Healthcare & Section 504

In 2024, HHS updated its Section 504 regulations to require that web content and mobile apps from recipients of HHS financial assistance meet WCAG 2.1 Level AA. In May 2026, HHS extended the compliance dates. Here is a summary, with links to the rule itself.

Who the rule applies to

The rule applies to recipients of financial assistance from the Department of Health and Human Services. That includes many hospitals and clinics. If you're not sure whether yours is covered, check the regulation or ask counsel.

What it requires

Under 45 CFR 84.84, a recipient must ensure that the web content and mobile apps it provides or makes available meet the Level A and Level AA success criteria of WCAG 2.1, unless the recipient can show that compliance would cause a fundamental alteration to a program or an undue financial and administrative burden.

Compliance dates

Compliance dates under 45 CFR 84.84(b), as amended by the May 2026 interim final rule
Recipient size Compliance date
15 or more employees May 11, 2027
Fewer than 15 employees May 10, 2028

These dates come from an interim final rule HHS published on May 11, 2026 (91 FR 25496, Document Number 2026-09266), which extended the compliance dates originally set in the 2024 final rule. The current regulatory text, including this amendment, is at 45 CFR 84.84 on eCFR.

Primary sources

This page is not legal advice. For questions about coverage or the undue-burden exception, talk to counsel.