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Quick Hits
- The DOJ extended the deadline for compliance with the rules on website accessibility for most state and local governments from April 24, 2026, to April 27, 2027.
- HHS has not yet acted to provide an additional extension on its website compliance regulation for “recipients” subject to the Rehabilitation Act, but may yet extend that May 2026 deadline.
- The additional year also lengthens the implied “grace period” that state and local government websites had to conform to the website accessibility rule.
In an interim final rule published on April 20, 2026, in the Federal Register, the DOJ justified this deadline based on the significant burdens associated with compliance, along with confusion about some of the provisions. The final rule, issued in April 2024, had given two (or three) years for state and local governments to bring their websites into compliance with the Web Content Accessibility Guidelines (WCAG), version 2.1.
The new deadlines for compliance under this Title II of the Americans with Disabilities Act (ADA) regulation are April 26, 2027, for most governmental entities, and April 26, 2028, for smaller governmental entities.
Will there be a similar reprieve under the Rehabilitation Act regulation due to be effective in early May 2026?
The actions come without any similar reprieve yet granted under a Rehabilitation Act regulation issued by the U.S. Department of Health and Human Services (HHS) that requires compliance in early May 2026 for most “recipients of federal financial assistance” and May 2027 for smaller “recipients.” Because nearly all Title II entities are also deemed “recipients,” a failure to extend the HHS deadline would effectively undermine this extension.
Key Takeaways
The one-year reprieve provides state and local governments with additional time to get their websites, mobile applications, and other electronic information into conformance with WCAG.
The one-year reprieve may also provide additional time for the many entities that act as vendors to state and local government of websites, mobile applications, and other electronic information to bring their products into conformance with WCAG.
As welcome as the reprieve may be, it is not the suspension of, or significant amendment to, the regulation that many had hoped for. Had the administration intended to suspend this regulation, as it has done with many others, this would have been a good opportunity to do so. But, with the additional time, suspension or amendment is certainly possible.
The additional year lengthens the implied “grace period” that state and local government websites had to conform to WCAG. State and local governments sued during the implied “grace period” for lack of website accessibility could argue that the regulation’s compliance period sets the deadline for their compliance.
It remains uncertain what will happen to the May 2026 deadline for a very large group of private sector “recipients” under the Rehabilitation Act.
Ogletree Deakins’ Disability Access Practice Group will continue to monitor developments and will post updates on the Disability Access, Healthcare, and Higher Education blogs as additional information becomes available.
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