ADA Title II: WCAG 2.1 AA for online courses by April 26, 2027
The dates, where legacy courses fail, and a plan for a whole library.
Last reviewed
US state and local governments must make their web content — online courses included — meet WCAG 2.1 AA by April 26, 2027 if they serve 50,000 people or more, and by April 26, 2028 otherwise. HHS’s Section 504 rule sets May 11, 2027 for organizations it funds with 15 or more employees, and May 10, 2028 for smaller ones.
Legacy courses from Captivate, Storyline and Flash-era tools rarely pass, and many of their failures come from the player itself, so the practical fix is to migrate the content, not patch the package.
- ADA Title II web rule: WCAG 2.1 AA by 2027-04-26 for state and local governments serving 50,000 people or more.
- ADA Title II web rule: WCAG 2.1 AA by 2028-04-26 for smaller governments and special districts.
- HHS Section 504 rule, as extended by HHS's May 2026 interim final rule: WCAG 2.1 AA by 2027-05-11 for recipients of HHS funding with 15 or more employees, and by 2028-05-10 for those with fewer than 15.
- Online courses delivered through an LMS are web content under these rules.
The deadlines
| Rule | Who | WCAG 2.1 AA by |
|---|---|---|
| ADA Title II web rule | State and local governments serving 50,000 people or more | April 26, 2027 |
| ADA Title II web rule | Smaller governments and special districts | April 26, 2028 |
| HHS Section 504 rule | Recipients of HHS funding with 15 or more employees | May 11, 2027 |
| HHS Section 504 rule | Recipients of HHS funding with fewer than 15 employees | May 10, 2028 |
The ADA dates are from the Justice Department’s 2024 final rule as extended by one year in its interim final rule of 20 April 2026; both keep WCAG 2.1 Level AA as the standard. The HHS dates are from its 2024 Section 504 rule as extended in its interim final rule of 11 May 2026. This is general information, not legal advice.
Where legacy courses usually fail
| Problem | WCAG 2.1 criterion |
|---|---|
| Text baked into images | 1.1.1 Non-text Content, 1.4.5 Images of Text |
| Fixed-size slides that do not reflow at 400% zoom or on a phone | 1.4.10 Reflow |
| Click boxes, hotspots and drag-and-drop that need a mouse | 2.1.1 Keyboard |
| Focus order that jumps around the slide | 2.4.3 Focus Order |
| Narration without captions or a transcript | 1.2.2 Captions, 1.2.1 Audio-only |
| Light grey text on white, or text over photos | 1.4.3 Contrast (Minimum) |
| Buttons and questions with no accessible name | 4.1.2 Name, Role, Value |
Several of these belong to the authoring tool’s player, not to anything an author typed. Adding alt text inside the old package does not make a fixed 1024×768 slide reflow.
A practical plan for a course library
- Inventory. List every course learners are still assigned, with its authoring tool and whether you still have the source file.
- Triage. Run each published course through the free scan. It lists findings by severity, shows what a screen reader announces, and states what it could not check.
- Retire or migrate. Archive what nobody needs. Import the rest into Scormbusters — from the published package if the source is gone — and fix what the import and the accessibility checker flag.
- Verify. Test the migrated courses with a keyboard and a screen reader, then export SCORM, cmi5 or xAPI and replace the old packages in your LMS.
Migration is priced per course ($99, less in packs), or with a $4,900 Library Pass for up to 150 courses — see pricing.
Frequently asked questions
Does the ADA Title II web rule apply to online courses?
The rule covers web content and mobile apps that state and local governments provide or make available, including through contractors. Courses delivered through an LMS — to the public, students or staff — are web content. Limited exceptions exist, such as archived content no longer in use; a course people are still assigned is not archived.
Which standard do courses have to meet?
WCAG 2.1 Level AA, in both the ADA Title II rule and HHS's Section 504 rule.
What are the deadlines?
Under ADA Title II: April 26, 2027 for public entities serving a population of 50,000 or more, and April 26, 2028 for smaller entities and special districts. Under HHS's Section 504 rule, as extended in May 2026: May 11, 2027 for recipients with 15 or more employees, and May 10, 2028 for smaller ones. Check the rule text for which date applies to your organization.
Can we fix legacy Captivate or Storyline courses, or must we rebuild them?
Many failures — fixed slide sizes, text drawn as images, mouse-only interactions — come from the player itself, so they cannot be patched in the old package. Migrating the content into an accessible format fixes them at the root. Scormbusters imports the published course, so the original source file is not needed.
Is a scan enough to prove compliance?
No automated tool can. The free scan finds a large share of problems and shows what a screen reader announces, and it says plainly what it did not examine. Conformance still needs a human review with assistive technology. This page is general information, not legal advice.
See what your course looks like to a screen reader first
The free scan reads a published course zip or URL and reports accessibility problems, with a transcript of what a screen reader announces. No account; your course is uploaded for scanning only and deleted immediately, never kept.
Sources (checked )
- DOJ final rule, ADA Title II web and mobile accessibility (Federal Register, 24 April 2024)
- DOJ interim final rule extending the Title II compliance dates (Federal Register, 20 April 2026)
- DOJ fact sheet on the Title II web rule (ada.gov)
- HHS final rule, Section 504 (Federal Register, 9 May 2024)
- HHS interim final rule extending the Section 504 web compliance dates (Federal Register, 11 May 2026)
This page is general information, not legal advice. Check the rule text, or ask counsel, for which date and exceptions apply to your organization.