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
| 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
- 45 CFR 84.84, Requirements for web and mobile accessibility (eCFR, current)
- 91 FR 25496: Extension of Compliance Dates (Federal Register, May 11, 2026)
- HHS Office for Civil Rights, Section 504 overview
This page is not legal advice. For questions about coverage or the undue-burden exception, talk to counsel.