ADA Web Accessibility Deadlines
The DOJ and HHS have set federal compliance dates for web accessibility under ADA Title II and Section 504. Here's who needs to comply, when, and what's required.
What Changed
In April 2024, the DOJ issued a final rule requiring state and local government websites and mobile apps to conform to WCAG 2.1 Level AA. In April 2026, the DOJ extended the original compliance dates, giving entities more time — but the requirement is firm and the deadlines are now less than two years away.
Separately, HHS extended Section 504 compliance dates in May 2026, applying the same WCAG 2.1 AA standard to HHS-funded organizations.
Who Must Comply
ADA Title II covers all state and local government entities. Section 504 covers HHS-funded organizations. Here's the breakdown:
Cities (50k+)
Salt Lake City, West Valley, Provo, West Jordan, Orem, Sandy, Ogden, St. George, Layton, South Jordan
Cities (under 50k)
All other Utah cities and towns — Clearfield, Roy, Murray, Clinton, Syracuse, Kaysville, Farmington, etc.
School Districts
All public school districts, charter schools, and education service centers
Special Districts
Water, fire, sewer, cemetery, recreation, mosquito abatement, irrigation, improvement districts
Higher Education
Community colleges, public universities, technical colleges (UVU, SLCC, Weber State, Snow, Dixie)
HHS-Funded Healthcare
FQHCs, community health centers, behavioral health, home health, nursing homes billing Medicare/Medicaid
What WCAG 2.1 AA Requires
WCAG 2.1 Level AA is organized around four core principles. Websites must be:
1. Perceivable
- Color contrast: Text must have a contrast ratio of at least 4.5:1 against its background
- Alt text: All meaningful images must have descriptive alt attributes
- Captions: Video content must have synchronized captions
- Resize: Content must remain usable at 200% zoom without loss of function
2. Operable
- Keyboard accessible: All functionality must work without a mouse
- Focus visible: Keyboard focus must be clearly visible on all interactive elements
- No keyboard traps: Users must be able to exit any component via keyboard
- Timing: No time limits without pause/stop/adjust controls
3. Understandable
- Language: Page language declared in HTML (lang attribute)
- Labels: Form fields must have associated labels
- Error prevention: Form errors must be identified and described in text
- Consistent navigation: Navigation mechanisms must be consistent across pages
4. Robust
- Valid ARIA: ARIA roles, states, and properties must be valid and correctly applied
- Name, Role, Value: All UI components must have accessible names and roles
- Status messages: Status changes must be programmatically determinable
Self-Assessment Checklist
Quick checks you can do right now to gauge where your site stands:
10-Second Tests
If you checked fewer than 8 of these, you likely have significant WCAG 2.1 AA gaps. Run our free automated scanner for a deeper look.
The Procurement Window Is Now
Utah public entities run on a July–June fiscal year. FY27 budgets are already allocated, and FY28 planning starts in Q1 2026. The first compliance deadline is April 26, 2027 — eight months out.
Most accessibility remediation projects take 4–12 weeks depending on site complexity. That means the procurement window for audit and remediation services is right now.
Many Utah special districts can purchase audit services under small-purchase thresholds — no RFP required. A WCAG 2.1 AA diagnostic audit can typically be purchased on a procurement card.
Find Out Where Your Website Stands
Run our free automated WCAG 2.1 AA scanner, or request a professional manual audit starting at $750.
Free Scan Request AuditFrequently Asked Questions
When is the ADA Title II web accessibility deadline?
April 26, 2027 for public entities serving 50,000 or more people. April 26, 2028 for public entities serving fewer than 50,000 people and all special district governments.
What is the Section 504 web accessibility deadline?
May 11, 2027 for HHS-funded entities with 15 or more employees. May 10, 2028 for entities with fewer than 15 employees.
What standard must public entities comply with?
WCAG 2.1 Level AA. This covers perceivable, operable, understandable, and robust accessibility criteria including color contrast, keyboard navigation, screen reader compatibility, alt text, and form accessibility.
What counts as a special district government under ADA Title II?
Special districts include water districts, fire districts, sewer districts, cemetery districts, recreation districts, mosquito abatement districts, irrigation districts, and similar special-purpose public entities. Utah has hundreds, all with an April 26, 2028 compliance deadline.
Does ADA Title II apply to school district websites?
Yes. All public school districts, charter schools, community colleges, and public universities are public entities subject to ADA Title II.
Can automated scanning tools verify compliance?
Automated scanning catches approximately 40% of WCAG 2.1 AA issues. It's a useful screening tool but cannot replace manual testing. Full conformance verification requires both automated and manual testing by a qualified specialist.
DOJ Title II Extension (91 FR 20902): Federal Register
HHS Section 504 Extension: Federal Register
28 CFR Part 35 — Nondiscrimination on the Basis of Disability in State and Local Government Services