ADA web compliance deadlines are the federal-rule effective dates for WCAG 2.1 AA conformance. The headline dates today: April 26, 2027 and April 26, 2028for ADA Title II (extended one year by the DOJ's April 2026 Interim Final Rule), May 11, 2026 for HHS Section 504 (NOT extended), and June 28, 2025 (already past) for the EU Accessibility Act.
April 26, 2027(was April 24, 2026)
Applies to: State and local government entities serving populations of 50,000+
Technical standard: WCAG 2.1 Level AA
Enforcement: U.S. Department of Justice
DOJ Interim Final Rule, 91 Fed. Reg. 20902 (April 20, 2026)
SourceApril 26, 2028(was April 26, 2027)
Applies to: State and local government entities serving populations under 50,000, and special district governments regardless of population
Technical standard: WCAG 2.1 Level AA
Enforcement: U.S. Department of Justice
DOJ Interim Final Rule, 91 Fed. Reg. 20902 (April 20, 2026)
SourceJune 22, 2026
Applies to: Open to anyone
Technical standard: —
Enforcement: U.S. Department of Justice
SourceMay 11, 2026
Applies to: Recipients of HHS funding with 15+ employees (most hospitals, clinics, healthcare providers, educational institutions)
Technical standard: WCAG 2.1 Level AA
Enforcement: HHS Office for Civil Rights
NOT EXTENDED — HHS has not matched the DOJ IFR
SourceMay 10, 2027
Applies to: Recipients of HHS funding with fewer than 15 employees
Technical standard: WCAG 2.1 Level AA
Enforcement: HHS Office for Civil Rights
SourceJune 28, 2025
Applies to: Any business serving EU customers regardless of where headquartered. Microenterprise exemption: <10 employees AND <€2M turnover.
Technical standard: EN 301 549 v3.2.1 (incorporates WCAG 2.1 Level AA)
Enforcement: Each EU member state
SourceNo formal deadline
Applies to: Private businesses that are 'places of public accommodation' — most B2C websites
Technical standard: Courts and DOJ apply WCAG 2.1 Level AA as the operative benchmark, but there is no formal regulatory deadline.
Enforcement: DOJ + private plaintiffs
SourceOnly ADA Title II was extended, by the DOJ's April 2026 Interim Final Rule. Three things were not extended:
Full Title II rule + IFR breakdown →
The consequences differ by which rule applies to you, and none of them require a lawsuit to land on your desk first — enforcement can start the day a deadline passes.
The DOJ enforces Title II through complaint investigations, compliance reviews, pattern-or-practice lawsuits, and intervention in private suits. Individuals can sue a government entity directly in federal court without filing with a federal agency first. Available remedies include injunctive relief, compensatory damages (no dollar cap under Title II), and attorneys' fees. Punitive damages aren't available against government entities, but entities that receive federal funding also risk losing it.
DOJ-initiated Title III enforcement can carry civil penalties up to $75,000 for a first violation and $150,000 for subsequent violations. In practice, far more businesses face private lawsuits: plaintiffs filed 3,117 federal website accessibility lawsuits in 2025 (+27% year-over-year), and roughly 95% of sued companies settle rather than litigate. Demand-letter settlements typically run $1,000–$25,000; the average out-of-court settlement is around $25,000 (occasionally up to $100,000); and the average court judgment in a website case runs roughly $75,000. In California, the Unruh Civil Rights Act adds statutory damages of $4,000 per violation on top of any federal remedy, without the plaintiff needing to prove actual harm.
HHS's Office for Civil Rights investigates complaints (typically filed within 180 days of the alleged discrimination) and can require a corrective action plan. The ultimate enforcement tool is the threat of terminating federal funding — rarely used, but real. Unlike Title III, Section 504 also permits compensatory damages in private lawsuits.
Complaints go through the agency's own administrative process, or a private lawsuit for injunctive relief. For vendors selling to the federal government, the more immediate risk is procurement: agencies can reject bids or decline to renew contracts with vendors whose products don't meet Section 508 standards.
None of this requires — or is solved by — an overlay widget marketed as instant compliance. The FTC fined accessiBe $1 million in April 2025 for falsely claiming its overlay made sites WCAG-compliant, and 22.64% of sites sued in H1 2025 already had an overlay installed at the time of suit.
The ADA became law on July 26, 1990, and Title II and Title III took effect January 26, 1992 — before the World Wide Web was publicly available and years before e-commerce existed. Congress had no reason to write “website” into a 1990 statute, and for over three decades neither Congress nor the DOJ amended the text to add one.
That silence didn't stop the law from applying. Title III's text requires “full and equal enjoyment” of the goods and services of a place of public accommodation, and as commerce moved online, plaintiffs argued that requirement covered websites too — with no regulation spelling out exactly what “accessible” meant technically. The DOJ periodically signaled that it agreed, including a March 18, 2022 guidance document reaffirming that Title III's web accessibility obligations were already in force. But guidance isn't a binding regulation, so it fell to courts to decide case by case — and they split.
The Ninth Circuit's Robles v. Domino's Pizza(2019) held that Title III applies to a website or app with a “nexus” to a physical place of public accommodation, rejecting Domino's argument that the absence of specific DOJ regulations made the claim premature. The Supreme Court denied certiorari later that year, leaving the ruling in place. Two years later, the Eleventh Circuit's Gil v. Winn-Dixie(2021) went the other way, holding that Winn-Dixie's website was nota “place of public accommodation” under Title III — a direct circuit split that persists today.
The DOJ finally closed part of this gap on April 24, 2024, publishing the first federal rule to codify a specific technical standard — WCAG 2.1 AA — for web accessibility under the ADA. But that rule only reaches Title II (state and local government). Private businesses under Title III still have no formal regulatory technical standard; courts and the DOJ continue to apply WCAG 2.1 AA as the de facto benchmark, and the circuit split from Robles and Winn-Dixie is still live. See the full Title III circuit-split breakdown for what that means jurisdiction by jurisdiction.
A deadline that's a year or two out is exactly the amount of runway you need to do this right instead of scrambling. A practical order of operations: