Two federal agencies set web and mobile accessibility deadlines for institutions in 2024, and both moved them this spring. The standard did not change. Both rules require conformance with the Web Content Accessibility Guidelines, version 2.1, Level AA. What changed is the timing, and the two agencies did not move in step.
The Justice Department rule
On April 20, 2026, the Justice Department published an interim final rule (RIN 1190-AA82), effective the same day, extending the compliance dates in its ADA Title II web accessibility rule at 28 CFR Part 35, Subpart H. Public entities with a total population of 50,000 or more now have until April 26, 2027, instead of April 24, 2026. Public entities with a population under 50,000, and special district governments, now have until April 26, 2028, instead of April 26, 2027.
The Department stated that the rule "does not impose new substantive requirements." Its reasons included that it had overestimated the staffing and technology capacity of covered entities, and that generative AI does not yet reliably automate the remediation of inaccessible content at scale.
Title II applies to public entities, including public colleges and universities and public school districts. The size tiers turn on the population of the public entity, not the enrollment of the institution.
The HHS rule
On May 11, 2026, the Department of Health and Human Services published its own interim final rule (RIN 0945-AA30), effective May 7, extending the compliance dates in its Section 504 regulations at 45 CFR Part 84. Recipients with 15 or more employees now have until May 11, 2027, instead of May 11, 2026. Recipients with fewer than 15 employees now have until May 10, 2028, instead of May 10, 2027.
The HHS rule reaches any recipient of HHS financial assistance, public or private. For many colleges and universities, that includes institutions that hold HHS grants or operate health programs. For many districts, it includes programs funded through HHS.
Which date applies
An institution may be subject to one rule, the other, or both, and the earliest applicable date controls its plan.
A public university that receives HHS funds is subject to both. It will usually fall in the larger Title II tier, with a date of April 26, 2027, which comes before the HHS date of May 11, 2027.
A private college that receives HHS funds is not a Title II public entity. Its web-specific deadline comes from the HHS rule: May 11, 2027, if it has 15 or more employees.
A public school district serving a population under 50,000 has a Title II date of April 26, 2028. If the district also receives HHS funds and has 15 or more employees, its HHS date of May 11, 2027 comes a full year earlier. This is the case most likely to be missed.
One plan, not two
Because both rules use the same technical standard, an institution does not need two remediation efforts. It needs one plan, measured against the earliest date that applies.
Confirm which rules apply by checking the institution's public status, its population tier under Title II, and whether it receives HHS funds and how many employees it has.
Inventory what is covered. That includes websites, mobile apps, learning management content, documents posted online, and third-party platforms the institution provides to the public or to students.
Prioritize by use. Content that people need in order to apply, enroll, pay, register, or file a complaint should be conformant first.
Change procurement now. Every new platform and content contract signed between now and the deadline should require conformance to WCAG 2.1 Level AA, with the vendor's obligation to remediate stated in writing.
The extensions moved the dates. They did not change the underlying obligation under Title II and Section 504 to provide effective communication and equal access, which applies today.