Section 504 and the HHS web accessibility rule

In brief

Section 504 of the Rehabilitation Act is separate from the ADA, but it often applies to the same organizations. Under 45 CFR 84.84, recipients of HHS financial assistance must make the web content and mobile apps they provide or make available accessible, using WCAG 2.1 Level A and Level AA.

Dates

• 15 or more employees: from 11 May 2027.
• Fewer than 15 employees: from 10 May 2028.

HHS extended these dates by one year in an interim final rule. They had been 11 May 2026 and 10 May 2027. The technical requirements did not change. Check the Federal Register and the eCFR for later changes.

Scope

• Websites and mobile apps provided or made available directly or through contractual, licensing or other arrangements.
• The same limits apply: a recipient is not required to do what would cause a fundamental alteration in the nature of a program or activity, or undue financial and administrative burdens.

What to do

• Check whether you receive HHS financial assistance.
• If you do, use the same WCAG 2.1 Level AA work plan as for Title II or III.
• Note your date based on your number of employees.

Common mistakes

• Assuming ADA work does not cover Section 504, or the other way round. They overlap, but the rules are separate.
• Using the original 2026 and 2027 dates.

Sources

• 45 CFR 84.84: Requirements for web and mobile accessibility (eCFR), opens in a new tab
• Americans with Disabilities Act, statute text (ADA.gov), opens in a new tab

This page is for informational purposes only and is not legal advice. For binding requirements, refer to the official ADA statute and regulations, and ask a lawyer how they apply to you.