive HHS funding, such as Medicare, Medicaid, CHIP or HHS grants. That includes most hospitals, health systems, health centers and nursing homes, and many nonprofits and universities.
Often both
A state health department or public university that also receives HHS funding is covered by both rules. The 2027 deadlines are about two weeks apart, so one plan can cover both.
Federal contractors (Section 508)
Section 508 applies to federal agencies, and to contractors through their contracts. It requires WCAG 2.0 AA for documents. Building to WCAG 2.1 AA covers it.
What counts
Your documents count too.
Both rules cover web content and mobile apps, and that includes the files you post: PDFs, Word documents, PowerPoint decks and Excel spreadsheets. There are five exceptions, and each one is narrower than it sounds.
Archived content. Only if it was created before your deadline, is kept only for reference, research or records, hasn’t been changed since it was archived, and sits in a clearly marked archive area.
Documents posted before your deadline. Excepted unless people use them to apply for, get or take part in your services, and that includes the instructions and guides they need to do it. Edit an old document after your deadline and the exception ends.
Content posted by others. Excepted unless they post it for you, under a contract or other arrangement.
Secured documents about one person. For example, a patient’s bill behind a password. The portal itself still has to be accessible.
Old social media posts. Posts from before your deadline. New posts have to be accessible.
Even when content is excepted, you still have to provide it in an accessible way to a person with a disability who asks for it.
Where to start
Five steps before the deadline.
List what you have. Find every document on your website and apps, and note which ones people use to apply for or take part in your services.
Sort it. Decide what to fix, what to move to a clearly marked archive and what to take down.
Fix what matters most first. Start with applications, forms, patient and student instructions, and the files people use most.
Make new files accessible from the start. Accessible templates and a short guide for your authors stop the backlog from growing.
Keep checking. Check new documents before they’re posted, and keep a record of what you checked.
We can help with every step, from a checkup to 508 remediation and accessible templates.
Sources
ADA Title II: 28 CFR part 35, subpart H (eCFR) and the April 20, 2026 extension (Federal Register). Section 504: 45 CFR part 84, subpart I (eCFR) and the May 11, 2026 extension (Federal Register). Section 508: section508.gov. The lawsuit is National Federation of the Blind v. Department of Justice, No. 1:26-cv-02007 (D. Md.), filed May 21, 2026, which challenges both extensions. No ruling had been reported as of October 27, 2026.
General information, not legal advice. Check with your counsel about your organization.
Not sure where you stand?
Start with an accessibility checkup. We’ll show you where you stand and what to fix first.