Where this comes from
Three separate laws, one standard. Each of them reaches the documents you publish, not just the pages around them.
- Public agencies
- ADA Title II. The Justice Department's web rule sets WCAG 2.1 AA for state and local government. April 26, 2027 for entities serving 50,000 people or more; April 26, 2028 for smaller ones and for special districts. Both dates moved back a year on April 20, 2026.
- Nonprofits funded by HHS
- Section 504. Same standard, different clock. May 11, 2027 at fifteen or more employees and May 10, 2028 below that, after an extension issued May 7, 2026. The nondiscrimination duty underneath has been in force since July 8, 2024.
- Anyone open to the public
- ADA Title III. No deadline, because there has never been one to extend. The Justice Department and most courts already read the statute to cover web content, and that reading applies today.
The deadlines moved. The exposure didn't.
Plaintiffs filed 3,117 website accessibility suits in federal court in 2025 — up from 2,452 the year before, and 36 percent of every ADA Title III case filed, by Seyfarth Shaw's count. In California the Unruh Civil Rights Act stacks a $4,000 statutory minimum per violation on top of any ADA finding, plus fees, which is why the state stays near the top of the filing tables.
None of that waits for a compliance date.
An old document is not automatically an exempt one.
Both federal rules carve out archived content and documents that already existed before the deadline — and the carve-out drops the moment a file is still used to apply for or access a service. Most libraries sit right on that line.
Drawing it is what this check is for. Every document lands in a bucket with the reasoning printed beside it, so you can hand the judgment calls to counsel instead of guessing at them.