Plain English guide · Accessibility law

What the law requires

Accessibility law now has a calendar. Two federal rules set a technical standard for public websites, apps and online documents, WCAG 2.1 Level AA, and fixed dates to meet it. Here is what each rule says, who it covers, what it does not require, and what happens when someone complains.

For cities, towns, counties, school districts, special districts, public colleges and organizations that receive federal funds.

See the dates Browse our guides

Four dates, two rules, one standard.

Both rules require WCAG 2.1 Level AA. Both had their dates pushed back one year in the spring of 2026.

Federal web and document accessibility dates
Who	Comply by
ADA Title II: governments of 50,000 or more	April 26, 2027
ADA Title II: governments under 50,000, and special districts	April 26, 2028
HHS Section 504: recipients with 15 or more employees	May 11, 2027
HHS Section 504: recipients with fewer than 15 employees	May 10, 2028

ADA Title II: state and local governments

Title II of the Americans with Disabilities Act covers state and local governments and the agencies that belong to them: cities, towns, counties, public school districts, special districts, community colleges and public universities. In April 2024 the Justice Department added a rule, 28 CFR part 35, subpart H, that makes their web content and mobile apps meet WCAG 2.1 Level AA.

Which date applies depends on total population, as the rule defines it in 28 CFR 35.104. A city or county uses its count in the most recent Census. An independent school district uses the Census Bureau’s Small Area Income and Poverty Estimates. An agency that belongs to a state or local government uses that government’s population, so a state university counts the whole state. Special district governments fall in the later group, whatever their size.

The Justice Department moved both dates back one year in an interim final rule published April 20, 2026. It said it may propose changes to the rule, and that if it does not, it “fully anticipates” enforcing the rule on the new dates. As of late October 2026 no proposal has been published.

Section 504: anyone who receives federal funds

Section 504 of the Rehabilitation Act of 1973 bars disability discrimination in any program or activity that receives federal financial assistance. That reaches nonprofits, hospitals, health centers, school districts, colleges and many others. Federal student aid counts: the Justice Department’s civil rights guidance says schools are recipients “when they accept payments from students who directly receive federal financial aid.” Each federal agency enforces Section 504 for the money it gives out.

The Department of Health and Human Services has gone furthest. Its rule, 45 CFR part 84, subpart I, applies to every recipient of HHS funding and requires WCAG 2.1 Level AA for websites, mobile apps and online documents. The dates in 45 CFR 84.84 depend on how many people you employ: May 11, 2027 for 15 or more, and May 10, 2028 for fewer. HHS moved both dates back one year in an interim final rule published May 11, 2026.

What the rules do not require you to fix

The Title II rule and the HHS rule share the same five exceptions. Each one is narrow, and each has conditions.

Archived content: created before your compliance date, kept only for reference, research or recordkeeping, not changed since it was archived, and stored in an area clearly labeled as archived. All four must be true.
Older documents: PDFs, word processing files, slides and spreadsheets posted before your compliance date, unless people currently use them to apply for, gain access to, or take part in your programs.
Third party content: posted by someone else on their own, not under a contract, license or other arrangement with you.
Individual records: documents about one person, property or account, behind a password or other security.
Older social media posts: made before your compliance date.

There is no exception for public school or college course content. Even where an exception applies, the Justice Department says you would likely still need to provide the content in an accessible format to a person with a disability who asks for it.

Read how the archived content exception works.

What WCAG 2.1 AA means for a document

WCAG, the Web Content Accessibility Guidelines, was written for the web, but both rules apply it to the PDFs, Word files, slides and spreadsheets you post. In practice an accessible document has:

Tags and reading order, so a screen reader reads the page in the right sequence.
Real headings and lists, so people can move through the document by section.
Alt text for images, charts and figures that carry meaning.
Table headers, so each number is announced with its row and column.
Real text, not a scanned picture of text.
Labeled form fields and clear instructions.
Enough contrast between text and background.
A title and a language set in the document properties.

A quick test: open the file, select all the text, and paste it into a plain text editor. If nothing comes across, or it comes across in the wrong order, a screen reader will struggle too.

Complaints and lawsuits

A person who meets a barrier can complain to a federal agency, go to court, or both.

Complaints to federal agencies

Justice Department. Anyone can file an ADA complaint with the Civil Rights Division online at civilrights.justice.gov or by mail, including against a state or local government.
Department of Education. Its Office for Civil Rights enforces Section 504 and Title II at schools and colleges, and takes complaints from students, parents and the public. A complaint must ordinarily be filed within 180 days of the last act of discrimination, and OCR asks for good cause to waive that. Someone who first uses the school’s own grievance process has 60 days after it ends to file with OCR.
Department of Health and Human Services. Its Office for Civil Rights enforces Section 504 for organizations that receive HHS funding.

Lawsuits

Title II and Section 504. A person who faces disability discrimination by a public entity or a federal funding recipient can sue. A court may award attorney’s fees to the side that wins.
Title III. This part of the ADA covers private businesses open to the public, including private schools and colleges. A private plaintiff can ask a court for an order to fix the barrier and for attorney’s fees. The Attorney General can also sue and seek civil penalties.

Our guides

ADA Title II deadline for small townsThe April 26, 2028 date, who it applies to, and how total population is counted.
Colleges and universitiesThe Title II and Section 504 rules on campus, and what to fix first.
HHS Section 504 web rule for nonprofitsWhat HHS funding recipients need to do, and by when.
Section 504 website and PDF checklistA free two page checklist to plan and track the work.
Do old agendas and minutes have to be accessible?The four conditions of the archived content exception.
How local government PDFs scored in every stateWe tested 72,921 PDFs on 6,287 local government websites. 84% did not pass a basic check.

Celsari can help

Celsari remediates and quality checks PDFs, Word files and forms so they meet WCAG 2.1 Level AA, at a fixed price set by the pages you have.

Ask about your documents How document accessibility works

Sources

Checked against these sources on October 31, 2026. This guide explains federal rules in plain language. It is not legal advice, and Celsari does not provide legal advice or representation. Check the current text of the rules, and ask your own attorney about your situation.