WCAG 2.1 (Web Content Accessibility Guidelines, version 2.1) is the technical standard cited by federal regulators. Level AA is the middle conformance tier — it's the bar set by ADA Title II (28 CFR §35.200), HHS Section 504 (45 CFR §84.84), and Section 508. It covers keyboard operability, screen-reader compatibility, color contrast ratios (4.5:1 for normal text), captioning for video, resizable text, and consistent navigation. It applies to websites, mobile apps, PDFs, and any digital content a public entity makes available.

Only the compliance date — not the obligations. Under 28 CFR §35.200(b)(1), large public entities (50,000+ residents) now have until April 24, 2027; under §35.200(b)(2), smaller entities and special districts have until April 26, 2028. WCAG 2.1 AA remains the standard. The extension does NOT apply to HHS Section 504 deadlines (still May 11, 2026), CMS Price Transparency, HIPAA, or ADA Title III private-sector obligations. Think of it as 12 additional months to execute, not 12 months to postpone starting.

Automated scans across every public-facing domain, plus expert manual review covering keyboard navigation, screen-reader behavior (NVDA/JAWS/VoiceOver), focus management, color contrast, form labeling, ARIA use, and document structure (PDFs, forms, embedded widgets). Deliverables: a severity-ranked scorecard cited to federal regulatory code (28 CFR, 45 CFR, WCAG success criteria), a prioritized remediation roadmap, and a bilingual executive summary suitable for procurement and board review. Re-test is included after remediation to support certification.

A typical municipal or hospital website runs 6–10 weeks per domain. Add 8–12 weeks if PDFs, intake forms, patient portals, or third-party widgets (payment, scheduling, formularies) are in scope. Organizations with multiple domains, Spanish-language parallel content, or legacy CMS platforms should budget 4–6 months end-to-end, including audit, remediation, verification, and procurement-ready certification packaging. Starting in Q1 of the deadline year leaves no margin for retest.

OCR and DOJ complaints become actionable the day after the deadline passes. A single complaint triggers mandatory investigation, corrective-action documentation, and a public-facing resolution. For HHS fund recipients, noncompliance under Section 504 (45 CFR Part 84) puts Medicaid, CMS, and grant funding at risk. For procurement, inaccessible digital assets block federal contract eligibility and vendor qualification. There is no grace period once a deadline has passed — the regulatory posture flips from 'must comply by X' to 'currently in violation'.

Yes. ADA Title II (28 CFR §35.200) and HHS Section 504 (45 CFR §84.84) both extend to mobile applications, PDF documents, online forms, and any digital content made available by a covered entity. PDFs used for official notices, ordinances, price transparency files, benefit enrollment, and patient intake are in scope and must be tagged for screen readers. Native mobile apps (iOS and Android) must meet WCAG 2.1 AA equivalent standards through accessible UI components, proper labels, and system-level assistive technology support.

Jurisdiction and enforcement authority. ADA Title II covers all state and local government public entities (28 CFR §35.200) regardless of federal funding — DOJ is the enforcement authority. Section 504 of the Rehabilitation Act (45 CFR Part 84, §84.84) covers any recipient of HHS funds — hospitals, health plans, public universities, research institutions — and is enforced by HHS OCR. Many organizations are covered by both simultaneously; for example, a Puerto Rico public hospital receiving Medicaid must meet Title II (by April 24, 2027) AND Section 504 (by May 11, 2026, whichever comes first).

The covered entity — your municipality, hospital, or agency — is legally responsible for conformance under 28 CFR §35.200 and 45 CFR §84.84, regardless of who built or hosts the digital asset. That said, procurement practice typically requires vendors to deliver WCAG 2.1 AA conformant work product and to remediate violations at no additional cost. AccessMark's audit deliverables are designed to plug directly into vendor remediation orders and federal procurement documentation (VPAT/ACR), so you can hold vendors accountable with regulator-ready evidence.