Government websites, online forms, court PDFs, e-filing and payment portals, mobile apps and LMS course materials are all within scope.

On April 20, 2026—just four days before the original compliance deadline—the Department of Justice (DOJ) published an interim final rule pushing back its web and mobile app accessibility deadlines by a year. The interim final rule took effect immediately. The extension is welcome, but the DOJ made clear it "fully anticipates implementing the regulation at the new deadline," and existing ADA obligations continue to apply in the meantime.

The 2024 rule was the DOJ's first attempt to set specific technical standards for web and mobile app accessibility under Title II, which covers state and local governments, public colleges and universities, courts and special districts (such as water, fire protection and transit authorities). It adopted WCAG 2.1 Level AA as the required standard, and its scope is expansive—applying not only to the content a covered entity produces itself but also to anything "provided or made available" through vendors or licensors. Government websites, online forms, court PDFs, e-filing and payment portals, mobile apps and LMS course materials are all within scope.

The New Deadlines

The interim final rule changes only the timing of the rule going into effect. WCAG 2.1 Level AA remains the standard, and all covered entities must still bring their digital content into full conformance by the new dates. 

Why the Delay?

The DOJ admitted it "overestimated the capabilities (whether staffing or technology) of covered entities to comply." Automated remediation tools aren't reliable enough yet—particularly for complex educational and STEM content—and many public entities, especially large university systems with thousands of sites and millions of pages, lack the staff, expertise or budget to meet the original deadlines. The Department also noted the real litigation exposure for entities that would have missed the deadline, given Title II's private right of action and fee-shifting provision.

What the Extension Does Not Do

The interim final rule only delays the WCAG 2.1 Level AA compliance dates. It does not suspend Title II's underlying nondiscrimination and effective-communication obligations, which have long supported web accessibility claims even without a specific technical standard. Private plaintiffs and advocacy organizations can (and likely will) still sue during the extension period.

Separately, the Department of Health and Human Services (HHS) Section 504 rule from May 2024—which imposes parallel web and mobile accessibility requirements on recipients of HHS funding—still has its original May 11, 2026, first compliance deadline. HHS has not matched the DOJ's extension. Healthcare providers, educational institutions and other HHS-funded entities should plan accordingly.

What to Do Now

Don't treat the extra year as a pause. The DOJ's language about "fully anticipating" enforcement at the new deadline is clear. As such, use the time allowed to:

• Complete a WCAG 2.1 Level AA audit of your primary sites and apps, inventory third-party content and review vendor contracts to make sure accessibility is built into procurement.
• Train staff who create or post web content on accessibility basics so new content doesn't add to the remediation backlog.
• If you receive HHS funding, run a separate compliance assessment under the HHS Section 504 rule—its deadline has not moved.
• Consider commenting on the interim final rule before the June 22, 2026, deadline for public comments.

For More Information

If you have any questions about this Alert, please contact J. Colin Knisely, any of the attorneys in our Website Accessibility and Privacy Compliance Litigation Group, any of the attorneys in our Technology, Media and Telecom Industry Group or the attorney in the firm with whom you are regularly in contact.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.