Section 504
Take HHS funding? You have an accessibility deadline too.
Most coverage of the accessibility rules talks about city and county government. Section 504 reaches a different group entirely: anyone who receives federal financial assistance from the Department of Health and Human Services. Hospitals, clinics, community health centers, county health and human services departments, long-term care, medical schools, and a great many nonprofits.
Your deadline is set by headcount, not population
This is the detail that catches people out. The ADA Title II rule that gets most of the attention bands organizations by the population they serve. Section 504 does not. It bands them by how many people they employ, and the dates are different.
- 15 or more employees: your websites and mobile applications must conform by May 11, 2027.
- Fewer than 15 employees: the date is May 10, 2028.
The standard is WCAG 2.1 Level AA, the same technical target the Department of Justice set for public entities. A11y Audit evaluates against WCAG 2.2 Level AA, which is deliberately stricter, so meeting our bar clears the one the regulation actually asks for.
Both the Section 504 rule and the ADA Title II rule were extended by one year by interim final rules issued in 2026. Dates can move again, and we track them so your countdown reflects the rule in force rather than the one that was in force when you signed up.
You may be under both rules, and the earlier one wins
A county health department is a public entity under Title II and a recipient of federal health funding under Section 504. So is a public hospital authority. When both apply, the obligation that binds you is simply whichever date arrives first, and that is not always the one you would guess.
A town of forty thousand people has until April 2028 under Title II. If that same town's health department takes HHS money and employs fifteen people, Section 504 binds it in May 2027, almost a year earlier. Reading only the Title II coverage would leave it eleven months behind before anyone noticed.
A11y Audit asks which rules apply to you when you set up, then tracks your estate against the date that actually binds rather than the one that is easiest to find online.
What conformance actually requires
More than a clean automated scan. These are the parts an OCR complaint or a procurement review will reach for.
Your website and your documents
Patient forms, notices of privacy practices, board minutes, and benefit letters are usually PDFs, and PDFs are where accessibility programs quietly fail. A11y Audit scans pages and documents together rather than treating documents as someone else's problem.
The checks a machine cannot make
Automated testing cannot decide whether alternative text is meaningful or whether a reading order makes sense. Those criteria are flagged for human review and are never recorded as passing on an automated result.
Evidence you can hand to OCR
Signed, tamper-evident conformance records and a per-criterion rollup, so that if the Office for Civil Rights asks what you evaluated and when, the answer is a document rather than a recollection.
A route for people to report barriers
A public grievance form, with submissions tracked, classified, and answerable. Being reachable by someone your service excluded is part of the obligation, not a nicety.
Section 504 questions
We're a private nonprofit. Does this really apply to us?
If you receive federal financial assistance from HHS, yes. Section 504 attaches to the funding rather than to whether you are a government body. Community health centers, nonprofit clinics, long-term care providers, and many social service organizations are covered precisely because of the funding they accept.
How do we count employees for the threshold?
The band is set by employee count rather than revenue, budget, or population served. If you are near fifteen, treat the earlier date as yours, because being wrong in that direction costs you eleven months of runway rather than a conversation.
What if we also fall under ADA Title II?
Then both apply and the earlier deadline governs. A11y Audit records which rules apply to you and counts down to the one that binds, rather than assuming the Title II date everyone talks about is the relevant one.
Is WCAG 2.1 AA or 2.2 AA the target?
The regulation names WCAG 2.1 Level AA. We evaluate against 2.2 Level AA, which adds criteria rather than removing them, so conformance on our measure clears the regulatory one with margin. Our WCAG coverage page lists exactly which criteria are evaluated automatically and which need dedicated manual testing.
We have no accessibility specialist on staff. Is this usable?
That is who it is built for. The platform crawls your estate, runs what can be automated, and then walks a non-specialist through the judgement calls one at a time, recording the determination and who made it as it goes.
Find out where you stand
Point A11y Audit at your site and it will crawl your pages and documents and show you what conformance looks like from here — before you commit to anything.