HHS Section 504 Web & Mobile Accessibility (Recipients of HHS Financial Assistance)

Current understanding

HHS regulations under Section 504 of the Rehabilitation Act require recipients of HHS financial assistance (hospitals, health programs, human services providers, state Medicaid agencies, etc.) to make their web content and mobile applications accessible to people with disabilities, generally conforming to WCAG 2.1 Level AA. Compliance deadlines were originally staggered by recipient size but have been extended by one year: larger recipients now have until May 2027 and smaller recipients until May 2028. The underlying substantive accessibility obligations remain unchanged; only the effective dates were adjusted.

Evidence log

• 2026-07-24 — Rescinding Portions of the U.S. Department of Health and Human Services Title VI Regulations To Align With the Statutory Text and Conform to Executive Order 14281: cross-connection with hhs-title-vi-disparate-impact-rescission: Both actions affect the civil rights compliance obligations of recipients of HHS financial assistance. (novelty: 2)
• 2025-05-14 — Websites and Software Applications Accessibility Act of 2025: cross-connection with websites-software-applications-accessibility-act: Legislative complement to agency-level Section 504 web/mobile accessibility rules, extending accessibility requirements beyond federal financial-assistance recipients. (novelty: 2)
• 2026-05-11 — Extension of Compliance Dates for Nondiscrimination on the Basis of Disability; Accessibility of Web Content and Mobile Applications of Recipients of Departmental Financial Assistance: cross-connection with online-accessibility-act: Both address digital accessibility standards for websites and mobile apps; HHS’s Section 504 rule imposes WCAG-based requirements on federal-assistance recipients while the Online Accessibility Act would establish broader ADA-based digital standards for private entities. (novelty: 2)

Open questions

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