Reference · checked 25 August 2026
Web accessibility deadlines, as they actually stand
A lot of published guidance on this still quotes dates that were superseded in April 2026. Here is the current position with primary sources, and the parts that genuinely remain unsettled.
This is not legal advice
Whether any of it applies to you depends on where you operate, how large you are, and what you sell. We are a testing service, not a law firm, and we will not tell you that you are covered or that you are not.
United States — ADA Title II (state and local government)
The Department of Justice's 2024 final rule requires public entities to meet WCAG 2.1 Level AA for their websites and mobile apps. On 20 April 2026 the DOJ issued an interim final rule pushing the compliance dates back by one year:
- 26 April 2027 — public entities serving 50,000 people or more.
- 26 April 2028 — smaller entities and special district governments.
The substantive requirement did not change; only the dates did. DOJ cited resourcing, staffing, and the limits of current remediation technology — including generative AI — as its reasons. Comments on the interim rule were open until 22 June 2026.
If you read anything dated before April 2026 saying the deadline is 2026 or 2027, it was written before this change.
United States — Section 504, for recipients of federal funding
HHS's Section 504 rule requires web content and mobile apps to meet WCAG 2.1 Level AA. It reaches any programme or activity receiving federal financial assistance from HHS — hospitals, clinics, research institutions, health and social service organisations — and covers content delivered through third parties as well as directly.
On 7 May 2026, four days before the original deadline, HHS's Office for Civil Rights published an interim final rule extending the dates by a year:
- 11 May 2027 — recipients with 15 or more employees.
- 10 May 2028 — recipients with fewer than 15 employees.
The technical standard and the rule's scope did not change. A great deal of published guidance still quotes the superseded May 2026 date — if what you are reading was written before May 2026, check it.
United States — ADA Title III (private businesses)
There is no regulation setting a technical standard or a date here. Obligations turn on whether a website has the necessary connection to a place of public accommodation, and the federal circuits do not agree on how far that reaches. Anyone telling you there is a fixed private-sector deadline is inventing one.
European Union — the European Accessibility Act
Directive (EU) 2019/882 has applied since 28 June 2025. It covers a defined list of products and services — e-commerce, consumer banking, e-books, transport and telecoms services among them — not every website.
The microenterprise carve-out. Article 4(5) exempts microenterprises from the requirements for services. A microenterprise has fewer than ten staff and either turnover or a balance sheet total of no more than €2 million. It is automatic; there is nothing to apply for. It does not extend to products, and the thresholds are assessed on the whole undertaking, so a small team inside a larger group generally does not qualify.
Enforcement is national, and penalties reported in the first year of the regime range from around €5,000 in Estonia to as much as €500,000 in Germany.
United Kingdom
Two separate things, often conflated:
- Public sector bodies. The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 came into force on 23 September 2018 and require WCAG 2.1 Level AA — meeting WCAG 2.2 AA satisfies them too. They also require a published, up-to-date accessibility statement naming known problems and what someone can do about them.
- Everyone else. The Equality Act 2010 imposes a duty to make reasonable adjustments. It is anticipatory — it does not wait for a complaint — but it sets no technical standard and no date. WCAG is evidence of what is reasonable, not the legal test.
Not sure which of these is yours?
We built a six-question questionnaire that narrows it down. It will not tell you whether you comply, and it will not tell you that you are exempt — but it will tell you which two or three of the above are worth taking to somebody qualified, with the thresholds and dates attached.
What testing can and cannot do about any of this
An automated scan produces evidence: what was tested, when, and what failed. That is genuinely useful — it is a dated record, it finds real defects, and it turns a vague worry into a list of tasks.
It cannot establish conformance. The rules reach 23 of the 55 Level A and AA success criteria, and 32 have no automated rule at all. The full table is here. Conformance claims need human testing on top, and in most cases someone qualified to make the judgement.
Sources
- DOJ interim final rule extending Title II compliance dates, 20 April 2026 — reported by Duane Morris and Jackson Lewis.
- Directive (EU) 2019/882, Article 4(5), microenterprise exemption for services.
- WCAG 2.2 success criteria, W3C.
We re-check this page weekly. Last verified 25 August 2026. If something here is out of date, tell us and we will correct it.