ADA & Section 504
ADA and Section 504: A deadline moved, a deadline did not
The DOJ moved the Title II web accessibility deadline to 2027 for nearly all public universities. The underlying obligations did not move, and neither did Section 504.
Two developments in the disability space deserve your attention, and they cut in different directions.
First, the deadline that moved. On April 20, 2026, the Department of Justice published an interim final rule extending state and local governments’ compliance deadlines for its 2024 web accessibility rule under ADA Title II from April 2026 to April 2027 or 2028, depending on population size. Because population is calculated at the state level, nearly all public universities fall under the April 26, 2027 deadline to bring websites, mobile applications, and digital course materials into conformance with WCAG 2.1 Level AA. Do not read the extension as a reprieve. The interim final rule delays only the WCAG 2.1 Level AA compliance dates; it does not suspend Title II’s underlying nondiscrimination and effective-communication obligations, and private plaintiffs and advocacy organizations can still sue during the extension period.
Second, the litigation landscape. The case formerly known as Texas v. Becerra continues in narrowed form. The states stated they are no longer challenging the constitutionality of Section 504 of the Rehabilitation Act, and Indiana dropped out on May 1, 2026, South Dakota on May 12, 2026, and Kansas on June 10, 2026, leaving six states continuing the challenge to the integration mandate. Section 504 stands. The 2024 regulations remain the terrain of the fight.
The takeaway: use the extended runway to run a real digital accessibility audit now, procurement contracts included, and keep your 504 obligations exactly where they have always been.
Trust, operationalized.
Albert Roberson
Founder & CEO
Sources
- U.S. Department of Justice, ADA.gov, “State and Local Governments: First Steps Toward Complying with the ADA Title II Web and Mobile Application Accessibility Rule,” updated April 2026.
- Jackson Lewis P.C., “DOJ Extends Public Entities’ Compliance Deadline for ADA-Related Website Accessibility, But HHS’s May 2026 Deadline Still Looms,” April 22, 2026.
- Duane Morris LLP, “DOJ Extends ADA Title II Digital Accessibility Deadlines by One Year,” April 23, 2026.
- UPCEA, “DOJ Extends Accessibility Deadline to April 2027, Policy Matters,” April 2026.
- Disability Rights Education and Defense Fund (DREDF), “Texas v. Kennedy (formerly Texas v. Becerra),” updated June 2026.
- National Health Law Program, “Texas and Eight Other States Renew Attack on Section 504,” January 28, 2026.
- Great Plains ADA Center, “Texas v. Kennedy: Update.”
