Targeted outreach playbook

The Justice Department pushed back its web-accessibility deadline for public colleges by a year, but the Health and Human Services deadline many campuses also face did not move. (federalregister.gov) (ecfr.gov) The original Justice Department rule, published on April 24, 2024, required state and local governments to make web content and mobile apps meet Web Content Accessibility Guidelines, or WCAG, 2.1 Level AA by April 24, 2026, for entities serving 50,000 or more people. Smaller public entities and special district governments were set for April 26, 2027. (federalregister.gov) (w3.org) An interim final rule published on April 20, 2026, moved those Justice Department dates to April 26, 2027, for larger entities and April 26, 2028, for smaller ones. The rule took effect immediately and accepts public comments through June 22, 2026. (federalregister.gov) (regulations.gov) The split matters for higher education because public colleges can fall under both legal tracks at once: Title II of the Americans with Disabilities Act as government entities, and Section 504 of the Rehabilitation Act if they receive Health and Human Services funding. Jackson Lewis said the HHS deadline still “looms” for covered recipients. (federalregister.gov) (jacksonlewis.com) Under the HHS rule, recipients with 15 or more employees must make covered web content and mobile apps conform to WCAG 2.1 Level A and AA beginning May 11, 2026. Recipients with fewer than 15 employees have until May 10, 2027. (ecfr.gov) (w3.org) That creates a messaging problem for vendors and consultants selling accessibility software to colleges. A campus accessibility office may care most about WCAG governance, audits, and policy controls, while a finance or operations team may respond more to labor savings from fixing templates, monitoring content, and reducing manual remediation work. (jacksonlewis.com) (w3.org) The underlying standard is technical but familiar in practice: text alternatives for images, keyboard access, readable contrast, captions, and predictable navigation. The Justice Department and HHS both wrote WCAG 2.1 into their rules, which gives colleges one benchmark even when their legal deadlines differ. (w3.org) (federalregister.gov) (ecfr.gov) Disability advocates criticized the Justice Department delay. Inside Higher Ed reported that advocates called the move “unconscionable” after many institutions had spent months preparing for the April 2026 date. (insidehighered.com) For colleges and the companies pitching them, the practical line is narrower than the new federal calendar suggests: a delayed Justice Department date does not erase the May 11, 2026, HHS deadline for covered recipients. That keeps accessibility spending in the category of compliance infrastructure, not a discretionary website upgrade. (ecfr.gov) (jacksonlewis.com)