The Deadlines Moved. The Standard Didn't.

Two accessibility deadlines shifted this year, on opposite sides of the Atlantic, for opposite reasons. One marks a regulation settling into enforcement. The other marks a regulator buying time it says it won't spend twice. Read together, they tell you more about where digital accessibility compliance is actually heading than either does alone.

Europe: the EAA turns one, and enforcement stops being theoretical

The European Accessibility Act (EAA) became enforceable on 28 June 2025 and turned one this summer. For most of its first year, national regulators were building capacity rather than issuing penalties – hiring staff, developing audit methodologies, drafting procedures. That phase is ending.

• France filed its first EAA-related legal actions in November 2025, seeking emergency remediation from major retailers over inaccessible checkout and browsing flows.
• The Dutch Authority for Consumers and Markets has been sending information requests to e-commerce operators – including some headquartered outside the EU – with active enforcement expected through the second half of 2026.
• Norway has already imposed accumulating daily penalties on at least one organisation for unresolved accessibility failures.

No EU-wide fine total exists yet, and headline enforcement numbers remain modest. But that's the wrong thing to measure. The infrastructure for enforcement – audits, complaint pipelines, cross-border cooperation between member states – is now operational. A new version of the technical standard, EN 301 549 v4.1.1, is expected during 2026, and it's expected to push the baseline from WCAG 2.1 toward WCAG 2.2.

The US: Title II gets a reprieve, not a rescue

On 20 April 2026 – four days before the original deadline – the Department of Justice issued an interim final rule extending Americans with Disabilities Act (ADA) Title II compliance dates for state and local government websites and mobile apps. State and local government entities serving populations of 50,000 or more now have until 26 April 2027; smaller entities and special districts have until 26 April 2028.

The technical requirement hasn't changed: WCAG 2.1 Level AA, covering web pages, forms, electronic documents and multimedia. Nor has the DOJ's posture. Its own language, that it “fully anticipates implementing the regulation at the new deadline”, reads as a warning that the extension is a courtesy, not a signal that enforcement is off the table.

A parallel deadline sits with the Department of Health and Human Services, covering healthcare organisations that receive federal funding. At the time of writing, HHS had not confirmed a matching extension to its own timeline, which is worth tracking separately if it applies to your organisation.

What the extra runway is actually for

An extended deadline is only useful if it's spent differently to the deadline it replaced. As such, it's worth considering whether to:

• Use it for a proper audit against the real product – the working application, not a marketing-site sample – rather than a late scramble once enforcement starts.
• Build to WCAG 2.2 AA where you can, not the 2.1 floor. Both frameworks are converging on it, and early alignment avoids a second remediation cycle.
• Treat procurement pressure as the leading indicator, not the regulator. Enterprise buyers and public sector customers are increasingly asking vendors for conformance documentation – audit summaries, VPATs, remediation roadmaps – regardless of where a legal deadline sits.
• Keep the accessibility statement honest. Under active enforcement, a statement claiming conformance that doesn't match what a screen reader or keyboard user actually experiences is itself a liability, not a shield.

Frequently asked questions

What is the actual EAA deadline?

The European Accessibility Act has been enforceable since 28 June 2025. There is no delay to that core obligation – what's changed through 2026 is the intensity of enforcement, not the date itself.

Has the ADA Title II deadline been delayed for everyone?

No. The extension applies specifically to state and local government entities in the US. It moves their compliance date to 26 April 2027 (populations of 50,000 or more) or 26 April 2028 (smaller entities and special districts).

What accessibility standard satisfies both frameworks?

WCAG 2.1 Level AA meets the current minimum for both. Given EN 301 549's expected update and the general trajectory of enforcement, aligning to WCAG 2.2 AA now avoids doing the work twice.

If you're not confident your organisation's evidence would hold up under either framework, that's exactly what Access360, our managed accessibility service, is built for – ongoing monitoring and audit-ready reporting, rather than a one-off certificate that's out of date within a quarter. Get in touch to talk it through.