The Department of Justice has extended ADA Title II compliance deadlines to April 2027 for entities serving 50,000 or more people, and to April 2028 for smaller entities. Similarly, HHS extended Section 504 deadlines to May 11, 2027, for organizations with 15 or more employees, and to May 10, 2028, for smaller organizations.
If you're interpreting this as a reason to delay accessibility work, you're missing the point. The extension offers time to build a program that withstands audits, vendor changes, and leadership shifts. It doesn't eliminate your current obligations under ADA Title II or Section 504. Individuals with disabilities can still file complaints, DOJ enforcement continues, and state laws remain active.
The real question is whether you'll use this time to create a sustainable program or find yourself scrambling again in 2027.
What You Need Before Starting
Organizational clarity:
- Determine which rule applies: ADA Title II for state and local governments, Section 504 for HHS funding recipients, or both.
- Identify your compliance deadline based on population or employee count.
- Document any state-level accessibility laws that might impose earlier or stricter requirements.
Technical baseline:
- Inventory your public-facing digital properties: websites, mobile apps, documents, social media accounts, and third-party platforms.
- Review existing vendor contracts and procurement processes.
- Ensure access to conformance testing tools, both automated and manual.
- Secure budget authority for remediation, training, and ongoing monitoring.
Stakeholder buy-in:
- Secure an executive sponsor who understands this isn't a one-time project.
- Involve IT, procurement, communications, and legal representatives who can allocate resources.
- Define clear ownership: who signs off on vendor contracts, approves content, and responds to accessibility complaints.
You don't need perfection to start. You need accountability and a realistic view of your current state.
Step-by-Step Implementation
Month 1: Establish governance and baseline
Create a cross-functional accessibility team with defined decision rights. Procurement, IT, communications, and legal must all participate. Assign a program lead with authority to block non-conformant purchases.
Run a baseline audit against WCAG 2.1 Level AA. Use automated tools like axe DevTools, WAVE, and Lighthouse to identify common failures: missing alt text, color contrast violations, keyboard traps, and unlabeled form fields. Document findings by property and severity.
Prioritize remediation based on user impact, not technical complexity. A login form that screen reader users can't navigate is more critical than a decorative image missing alt text on a legacy PDF.
Month 2-3: Build procurement controls
Revise your vendor onboarding process to require accessibility documentation before contract signature. Request a current Accessibility Conformance Report for any software, content management system, or digital service you're acquiring. If the vendor can't produce one, that's a red flag.
Add accessibility language to RFPs and master service agreements. Specify WCAG 2.1 Level AA conformance as a contractual requirement, not a best effort. Include remediation timelines and penalties for non-conformance.
Train procurement staff to recognize incomplete or misleading accessibility claims. A vendor saying "we take accessibility seriously" without documentation isn't conformant. A Voluntary Product Accessibility Template from 2019 referencing WCAG 2.0 isn't current.
Month 4-6: Remediate high-priority properties
Start with services that people with disabilities use most frequently: online forms for permits, licenses, and benefits; public meeting notices; emergency alerts; healthcare portals.
Fix structural issues first: heading hierarchy, landmark regions, focus order, form labels. These failures block entire workflows for assistive technology users. Then address color contrast, link text, and alternative text.
Document your remediation process. When you fix a contrast violation, record the before and after color values. When you add alt text, note the decision criteria. You'll need this documentation if you face a complaint or audit.
Month 7-12: Operationalize accessibility
Integrate conformance testing into your content publishing workflow. No document, video, or social media post goes live without an accessibility check. Train content creators on accessible authoring: how to structure a Word document with styles, when to use aria-label, how to write meaningful alt text.
Establish a complaint response process. Designate a point of contact for accessibility issues. Commit to response timelines. Track complaints by category to identify systemic problems.
Schedule quarterly vendor reviews. Request updated conformance reports. Test vendor-supplied products yourself. Don't rely solely on vendor claims.
Validation: How to Verify It Works
Technical conformance: Run monthly automated scans on all public-facing properties. Track the number of WCAG violations over time. You should see a downward trend.
Conduct quarterly manual testing with screen readers like NVDA, JAWS, and VoiceOver. Navigate your highest-traffic workflows using only a keyboard. If you can't complete a task without a mouse, neither can many users with disabilities.
Procurement conformance: Audit your last 10 vendor contracts. How many included accessibility requirements? How many vendors provided conformance documentation before contract signature? If fewer than 8 out of 10, your procurement controls aren't working.
Review your Accessibility Conformance Reports. Are they current (within 12 months)? Do they reference WCAG 2.1 or 2.2? Do they document known issues and remediation timelines? Generic statements about commitment to accessibility don't count.
Operational conformance: Track the percentage of published content that passes accessibility review before going live. Your target is 100%. If you're publishing first and fixing later, you're creating technical debt faster than you can remediate it.
Monitor complaint volume and resolution time. An increase in complaints may indicate new accessibility barriers. A decrease in resolution time indicates your process is maturing.
Maintenance and Ongoing Tasks
Accessibility isn't a project with an end date. It's a capability you build into how your organization operates.
Quarterly:
- Review and update your accessibility conformance documentation.
- Test new features and content types introduced since the last review.
- Audit vendor conformance reports and request updates where needed.
- Assess training effectiveness: are new staff following accessible authoring practices?
Annually:
- Conduct a full conformance audit against the current version of WCAG.
- Review procurement contracts for accessibility clause compliance.
- Evaluate state-level law changes that may affect your obligations.
- Budget for next year's accessibility work: tools, training, remediation, third-party audits.
Continuously:
- Monitor WCAG updates and browser/assistive technology changes.
- Review accessibility complaints for patterns that indicate systemic issues.
- Test new vendor products before deployment.
- Incorporate accessibility into your change management process.
Organizations that use this extension to build sustainable programs will be ready in 2027. Those that treat it as a postponement will find themselves scrambling again when the deadline arrives. The timeline shifted; your obligation to provide equal access did not.
