HHS Section 504 web accessibility rule: what nonprofits need to know

The dates now

HHS made the change in an interim final rule announced May 7, 2026 and published in the Federal Register on May 11, 2026. It changed only the two dates. Many pages online still show the 2026 date.

Who is covered

The rule applies to "recipients" of HHS federal financial assistance. That includes many community health centers, behavioral health and substance use providers, Head Start programs, aging and disability service agencies, family service nonprofits and hospitals. If you are unsure whether you receive HHS funds, your grant or contract paperwork will name the federal agency, sometimes through a state agency that passes the money on.

A county or city health department that receives HHS money is covered by this rule and by the Justice Department's ADA Title II web rule. The standard is the same, WCAG 2.1 Level AA, but the dates differ. See the ADA Title II dates.

What it requires

• Your website and mobile apps, including content provided through vendors, must meet WCAG 2.1 Level A and AA.
• The PDFs, Word files, slides and spreadsheets on your site are web content and are covered.
• Kiosks, such as check-in screens, fall under a separate general duty in 45 CFR 84.83. That section sets no WCAG standard and no date of its own.

The exceptions

45 CFR 84.85 mirrors the Justice Department's rule. These are exempt:

• archived web content that meets a four-part test
• documents posted before your compliance date that nobody currently uses to apply for, get or take part in a service
• content posted by third parties, unless you arranged it
• individual, password-protected documents about a specific person, such as a patient's statement
• social media posts made before your compliance date

How the archived content test works in practice.

Where to start

1. Confirm whether you receive HHS funds, and count your employees to find your date.
2. List what is on your website: pages, PDFs, intake and referral forms, donation and payment pages.
3. Fix what clients use first: intake forms, eligibility rules, notices of privacy practices, program guides and anything about how to get services.
4. Move old reports and newsletters into a labeled archive.
5. Ask your website and patient portal vendors in writing how they meet WCAG 2.1 AA.
6. Post an accessibility statement with a way to ask for another format.

This guide explains federal rules in plain language. It is not legal advice. Check the current text of the rule, and ask your municipal attorney about your own situation.