How to Meet the 2026 Accessibility Deadline: Step-by-Step Guide

With less than two years to prepare, healthcare leaders must act now. This guide covers what the ruling requires, who it affects, and how to meet the deadline while improving digital accessibility.

New HHS Ruling Brings Clearer Accessibility Standards

Until now, U.S. healthcare organizations were in a gray area regarding digital accessibility. While laws like the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act prohibit discrimination against individuals with disabilities, they haven’t always provided clear-cut digital accessibility standards.

The new HHS ruling changes that by explicitly requiring compliance with WCAG 2.1 AA, a widely accepted set of web accessibility guidelines. Organizations that fail to meet these standards could face lawsuits, government enforcement actions, and loss of public trust.

This ruling doesn’t just apply to public hospitals and healthcare clinics—it also extends to any U.S. organization receiving federal financial assistance, including those participating in Medicare, Medicaid, and CHIP. If your organization falls into this category, accessibility compliance is no longer optional.

What is WCAG 2.1 Level AA?

The Web Content Accessibility Guidelines (WCAG) are designed to ensure that websites and digital content are usable for people with disabilities, including those with vision, hearing, mobility, and cognitive impairments. 2.1 refers to the version (note, the newest version is actually 2.2, but the HHS ruling states version 2.1).

The guidelines focus on four core principles:

• Perceivable: Content must be available in multiple formats so all users can access it. This includes providing alt text for images, captions for videos, and adaptable layouts.

• Operable: Websites and apps must be easy to navigate, including by keyboard alone. Features that could trigger seizures, such as flashing images, must also be avoided.

• Understandable: Content should be clear and predictable. This means using plain language, providing error messages on forms, and ensuring consistent navigation.

• Robust: Digital content must be compatible with assistive technologies like screen readers and be built with proper coding practices to remain accessible as technology evolves.

WCAG compliance is measured at three levels: A, AA, and AAA. The HHS ruling requires organizations to meet the AA level, which includes critical accessibility features like live video captions and resizable text.

Does This Apply to Your Organization?

If your organization participates in Medicaid, Medicare, or CHIP, your digital platforms must meet WCAG 2.1 AA standards.

It’s also important to note that this applies to more than just your website. Patient portals, mobile apps, online appointment scheduling tools, and any other digital touchpoints must be fully accessible. While marketers may not always have direct control over EHR systems and apps, ensuring accessibility across all digital experiences is critical for patient satisfaction and compliance.

Even if your organization isn’t directly impacted by this ruling, aligning with WCAG 2.1 (better yet, 2.2) AA is still a smart move. Digital accessibility lawsuits against U.S. healthcare organizations are increasing, with the ADA frequently cited in these claims. By proactively addressing accessibility, you not only reduce legal risk but also ensure that all patients can easily access your services.

Beyond compliance, accessibility is simply the right thing to do. An inclusive website doesn’t just prevent barriers, it expands your reach. The more people who can navigate your site, the more patients you can serve, improving engagement, trust, and overall patient experience.

Legal Action

Non-compliance with WCAG 2.1 AA can lead to lawsuits under the ADA and Section 504 of the Rehabilitation Act. Several U.S. healthcare organizations have already faced legal challenges over inaccessible websites, and with this new ruling in place, enforcement is expected to increase.

Financial Penalties

Legal fees, settlements, and remediation costs can add up quickly. Many U.S. healthcare organizations that have faced lawsuits were required not only to update their digital platforms but also to pay financial damages.

Reputational Damage

Accessibility isn’t just a legal requirement—it’s a matter of patient trust. If your U.S. organization is publicly cited for lacking an inclusive digital experience, it could damage your reputation and deter patients from seeking care.

How to Prepare for the HHS 2026 Accessibility Deadline

The May 2026 deadline may seem far off, but achieving WCAG 2.1 AA compliance takes time. Healthcare organizations should start now to avoid last-minute challenges and serve patients better.

Failure to meet these new accessibility standards can result in serious consequences for healthcare organizations.

1. Conduct a Website and App Accessibility Audit

The first step is to assess your current level of accessibility. Start with an accessibility audit. Tools like Lighthouse and Total Validator catch basic issues, but manual testing by experts is essential for full compliance.

Remember to test your third-party tools like chatbots and other virtual assistants, too.

2. Make Necessary Updates to Your Digital Platforms

Based on your audit results, you’ll need to update your website and mobile apps to meet WCAG 2.1 AA standards. This may involve:

• Adding alt text for images

• Ensuring keyboard-friendly navigation

• Implementing closed captions and transcripts for video content

• Improving color contrast for readability

• Fixing underlying code to support screen readers and other assistive technologies

For a deeper dive into accessible best practices for healthcare websites, check out our guide on creating inclusive digital experiences.

3. Train Your Team on Accessibility Best Practices

Accessibility isn’t a one-time project—it requires ongoing effort. Your content and development teams should be trained on how to create and maintain accessible content, ensuring compliance long after initial updates are made.

Consider appointing an accessibility lead within your organization who is responsible for overseeing compliance efforts and responding to any issues that arise.

4. Implement Ongoing Monitoring and Testing

Websites and digital platforms evolve over time, and accessibility issues can emerge as new content is added. To stay compliant, establish a regular monitoring and testing process.

Consider using tools like Lighthouse, axe DevTools, or WAVE to spot accessibility issues early. Pair automated testing with manual reviews for best results.

Why Acting Now is Critical

With clear enforcement guidelines and a firm deadline in place, healthcare organizations can no longer afford to delay digital accessibility efforts. Waiting until the last minute could result in rushed compliance work, increased costs, and greater legal exposure.

Beyond avoiding penalties, improving accessibility enhances the patient experience, expands your reach, and demonstrates a commitment to inclusivity. Making digital healthcare services accessible benefits everyone—especially the millions of patients who rely on assistive technologies to navigate online content.

If your organization needs help evaluating accessibility compliance and preparing for the May 2026 deadline, now is the time to start. Taking a proactive approach will ensure you meet the new requirements while improving the overall usability of your digital platforms.

It's also important to note that accessibility can't be "added on" with an overlay—these tools often create more barriers rather than solving underlying issues. True accessibility requires structural improvements and adherence to WCAG guidelines from the ground up. For a detailed look at the problems with overlays and why they fall short, check out this resource on the risks of overlay solutions.

Ready to build a more accessible website? Our team can help you meet WCAG 2.1 AA standards and improve the patient experience.

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