Skip to main content

Preparing for the 2026 accessibility deadlines: HHS, DOJ Title II, and the EAA, ten months in

Sergi Sánchez Mancha

The accessibility regulation map shifted twice this month. If you're responsible for a digital product, the practical takeaway is the same in both directions: regulators care less about intent and more about evidence than they did a year ago.

Here's what actually changed and what to do about it before May.

What just happened

DOJ Title II — extended by one year (April 20, 2026)

On April 20, 2026, four days before the original compliance deadline, the Department of Justice published an interim final rule extending the ADA Title II web accessibility deadlines by twelve months. State and local governments now have until 2027 (large entities) or 2028 (small entities) to comply with WCAG 2.1 Level AA for their websites and mobile apps.

The interim rule is effective immediately. DOJ is accepting public comments through June 22, 2026.

This is a real reprieve, but a narrow one. It applies to public entities under Title II. It does not move:

HHS Section 504 — May 2026 deadline still stands

Healthcare providers receiving federal financial assistance are still on the hook for the HHS Section 504 deadline in May 2026. HHS did not extend. If you build for, with, or alongside a covered healthcare entity, your May calendar already has a date on it.

European Accessibility Act — ten months into enforcement

The EAA has been enforceable across the EU since June 28, 2025. Ten months in, the picture is clearer:

  • France can fine up to €250,000 per violation.
  • Spain can fine up to €600,000 per violation.
  • Several member states allow individuals to initiate civil proceedings directly.
  • Enforcement is uneven — but it is happening.

The interesting trend is not the fines (which are still rare publicly). It is the procurement effect: large EU buyers are asking suppliers for accessibility evidence as part of standard vendor onboarding, well outside the formal enforcement channel.

WCAG 3.0 — first working draft

The W3C published a new WCAG 3.0 Working Draft on March 3, 2026 introducing 174 new outcomes. It will not finalise until 2028 at the earliest, but the direction is set: outcomes, not just success criteria.

This is not a deadline. It is a signal about what the next decade of accessibility regulation will measure.

What regulators and procurement teams actually ask for

After spending the last year talking to compliance leads, in-house counsel, and procurement officers across these frameworks, the questions are remarkably consistent:

  1. Which WCAG version and level do you target? (Usually 2.2 AA in 2026; 2.1 AA accepted in older contracts.)
  2. What evidence can you produce that you meet it? (Not a policy. An artefact.)
  3. When was that evidence last refreshed? (A year-old VPAT is suspect.)
  4. How do you handle issues found between audits? (This is the question that breaks most teams.)

That last question is where the framing has changed. A static VPAT from your last audit answers questions 1–3. It does not answer question 4. Buyers and regulators are increasingly asking for evidence of continuous compliance, not point-in-time conformance.

What "evidence" looks like in 2026

The bar moved. Here is what holds up under serious scrutiny:

  • Per-criterion conformance status. For each WCAG criterion you claim to support, evidence of how you verify it.
  • Issue history. Findings raised, who raised them, when, and what happened next.
  • Fix verification. Proof that fixes actually resolved the underlying issue, not just that someone marked a ticket "done".
  • Reviewer identity and timing. Who reviewed each finding and when.
  • Mapping to legal frameworks. Findings linked to WCAG 2.2 criteria, with cross-references to EAA, ADA Section 508, EN 301 549.

A spreadsheet can do this. A chat transcript cannot.

A practical checklist for the next ten weeks

If you are scrambling toward a May deadline (HHS) or quietly behind on EAA evidence, here is the order to do things:

  1. Identify which framework actually applies. Don't generalise. HHS Section 504, ADA Title II, ADA Title III, EAA, EN 301 549, UK Equality Act — they overlap but are not identical.
  2. Inventory your digital surface. Public websites, internal tools, customer apps, vendor integrations. Most teams underestimate this by 2–3×.
  3. Pick a target. WCAG 2.2 AA is the safe default for new work in 2026. AAA is rarely required but worth aspiring to for healthcare and public services.
  4. Run a baseline scan. Anything is better than nothing — axe-core, WAVE, Lighthouse, your AI coding tool of choice. The output is a list of known gaps, not a clean bill of health.
  5. Stand up a tracking system. Findings, owners, timestamps, fix verification. This is the part most teams skip and the part that makes the rest defensible.
  6. Refresh quarterly, not annually. Auditors and procurement are increasingly suspicious of evidence older than 6–12 months.

Where Jeikin fits

Jeikin is the enforcement layer in this picture. It is not a scanner — it is the system that turns scans, AI-found issues, and human reviews into a continuous, timestamped record of compliance work, mapped to WCAG 2.2 and exportable for EAA, ADA Section 508, and EN 301 549 audits.

If your team is using Claude Code, Cursor, or Windsurf, Jeikin runs inside those tools so the evidence accumulates as a side-effect of normal development, not as a separate compliance project. Compliance teams get a dashboard view of progress and risk per project.

Free during beta, up to 3 projects per account. Most teams need one.

The shift, in one line

A year ago, "we follow WCAG" was a credible answer. In 2026, the credible answer is "here is the evidence". Build the system that produces it.

Deadlines move. Evidence requirements don't go backwards. The teams setting up tracking now will spend May making fixes; the teams that wait will spend May making spreadsheets.