Field guide · compliance deadlines
The 2025–2028 accessibility deadlines
One deadline has already passed. Two more are on the calendar for U.S. state and local government sites. None of them are optional, and none of them wait for a scan to be convenient.
Last reviewed 26 September 2026
European Accessibility Act: already enforceable
The European Accessibility Act (Directive (EU) 2019/882) became enforceable on June 28, 2025. It reaches private-sector products and services sold in the EU, including e-commerce, banking, e-books, and passenger transport. That is a much wider net than public-sector rules, and one most U.S.-based teams selling into Europe underestimate.
There is no phase-in left to plan around: if a covered product or service shipped after that date, the obligation is already live.
ADA Title II: two dates, not one
The Department of Justice finalized its ADA Title II web and mobile app rule on April 24, 2024, covering state and local government entities in the United States. An interim final rule published April 20, 2026 pushed the original single deadline back and split it in two:
- April 26, 2027: state and local government entities serving a population of 50,000 or more.
- April 26, 2028: smaller entities and all special district governments, regardless of population.
The technical requirement did not change, only the timeline. A 2027 deadline is nearer than it sounds once you count the months an audit-and-fix cycle actually takes on a real government site with an authenticated citizen portal behind it.
The standard both point to
Both regimes measure conformance against WCAG 2.1 Level AA. Neither rule requires a specific tool or vendor. They require the outcome axe-core checks for deterministically: alt text, labeled forms, keyboard operability, contrast, and the rest of the 2.1 AA success criteria.
What to do this quarter
- Run a baseline scan now, not near the deadline. Crawl the site, including any state that only exists after a citizen signs in, and see the actual defect count before committing to a fix timeline.
- Fix critical and serious findings first. A missing accessible name on a form control blocks a task outright; a nice-to-have contrast tweak doesn't. Triage by what a screen reader user actually hits.
- Gate new work in CI. A baseline plus a CI accessibility gate stops the backlog from growing while it's being cleared.
- Don't reach for an overlay. A widget that adjusts contrast or font size on top of the existing markup doesn't fix the underlying barrier, and it is not accepted as compliance evidence by either regime.
- Keep a dated record of progress. A retest comparison between two scans (new, cleared, still-open) is the evidence an agency or a client will ask for later.
Not legal advice
Sources
- Federal Register 2026-07663: DOJ interim final rule extending ADA Title II web/app compliance dates (published April 20, 2026).
- ADA.gov: Title II web and mobile app rule: the department's own summary of the original rule and the 2026 extension.
- Directive (EU) 2019/882: the European Accessibility Act, in force since June 28, 2025.