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Insights · August 26, 2026

Accessibility Law Deadlines for 2026 and 2027

Four laws have dates on the calendar. Two of those dates moved in 2026, which is why half the advice you will find online is a year out.

Most accessibility law is already in force. A few obligations carry deadlines still ahead, and those are near enough to plan around now. This is the picture in August 2026, with each law linked to its full guide.

Already in Force: The European Accessibility Act

The EAA has applied since June 28, 2025 to e-commerce, consumer banking, electronic communications, e-books and other consumer services sold into the European Union, and it reaches companies based outside the EU that sell into it. Enforcement happens through national law rather than through the directive itself. Germany's BFSG is the furthest along. Its market surveillance body started work in September 2025 and adopted its enforcement strategies in January 2026, which moved it from preparing to checking, and it checks accessibility statements first and conformance after.

One exemption is worth knowing before you assume this reaches you. A microenterprise providing services, meaning fewer than 10 employees and either turnover or a balance sheet total no higher than 2 million euros, is exempt from the accessibility requirements for those services. The exemption covers services and not products.

April 26, 2027: US State and Local Government

The Department of Justice's Title II rule makes WCAG 2.1 Level AA a formal requirement for state and local government web content. It reaches public entities, so school districts, cities, counties and public universities are in, along with content a vendor supplies to them under contract. A private college is not.

The dates moved, which matters if you have read anything about this before. The original deadlines were April 24, 2026 and April 26, 2027. Four days before the first one landed, the DOJ published an interim final rule pushing both back by a year. So public entities with a Census population of 50,000 or more now have until April 26, 2027, and smaller ones and special district governments have until April 26, 2028. Watch that word population, because the DOJ says outright that it is not the number of people you serve. It is the Census population of the entity you are part of, which is why a state university inside a large state lands in the earlier tier however few students it has. Advice written before April 2026 will give you the old pair.

May 11, 2027: US Healthcare

The HHS Section 504 rule reaches recipients of federal financial assistance from the Department of Health and Human Services, which takes in most healthcare providers through Medicare and Medicaid. Read that scope as it is written, though, because it is neither every provider taking any federal money nor healthcare alone. Recipients with fifteen or more employees have until May 11, 2027, and smaller ones until May 10, 2028. These dates moved by a year as well, from 2026 and 2027. Web content and mobile apps are both covered, so patient portals, appointment booking and telehealth platforms all sit inside the rule.

Already Past: Colorado

Colorado's compliance date under HB21-1110 was July 1, 2024, and it never moved. What ended on July 1, 2025 was something narrower, a statutory immunity from liability that a public entity only had if it had published a progress report on its public pages by July 2024, updated it quarterly, and set up a clear way to request redress. Entities that did not do those three things never had the immunity to lose.

What did not expire is the compliance route built on progress. Under the rules, an entity that publishes a technology accessibility statement, provides reasonable accommodations, and can evidence good-faith progress against a plan is in compliance even where its technology does not fully conform. Colorado is enforcing now, and effort against a documented plan still counts.

What the dates mean in practice

Every deadline above has WCAG somewhere behind it, so the first move is the same one in every jurisdiction. Find out where your site stands. One caution before you treat a scan as the whole answer, because several of these laws ask for more than WCAG conformance. The European Accessibility Act adds functional requirements and a published information duty, Colorado offers alternative compliance routes, and most of them carry exceptions that decide whether they reach you at all. The free scan covers the machine-checkable part today at no cost, and the law library explains the rest, including the ones with no date attached. Dates checked August 2026.

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