Summary: The HHS Section 504 rule requires organizations that receive funding from the U.S. Department of Health and Human Services to make their websites and mobile apps meet WCAG 2.1 Level AA, the international accessibility standard. In May 2026, HHS extended the deadlines by a year: May 11, 2027 for organizations with 15 or more employees, and May 10, 2028 for smaller ones. That includes community health centers, Head Start programs, and many New Hampshire nonprofits funded through HHS programs. Here's what the rule asks for, who it covers, and why your current website may not be ready.
A lot of articles online still list the original 2026 and 2027 dates. Everything below reflects where things stand as of November 2026.
What the HHS accessibility rule requires
In May 2024, HHS updated its rules under Section 504 of the Rehabilitation Act, the law that bars disability discrimination in programs that receive federal money. For the first time, the rule spells out a technical standard for websites and mobile apps: WCAG 2.1, Level A and AA.
WCAG stands for Web Content Accessibility Guidelines. It's the international checklist for making a website usable by people who are blind or have low vision, are deaf or hard of hearing, can't use a mouse, or process information differently. In everyday terms, Level AA covers things like:
Text that's dark enough to read against its background
Descriptions on images so screen readers can explain them
Captions on videos
Forms that work with a keyboard and tell people what went wrong
Headings that give the page a clear structure
Links and buttons that say where they go
The rule also covers content a vendor or contractor provides for you, like an online donation form, a registration system, or a patient portal.
Who the rule covers
The rule applies to any organization that receives federal financial assistance from HHS. That's a wider group than hospitals. HHS and the law firms tracking this rule name examples like:
Community health centers and clinics
Head Start agencies
Organizations that accept Medicare or Medicaid
Family support, behavioral health, and social service nonprofits funded through HHS programs
Colleges and universities with HHS funding
In New Hampshire, a lot of HHS money reaches nonprofits through contracts with the NH Department of Health and Human Services instead of directly from Washington. NH DHHS funds programs at family resource centers with a mix of federal and state dollars, and the state's 10 community mental health centers hold state contracts that include federal funding. NH's community health centers also receive federal HHS grants directly. If your funding agreement traces back to a federal HHS program, ask your program officer or attorney whether Section 504 applies to you. That question is worth answering now, while there's still time to plan.
The number of employees doesn't decide whether the rule applies. It only decides which deadline you get.
HHS Section 504 website accessibility deadlines
The original deadline for larger organizations was May 11, 2026. On May 7, 2026, four days before it arrived, HHS issued an interim final rule that moved both deadlines back one year. HHS said many community health centers, hospitals, and primary care centers weren't going to make the original dates, and it wanted to line up with a similar delay the Department of Justice gave state and local governments.
| Organization size | Original deadline | Current deadline |
|---|---|---|
| 15 or more employees | May 11, 2026 | May 11, 2027Current |
| Fewer than 15 employees | May 10, 2027 | May 10, 2028Current |
The standard itself didn't change. It's still WCAG 2.1 Level AA.
What the extra year doesn't change
The delay moved the date for meeting the technical standard. Everything else in Section 504 still applies today:
You still have to make reasonable accommodations. If someone can't use your website because of a disability, you're expected to help them get the same information or service another way.
People can still file complaints and lawsuits. Section 504 lets individuals sue, and the HHS Office for Civil Rights can open a review at any time.
New content keeps adding up. Every PDF, flyer, and event page you post between now and the deadline is something you'll have to fix later if it isn't accessible from the start.
HHS also said it may propose changes to the rule itself, and that the new dates hold unless it does. As of this writing, no proposal has been published. I'd plan for May 2027 or May 2028 and treat any further change as a bonus.
Why your current website may not be ready
Odds are, your website has accessibility problems right now. When WebAIM tested the home pages of the top one million websites in 2026, 95.9% had detectable WCAG failures, and software can only catch some of them. If your site was designed before 2018, it was built before WCAG 2.1 even existed. Common problems include:
Light gray or brand-colored text that's too faint to read
Images with no description, or a file name like "IMG_4032"
Headings chosen for their size instead of their place in the page
Buttons and links that say "Click here" or "Learn more" with no context
Scanned PDFs that a screen reader can't read at all
Videos with no captions
Embedded forms and calendars from other services that don't work with a keyboard
Accessibility widgets, the little icons that promise to fix a site with one line of code, don't solve these. The fixes happen in the design, the content, and the way each page is put together.
An inaccessible site is often an outdated one, too. It may be hard for your staff to update, slow on phones, or still describe your programs the way you ran them years ago. If your website needs accessibility work and a refresh anyway, a new build takes care of both at once.
If you want to check your own site first, I cover five of the biggest ones in Website Accessibility Basics for Small Businesses and Nonprofits.
How I can help your organization get ready
I build Squarespace websites for nonprofits, schools, and service businesses in New Hampshire and across the US, and I design every site with accessibility best practices from the first page. If the HHS deadline applies to you, here's where I can help:
Build a new Squarespace site. The Full Build gives you a new website with strategy, design, copywriting, and SEO, built with accessibility in mind from the first page. Learn more about nonprofit web design.
Move over from WordPress. If your site is on WordPress or another platform, I'll bring your content over to Squarespace and rebuild each page with the same accessibility care as a brand-new site.
Design with accessibility built in. Readable colors, clear headings, image descriptions, descriptive links, and forms that work with a keyboard are part of the design from the start. You can see how that came together for a Henniker prayer ministry in The Living Room case study.
Keep it accessible after launch. Once your new site is live, my monthly support plans cover updates and site checks, so new events, staff pages, and announcements go up the right way.
One honest note: I'm a web designer, not an attorney or an accessibility auditor. I can't certify that your organization meets Section 504, and no single website review can. What I can do is give you a new site designed and built with accessibility in mind, so you're in a much stronger position when the deadline arrives.
Frequently asked questions
Is the HHS website accessibility deadline still May 2026? No. In May 2026, HHS extended it to May 11, 2027 for organizations with 15 or more employees and May 10, 2028 for organizations with fewer than 15.
Does the rule apply to small nonprofits? If you receive HHS federal financial assistance, yes. Size only changes your deadline.
Does it cover PDFs? Yes. Documents you post on your website are web content. The rule has narrow exceptions for some older and archived documents, but anything new or still in active use should be accessible.
How do I know if my website is accessible? Free checkers like WAVE can flag common problems, such as low-contrast text and missing image descriptions. They only catch part of the picture, though. A professional audit tests what software can't, like keyboard use and screen reader behavior.
What about third-party tools like donation forms or registration systems? They count when you use them to provide your programs or services. It's worth asking your vendors whether their tools meet WCAG 2.1 AA.
What if we want to keep our current website? I'd recommend a professional accessibility audit. An auditor can test your site against WCAG 2.1 AA, document what needs fixing, and give you a record of your progress. I don't do audits or fixes on existing sites myself. If the list comes back long, or your site is due for a refresh anyway, that's where I can help: a new Squarespace site, or a move from WordPress, designed with accessibility in mind from the start.
Where should we start? Start with the pages people rely on most: your homepage, program and service pages, contact information, and any forms. Then work through PDFs and older content.
Let's talk about your website
May 2027 sounds far off, but a new website takes planning, and new content keeps piling up in the meantime. If a new site makes sense for your organization, let's talk. A discovery call is a relaxed conversation about your organization and your website, with no pressure to sign anything.
This article is general information about a federal rule, current as of November 2026. It isn't legal advice. Check with your attorney or funding agency about how Section 504 applies to your organization.
