There are two federal web accessibility deadlines landing weeks apart in 2027, and they are constantly mistaken for each other. If you have been told your practice has to be ready by April, that is very likely the wrong rule.
The two rules side by side
| ADA Title II | Section 504 | |
|---|---|---|
| Agency | Department of Justice | Health and Human Services |
| Regulation | 28 CFR Part 35 | 45 CFR Part 84 |
| Who it covers | State and local government entities | Recipients of federal financial assistance |
| What triggers it | Being a government entity | Billing Medicare or Medicaid |
| Size threshold | Population served | Employees |
| Earlier deadline | April 26 2027, population 50,000+ | May 11 2027, 15+ employees |
| Later deadline | April 26 2028, under 50,000 plus special district governments | May 10 2028, under 15 employees |
| Standard | WCAG 2.1 Level AA | WCAG 2.1 Level AA |
The technical requirement is identical. Everything else differs.
Why the mix-up happens
April 2027 got substantially more press. The DOJ rule covers every city, county, school district, and public university in the country, so it was covered widely and the date entered general circulation as the web accessibility deadline.
It is not the healthcare deadline. A private medical practice is not a government entity and ADA Title II does not reach it. If a vendor is quoting you April 2027, they are quoting a rule that does not apply to you. That is worth noticing, because it tells you something about how carefully they have read.
Working out which is yours
A private practice, clinic, or group. Section 504 applies if you bill Medicare or Medicaid. Your dates are May 11 2027 at 15 or more employees, May 10 2028 below that. Note that Medicare Part B on its own is now enough to trigger it.
A county health department, public hospital district, or state-run clinic. Potentially both. ADA Title II because you are a government entity, and Section 504 as well if you receive federal financial assistance. The earlier applicable date is the one that matters, and since both name WCAG 2.1 AA, meeting one gets you the other.
A cash-pay-only private practice. Neither of these dated rules applies. No federal financial assistance means no Section 504; not being a government entity means no Title II.
That is not the same as having no exposure. Private practices are places of public accommodation under ADA Title III, which has no published WCAG deadline but is the basis for most of the website litigation that actually happens. Thousands of Title III web accessibility suits are filed annually, and none of them wait for 2027.
The size threshold trap
The two rules measure size in completely different units, which produces confident wrong answers.
Under Title II the split is the population the entity serves, using 2020 Census figures. Independent school districts are measured differently again, using 2022 SAIPE data, and special district governments are carved out to the later date regardless.
Under Section 504 the split is simply how many employees the recipient has. Not providers, not locations, not patients, not revenue.
A twelve-person practice serving a city of 200,000 is on May 10 2028, the later date, because employees are what counts for the rule that applies to it. Reaching for the population figure lands you on April 2027, a date from a rule that does not cover you.
Both are being challenged
In May 2026 the National Federation of the Blind sued DOJ and HHS in the District of Maryland over the one-year extensions that produced these 2027 dates, arguing they were issued without required notice and comment. The suit asks the court to vacate them, which would pull the deadlines earlier. No ruling has issued.
The practical conclusion is the same either way: the dates can move earlier but are unlikely to move later, and the underlying duty to communicate effectively with people who have disabilities is already in force and already actionable.
This page is general information about federal rules, not legal advice. Which rule reaches your organisation is a legal question about your facts. Ask your own counsel.
Related
- Section 504 web accessibility: the requirement in full
- Does Medicare Part B trigger Section 504?: the reversal most guidance misses