National ADA Symposium Takeaway #4: What should an extra year accomplish in meeting Digital Compliance?
In 2026, the Department of Justice and the Department of Health and Human Services disrupted the important digital accessibility compliance deadlines. Many counties, colleges, hospitals, and school districts welcomed the delay. I can see why, there had been a buildup of content, a shortage of staff, and a lack of budgeting for the extent of the work required. But changing the deadlines means little if the systemic issues still exist.
The reality of who is affected have stayed with me since the National ADA Symposium; although an extra year might ease the immediate pressure, what matters is whether that time leads to real improvements in access. And most importantly, how will the people who rely on the information be served?
Braille Works has recently discussed the change to the HHS deadline and the responsibilities that still need to be met. In this instance, I would like to focus on what organizations can demonstrate during the additional time that has been granted to them.
What has occurred
The Department of Justice moved the compliance date for larger state and local government bodies to April 26, 2027, and established April 26, 2028, as the compliance date for smaller public bodies and special district governments. The Health and Human Services agency set May 11, 2027, for recipients with 15 or more employees, and May 10, 2028, for those with fewer than 15 employees. The rules under Title II and Section 504 still make use of WCAG 2.1 Level AA.
HHS altered the dates in its Section 504 regulation; it did not amend Section 1557 of the Affordable Care Act. Because many healthcare organizations comply with both laws, the requirements of the two are often discussed together.
The agencies cited staffing problems, cost considerations, technical limitations, among other complaints. The disability groups replied that the agencies had taken the burden into account when they introduced the 2024 rules.
The DOJ took action four days before its first compliance date on April 22, 2026. On May 21, 2026, the National Federation of the Blind brought a federal lawsuit challenging both extensions. It claims that the DOJ and HHS violated the Administrative Procedure Act by not giving sufficient consideration to the harm caused by inaccessible services. The court has not yet ruled. AHEAD and 34 disability-rights organizations had previously opposed a delay under Title II. As you can see there is a lot of reason for concern on the part of Americans’ with disabilities and the organizations that support them.
I take the practice of accessibility serious and am aware of the frustration people are now experiencing as they wait even longer for access. The practical solution lies in accountability, since the organizations have been given more time and they need to be prepared to show what they achieved with it.
The starting point has to be honest
A good starting point for organizations is to get organized by prioritizing the pages, forms, documents, and applications which people require equal access. This approach enables the identification of the services that have the greatest impact, allows tracking of how long high-priority obstacles remain unresolved, and measures the speed at which problems are addressed after they are noticed or reported.
The initial report will probably appear worse than anticipated. It is common for this discovery process to reveal issues that had previously gone unaccounted. Make sure the process remains consistent across all departments in the review and reporting of information. This is the only way to get an accurate picture of the necessary steps that need to be taken to meet the compliance dates.
New content changes the data
A company can’t eliminate an existing backlog if new obstacles keep being introduced; it’s like trying to empty a bucket while someone keeps pouring water into it.
The earliest indication of progress should be a reduction in the number of problems starting with new content. Although accessible templates are useful, someone must still check the work and have the authority to delay a release if it is not accessible. Keep a record of how much new content goes through without being published. When the same template, system, department, or vendor continues to cause problems, the underlying cause should be addressed rather than repeatedly correcting the same error.
Not every barrier carries the same weight
It is not possible for an organization with thousands of files to address all matters at once, so you should begin with the services that have the most serious consequences, are used most frequently, or handle urgent information. You must provide a reason for choosing those services first, and this explanation will be important if the organization must make difficult decisions or provide proof of reasoning.
Check the entire process using assistive technology or have a reputable third party assist in this process. Is it possible for a person to access all of the information, open a form, fill it out, submit it, and then receive communications without any assistance? Keep in mind one page or document may be manageable; the process as a whole could still fail. It is wise to get the documents certified, especially if you are using a third-party vendor.
A year needs checkpoints
Don’t delay action until the last quarter. In the first months, you should establish the baseline, decide on priority services, allocate responsibilities, and confirm the budget. At every quarterly review, you must compare the pass rate for new content, the pass rate for the high-priority backlog, the pass rate for the oldest unresolved barriers, the time taken to fix issues, and the sources that continue to cause problems.
When you get to the halfway stage, recheck the priority tasks and make changes to the plan if the team is still unable to complete them. In the final 90 days, carry out an independent review and keep a clear record of any important work which remains open. If a vendor or platform is preventing progress, decide who is going to escalate the issue and by what date. ‘Waiting on the vendor’ should be treated as a status, not as a solution.
This schedule allows the ADA accessibility coordinators to raise their concerns while still giving leadership the opportunity to respond; it also makes it so that the extension does not turn into yet another last-minute rush.
The proof at the deadline
On arrival of the new deadline, leaders ought to place the initial report alongside the present one and give a clear and simple explanation of the differences. For any critical work which is still open, there should be an owner, a deadline, and a clear reason for why it has not been completed.
Certain organizations will still have some work to carry out. Making honest progress does not mean achieving perfection. The thing that worries me is that reports contain a lot of references to training hours, the purchase of software, and meetings, yet nobody can state that access has in fact improved.
The year in question will have been worthwhile only if more people are able to access the content that is most important, and if the organization can demonstrate how, it achieved that.
This information is not legal advice, and the regulatory and case statuses are up to date as of August 31, 2026.
