Federal funding exposure
Recipients of federal financial assistance face audit, corrective-action plans, and potential suspension of funds for noncompliance with accessibility provisions attached to HHS, DOJ, and CMS programs.
Federal compliance · Public-sector entities
See where your website may be exposed — and what it takes to become compliant.
AccessMark is a four-phase methodology — audit, remediation, certification, continuous monitoring — for federal digital accessibility requirements under ADA Title II, HHS Section 504, HIPAA, and CMS Price Transparency.
Operational risk
Five reasons digital accessibility is a federal compliance matter.
DOJ enforcement deadlines
State and local government entities subject to ADA Title II must meet WCAG 2.1 AA for web and mobile content under 28 CFR §35.200, with compliance dates recently amended by DOJ Interim Final Rule (April 2026).
Procurement friction
Federal and state procurement processes increasingly require accessibility attestations from vendors. Noncompliance translates into disqualification from bids, contract delays, and renegotiation costs.
OCR complaint liability
HHS Office for Civil Rights investigates Section 504 complaints through compliance reviews. Resolutions typically require corrective-action plans, documented remediation, and ongoing monitoring.
Compliance decay
A one-time audit does not sustain compliance. Content changes daily; WCAG conformance drifts within weeks. Sustained conformance requires continuous monitoring — the same principle applied to financial controls.
Federal compliance dates
Three regulatory dates on the current horizon.
These are the compliance dates currently in effect. Dates are subject to regulatory amendment; sources are cited alongside each entry.
May 11, 2026
HHS Section 504
45 CFR Part 84 · §84.85(c)
Recipients of HHS financial assistance with 15 or more employees must meet WCAG 2.1 AA for web content and mobile applications. Applies to hospitals, health plans, federally qualified health centers, and related entities.
⚠ Status: An HHS Interim Final Rule (RIN 0945-AA30) is under OIRA review as of April 17, 2026, and may amend this date.
April 26, 2027
ADA Title II — Large entities
28 CFR §35.200(b)(1)
State and local government entities with total population of 50,000 or more must meet WCAG 2.1 AA for web content and mobile applications.
Source: DOJ Interim Final Rule, 91 FR 20902, effective April 20, 2026.
April 26, 2028
ADA Title II — Small entities
28 CFR §35.200(b)(2)
Public entities with total population under 50,000, and any special district government, must meet WCAG 2.1 AA for web content and mobile applications.
Source: DOJ Interim Final Rule, 91 FR 20902, effective April 20, 2026.
Methodology
Four phases. One compliance record.
AccessMark structures compliance work into four defined phases, each producing a citation-grounded deliverable that documents conformance against the applicable federal rule.
01
Audit
WCAG 2.1 AA conformance review of web content and mobile applications, mapped to the applicable regulatory sections. Deliverable: a technical findings report with severity ratings and CFR-level citations.
02
Remediation
Prioritized correction of findings, coordinated with the entity's in-house or contracted development resources. Deliverable: a remediation log and retested conformance status.
03
Certification
Issuance of an AccessMark certification letter documenting the scope, standard, and conformance status. Twelve-month validity, annual renewal tied to continuous monitoring.
04
Continuous monitoring
Ongoing conformance surveillance across covered properties, with scheduled re-audits and change-triggered rechecks. Deliverable: a compliance record updated throughout the certification term.
Frequently asked
Common questions about federal accessibility compliance.
Who is subject to these rules?
ADA Title II covers state and local government entities. HHS Section 504 covers recipients of HHS financial assistance — including hospitals, health plans, and federally qualified health centers — with 15 or more employees for the first deadline. CMS Price Transparency applies to hospitals offering services paid under Medicare.
What technical standard must we meet?
WCAG 2.1 Level AA is the technical standard incorporated by both the DOJ ADA Title II rule (28 CFR §35.200) and the HHS Section 504 rule (45 CFR Part 84). The 2018 version is the one referenced by regulation.
What does an AccessMark certification prove?
It documents that the covered digital properties were reviewed against WCAG 2.1 AA and the applicable CFR section, that findings were remediated, and that the entity is under a continuous-monitoring arrangement. It is a compliance record, not a legal opinion.
How long does a typical engagement take?
Audit phase runs four to six weeks depending on site scope. Remediation is scoped to the findings and the entity's development capacity. Certification is issued upon retest; continuous monitoring begins immediately after.
Engagement
Talk to AccessMark about certification.
Tell us about your organization, the properties in scope, and the regulatory deadline you are working against. We respond within two business days.