Standards and laws are different
WCAG is a technical standard. A law, regulation, contract, or organizational policy may require a particular version and level. Legal compliance can also involve effective communication, reasonable modifications, and individual accommodations.
This is general educational information, not a determination of your legal obligations. Coverage, exceptions, and enforcement vary by jurisdiction and circumstances. Sources reviewed September 25, 2026.
ADA Title II: state and local government
The DOJ web and mobile rule adopts WCAG 2.1 Level AA for covered state and local government web content and mobile apps, including certain services provided through contractual arrangements.
DOJ extended the compliance dates in an interim final rule published April 20, 2026:
- April 26, 2027: public entities with a total population of 50,000 or more, other than special district governments.
- April 26, 2028: public entities below 50,000 and all special district governments.
The rule includes defined exceptions and other provisions; they are not blanket permission to leave services inaccessible. Existing ADA obligations continue before these deadlines.
Official guidance: DOJ web rule fact sheet
Official guidance: First steps for public entities
ADA Title III: public accommodations
DOJ takes the position that the ADA applies to the goods and services public accommodations offer through the web. Covered businesses must consider equal access and effective communication.
Do not apply Title II’s technical rule and deadlines as if they were a universal rule for private businesses. Coverage and legal analysis can depend on the jurisdiction and facts.
Official guidance: DOJ guidance on web accessibility and the ADA
Employment and accommodations
ADA Title I addresses covered employment, including accessible recruitment and reasonable accommodations. Workplace software, documents, training, and communications can affect an employee’s access to work.
Official guidance: EEOC reasonable accommodation resources
Sections 504 and 508
Section 504 prohibits disability discrimination in covered federally funded programs and activities. Agency regulations matter. HHS adopted web and mobile accessibility requirements and announced a one-year compliance-date extension in May 2026; consult its current guidance for the applicable schedule.
Official guidance: HHS deadline update
Section 508 addresses federal information and communication technology. The revised standards incorporate WCAG 2.0 A and AA for covered content and contain additional ICT provisions. Receiving federal funding alone does not automatically subject an organization to Section 508.
Official guidance: Revised Section 508 Standards
Physical access requirements
The ADA Standards address covered built-environment features. The analysis differs for new construction, alterations, existing barriers, and public-sector program access. State and local building codes can add requirements.
Official guidance: ADA Accessibility Standards
Selected international requirements
European Union: the European Accessibility Act covers specified products and services. Check national implementation, scope, exemptions, and transitional provisions; it is not a universal rule for every website.
Official guidance: European Commission EAA overview
United Kingdom: official guidance for covered public-sector websites and apps identifies WCAG 2.2 AA and an accessibility statement, with applicable scope and exceptions. Other disability law obligations may also apply.
Official guidance: UK public-sector accessibility guidance
Questions for your compliance review
- Which entity, service, jurisdiction, and funding source are involved?
- Which standard, version, level, and deadline are specified?
- What do contracts and procurement terms require?
- Are exceptions applicable, and what other access duties remain?
- Who owns requests, complaints, remediation, and documentation?
Keep a dated record of authoritative sources and review changes with appropriate legal and accessibility expertise.