Extension of Compliance Dates for Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities
4.20.2026 Justice Department
By this Interim Final Rule (“IFR”), the Department of Justice (“Department”) is revising the regulations implementing title II of the Americans with Disabilities Act (“ADA”) to extend the compliance dates for the requirements for web content and mobile application (“app”) accessibility that were adopted on April 24, 2024. The compliance date for State and local government entities with a total population of 50,000 or more is extended from April 24, 2026, to April 26, 2027. The compliance date for public entities with a total population of less than 50,000, or any special district government, is extended from April 26, 2027, to April 26, 2028.
By this Interim Final Rule (“IFR”), the Department of Justice (“Department”) is revising the regulations implementing title II of the Americans with Disabilities Act (“ADA”) to extend the compliance dates for the requirements for web content and mobile application (“app”) accessibility that were adopted on April 24, 2024. The compliance date for State and local government entities with a total population of 50,000 or more is extended from April 24, 2026, to April 26, 2027. The compliance date for public entities with a total population of less than 50,000, or any special district government, is extended from April 26, 2027, to April 26, 2028.
Ecommerce Accessibility by the Numbers
Don't just take our word for it...
1.3 billion people globally live with disabilities
That represents roughly 16% of the world’s population, making people with disabilities one of the largest underserved consumer groups globally. Be Accessible
28.7% of U.S. adults live with a disability
According to updated CDC data, more than one in four adults in the United States has a disability that may impact how they interact with digital platforms. Testparty.ai
$13 trillion in global disposable income
The disability community and their families represent an estimated $13 trillion in annual disposable income, often referred to as the “disability market.” Testparty.ai
$6.9 billion in annual ecommerce revenue is lost
U.S. ecommerce retailers lose billions each year to competitors with more accessible websites due to preventable accessibility barriers. Boia
$828 million lost during holiday shopping alone
Retailers are estimated to lose hundreds of millions during peak shopping seasons because inaccessible websites prevent customers from completing purchases. Forbes
71% of customers with disabilities leave inaccessible websites immediately
When users encounter accessibility barriers, most abandon the experience and take their business elsewhere. Commerce.fabrity
75% of consumers with disabilities have abandoned purchases due to accessibility barriers
Accessibility issues directly impact conversion rates and customer retention. Testparty.ai
Nearly 70% of accessibility lawsuits target ecommerce businesses
Ecommerce remains one of the most legally vulnerable industries for digital accessibility litigation. Raleigh News
5,114 ADA digital accessibility lawsuits were filed in 2025
Legal pressure continues to increase as accessibility enforcement expands. Be Accessible
97% of websites still fail basic accessibility standards
Most organizations remain reactive instead of proactive, creating both risk and opportunity for companies willing to lead. TechRadar
That represents roughly 16% of the world’s population, making people with disabilities one of the largest underserved consumer groups globally. Be Accessible
28.7% of U.S. adults live with a disability
According to updated CDC data, more than one in four adults in the United States has a disability that may impact how they interact with digital platforms. Testparty.ai
$13 trillion in global disposable income
The disability community and their families represent an estimated $13 trillion in annual disposable income, often referred to as the “disability market.” Testparty.ai
$6.9 billion in annual ecommerce revenue is lost
U.S. ecommerce retailers lose billions each year to competitors with more accessible websites due to preventable accessibility barriers. Boia
$828 million lost during holiday shopping alone
Retailers are estimated to lose hundreds of millions during peak shopping seasons because inaccessible websites prevent customers from completing purchases. Forbes
71% of customers with disabilities leave inaccessible websites immediately
When users encounter accessibility barriers, most abandon the experience and take their business elsewhere. Commerce.fabrity
75% of consumers with disabilities have abandoned purchases due to accessibility barriers
Accessibility issues directly impact conversion rates and customer retention. Testparty.ai
Nearly 70% of accessibility lawsuits target ecommerce businesses
Ecommerce remains one of the most legally vulnerable industries for digital accessibility litigation. Raleigh News
5,114 ADA digital accessibility lawsuits were filed in 2025
Legal pressure continues to increase as accessibility enforcement expands. Be Accessible
97% of websites still fail basic accessibility standards
Most organizations remain reactive instead of proactive, creating both risk and opportunity for companies willing to lead. TechRadar
What is a Certified Trusted Tester?
The Department of Homeland Security (DHS) Trusted Tester Certification is one of the most rigorous manual accessibility testing certifications in the United States. The methodology aligns with the federal government’s Information and Communication Technology (ICT) Testing Baseline and is designed to produce consistent, repeatable, and defensible accessibility test results.
A Certified Trusted Tester is trained to manually evaluate websites, web applications, and digital content against Revised Section 508 standards using approved testing methodologies and tools. Unlike automated scans that can only detect a portion of accessibility issues, Trusted Testers identify complex usability and compliance barriers that require human evaluation.
To earn certification, testers must successfully complete the DHS Trusted Tester training program and pass a comprehensive certification exam demonstrating their ability to deliver accurate and repeatable conformance results.
For organizations, this means your accessibility audit is conducted using a recognized federal-standard methodology that provides clear documentation, credible findings, and actionable remediation guidance.
A Certified Trusted Tester is trained to manually evaluate websites, web applications, and digital content against Revised Section 508 standards using approved testing methodologies and tools. Unlike automated scans that can only detect a portion of accessibility issues, Trusted Testers identify complex usability and compliance barriers that require human evaluation.
To earn certification, testers must successfully complete the DHS Trusted Tester training program and pass a comprehensive certification exam demonstrating their ability to deliver accurate and repeatable conformance results.
For organizations, this means your accessibility audit is conducted using a recognized federal-standard methodology that provides clear documentation, credible findings, and actionable remediation guidance.
What does WCAG stand for?
Web Content Accessibility Guidelines (WCAG) are the internationally recognized standards for making websites, applications, and digital content accessible to people with disabilities.
These guidelines help ensure digital experiences are usable for individuals with a wide range of disabilities, including:
WCAG standards also improve usability for older adults experiencing age-related changes and often create better digital experiences for all users.
Today, most organizations strive to meet WCAG 2.1 AA standards, while many are beginning to prepare for evolving requirements under WCAG 2.2 and global regulations such as the European Accessibility Act.
At Mozaro, we help organizations move beyond technical compliance by creating digital experiences that are both accessible and usable for everyone.
These guidelines help ensure digital experiences are usable for individuals with a wide range of disabilities, including:
- Visual disabilities
- Hearing disabilities
- Mobility limitations
- Speech disabilities
- Cognitive and learning disabilities
- Neurological disabilities
WCAG standards also improve usability for older adults experiencing age-related changes and often create better digital experiences for all users.
Today, most organizations strive to meet WCAG 2.1 AA standards, while many are beginning to prepare for evolving requirements under WCAG 2.2 and global regulations such as the European Accessibility Act.
At Mozaro, we help organizations move beyond technical compliance by creating digital experiences that are both accessible and usable for everyone.
What's the difference between A, AA, AAA levels of compliance?
World Wide Web Consortium’s Web Content Accessibility Guidelines (WCAG) define three levels of accessibility conformance: A, AA, and AAA.
This is the most basic level of accessibility and addresses critical barriers that may prevent users with disabilities from accessing content altogether.
Examples may include:
Meeting only Level A does not provide broad accessibility coverage and often leaves significant usability barriers in place.
Level AA is the most commonly required and widely adopted standard for businesses, government entities, educational institutions, and organizations seeking legal compliance.
It builds on Level A requirements and
addresses more comprehensive accessibility issues such as:
Most organizations target WCAG 2.1 AA conformance, as it aligns with many legal expectations and provides meaningful accessibility for a broader range of users.
Level AAA represents the highest level of accessibility and includes enhanced requirements that create an exceptional user experience for some users with disabilities.
Examples may include:
While AAA is ideal in certain situations, World Wide Web Consortium does not recommend it as a requirement for entire websites because many AAA criteria are not realistic for all types of content.
A = Minimum accessibility
AA = The standard most organizations should achieve
AAA = Exceptional accessibility enhancements where appropriate
At Mozaro, we help organizations prioritize practical compliance strategies that reduce risk while creating stronger digital experiences for all users.
Level A (Minimum Compliance)
This is the most basic level of accessibility and addresses critical barriers that may prevent users with disabilities from accessing content altogether.Examples may include:
- Missing alternative text for images
- Keyboard navigation barriers
- Missing form labels
- Basic screen reader issues
Meeting only Level A does not provide broad accessibility coverage and often leaves significant usability barriers in place.
Level AA (Industry Standard)
Level AA is the most commonly required and widely adopted standard for businesses, government entities, educational institutions, and organizations seeking legal compliance.It builds on Level A requirements and
addresses more comprehensive accessibility issues such as:
- Color contrast requirements
- Resizable text
- Consistent navigation
- Error identification
- Improved readability and usability
Most organizations target WCAG 2.1 AA conformance, as it aligns with many legal expectations and provides meaningful accessibility for a broader range of users.
Level AAA (Highest Standard)
Level AAA represents the highest level of accessibility and includes enhanced requirements that create an exceptional user experience for some users with disabilities.Examples may include:
- Sign language interpretation for video content
- Higher contrast requirements
- Enhanced reading support
While AAA is ideal in certain situations, World Wide Web Consortium does not recommend it as a requirement for entire websites because many AAA criteria are not realistic for all types of content.
In Simple Terms:
A = Minimum accessibility
AA = The standard most organizations should achieve
AAA = Exceptional accessibility enhancements where appropriate
At Mozaro, we help organizations prioritize practical compliance strategies that reduce risk while creating stronger digital experiences for all users.
Do Automated WCAG Testing Solutions Work?
While software solutions are useful for binary testing, even the best platforms available can only detect up to 30% of WCAG issues. While these solutions help catch the low hanging fruit, such as broken links and missing alt tags, manual human WCAG testing is required to ensure your website is actually compliant.
For example, there are 60 testing parameters required for WCAG testing. Of those 60 tests, 46 of these tests (76%) require manual inspection of the page.
Additionally, automated programs have difficulty with:
For example, there are 60 testing parameters required for WCAG testing. Of those 60 tests, 46 of these tests (76%) require manual inspection of the page.
Additionally, automated programs have difficulty with:
- Color Contrast: While many platforms can check for color contrast ratios, however, they are not able to consistently provide accurate results.
- Links: Even though your website links have been coding properly, manual testing is required to make sure any links you have to external websites or digital assets are accessible as well.
- Keyboard Focus: This is a huge issue for automated testing software. Visitors that rely on the keyboard to navigate a website need to know where their cursor is on the page - or where the keyboard focus is. This can only be accomplished through manual testing.
- Improper Labels: Automated software can determine if there are labels associated with each element of your site, however, it cannot determine if the label serves it's purpose.
- Alt Text: Again, automated software can determine if alt text has been added to all images on your site, however, it cannot determine if the alt text is appropriate or adequately describes the image.
Can you get sued for having an inaccessible website?
Yes.
Website accessibility lawsuits continue to rise as organizations face increased scrutiny under the Americans with Disabilities Act, Section 508 requirements, and evolving global regulations such as the European Accessibility Act.
Organizations across industries, particularly ecommerce, healthcare, education, hospitality, and financial services, have faced legal action due to inaccessible websites, mobile applications, and digital documents.
That said, at Mozaro, we do not believe accessibility should be driven solely by fear of litigation.
We believe accessibility is about creating equal access to information, services, and opportunities for everyone while also strengthening your business.
An accessible digital experience helps organizations:
Compliance may be what gets leadership’s attention. Inclusion is what creates long-term value.
Website accessibility lawsuits continue to rise as organizations face increased scrutiny under the Americans with Disabilities Act, Section 508 requirements, and evolving global regulations such as the European Accessibility Act.
Organizations across industries, particularly ecommerce, healthcare, education, hospitality, and financial services, have faced legal action due to inaccessible websites, mobile applications, and digital documents.
That said, at Mozaro, we do not believe accessibility should be driven solely by fear of litigation.
We believe accessibility is about creating equal access to information, services, and opportunities for everyone while also strengthening your business.
An accessible digital experience helps organizations:
- Expand their customer base
- Reduce legal risk
- Improve usability for all users
- Strengthen brand trust
- Create more inclusive customer experiences
Compliance may be what gets leadership’s attention. Inclusion is what creates long-term value.
Does making my website accessible really matter?
Yes. More than most organizations realize.
Over 70 million U.S. adults live with a disability, according to the Centers for Disease Control and Prevention. Globally, more than 1.3 billion people, or roughly 16% of the world’s population, live with some form of disability according to the World Health Organization.
That represents a massive audience that may be unintentionally excluded when websites, applications, and digital documents are not accessible.
Accessibility matters because it directly impacts:
An accessible website ensures more people can engage with your products, services, and content without barriers.
At Mozaro, we believe accessibility is not about checking a compliance box. It’s about building digital experiences that work for everyone and positioning your organization for long-term growth.
Over 70 million U.S. adults live with a disability, according to the Centers for Disease Control and Prevention. Globally, more than 1.3 billion people, or roughly 16% of the world’s population, live with some form of disability according to the World Health Organization.
That represents a massive audience that may be unintentionally excluded when websites, applications, and digital documents are not accessible.
Accessibility matters because it directly impacts:
- Customer reach
- Revenue opportunities
- Brand reputation
- Legal compliance
- User experience
An accessible website ensures more people can engage with your products, services, and content without barriers.
At Mozaro, we believe accessibility is not about checking a compliance box. It’s about building digital experiences that work for everyone and positioning your organization for long-term growth.