Three federal paths converge in 2027 and 2028 to require WCAG 2.1 Level AA of a great many nonprofit organizations. RLEDC audits nonprofit websites against that standard, delivers a written findings report and a costed remediation plan, and can carry out the fixes. The first step is a free preliminary scan.
A complete accessibility compliance engagement for nonprofit organizations, structured so an organization can stop at any stage, keep the deliverables, and finish the work internally or with its own web vendor.
RLEDC runs an automated WCAG 2.1 Level A and AA scan of your public website and returns a short plain-language summary: which of the three federal paths applies to your organization, roughly where the site stands, and what the work realistically involves. No cost and no obligation for nonprofits in the region.
Every page tested against the complete WCAG 2.1 A and AA rule set, plus manual keyboard-only navigation, screen reader review, contrast measurement, and reflow testing at mobile widths. Linked documents are inventoried and sampled. Vendor-hosted systems are identified and tested separately.
Every failure listed with the success criterion it violates, where it occurs, its severity, and what it takes to fix. Ranked so you address the barriers affecting the most people first. Written to be read by a board or an executive director, not only by a developer.
A sequenced plan with effort estimates and a schedule that lands ahead of your applicable deadline, with a clear split between what your existing web vendor should fix under contract and what needs new work. Includes procurement language for future contracts.
Where an organization has no web vendor, or the vendor cannot do the work, RLEDC performs it: corrected markup, contrast-compliant styling, keyboard and screen reader support, accessible document templates, and a published accessibility statement.
Re-testing after remediation and a dated conformance record your organization can produce to a funder, an awarding agency, or a complainant. Documentation matters as much as the fix — an organization that cannot show its work is in a weak position.
RLEDC works with nonprofit organizations across the seven counties of the Eastern Plains region — Curry, De Baca, Guadalupe, Harding, Quay, Roosevelt, and Union — and with regional and statewide nonprofits serving those communities.
Clinics, federally qualified health centers, behavioral health providers, aging and disability services, child welfare and family service agencies. These organizations are the most likely to be HHS recipients and therefore on the earliest deadline.
Any organization delivering a program, portal, or public information under contract or MOU with a city, county, school district, or state agency. The public entity's obligation reaches your content through the contract.
Food banks, shelters, museums, recreation programs, animal rescues, chambers, and community foundations — places of public accommodation under Title III, where WCAG is the working benchmark.
Organizations running a vendor template that was never tested, with agendas and reports posted as scanned PDFs. This is the most common situation in rural New Mexico and the most straightforward to fix if it is started early.
There is no single rule that says "nonprofits must make their websites accessible by 2027." That is exactly why so many organizations will be caught out. The obligation arrives through three doors, and most nonprofits are standing in at least one of them.
If your organization receives federal financial assistance from the Department of Health and Human Services, Section 504 of the Rehabilitation Act now carries an explicit web accessibility standard. Nonprofits with 15 or more employees must comply by May 11, 2027.
The Title II rule reaches web content a public entity provides "directly or through contractual, licensing, or other arrangements." A nonprofit delivering a program or hosting content on behalf of a city, county, or state agency sits inside that obligation. The first public entities hit April 26, 2027.
Title III of the ADA has always covered nonprofits that operate places of public accommodation. There is no codified web standard under Title III — but WCAG is the benchmark used in Department of Justice settlements and in private litigation, and the rules above make it the de facto standard.
This is the path that directly regulates nonprofits, and it is the one most organizations have not heard about.
In 2024 the Department of Health and Human Services issued a final rule under Section 504 of the Rehabilitation Act setting a web and mobile accessibility standard for recipients of HHS federal financial assistance. The standard is the same one the Justice Department adopted for state and local government: WCAG 2.1 Level AA. The rule is codified at 45 CFR § 84.84.
On May 11, 2026, HHS published an interim final rule extending the compliance dates by one year. The current dates are:
| Recipient | Original Date | Current Date | Standard |
|---|---|---|---|
| 15 or more employees | May 11, 2026 | May 11, 2027 | WCAG 2.1 Level AA |
| Fewer than 15 employees | May 10, 2027 | May 10, 2028 | WCAG 2.1 Level AA |
Two points that matter for small organizations. First, the threshold is 15 employees, not budget size — a nonprofit with a small budget and sixteen part-time staff is on the 2027 date. Second, the rule applies to the organization's programs and activities, not only to the federally funded program. An organization does not get to make one page accessible and leave the rest.
This is the path that catches nonprofits with no federal funding at all.
28 CFR § 35.200(a) requires a public entity to ensure that web content it "provides or makes available, directly or through contractual, licensing, or other arrangements," is accessible. That phrase is the whole issue. The obligation does not stop at the edge of the city's own server.
If a nonprofit runs a program, portal, registration form, resource directory, or public information page on behalf of a public entity, that content is content the public entity makes available through a contractual arrangement. The public entity carries the legal obligation — and the public entity will push it down through the contract, because it has no other way to satisfy the rule.
Title III of the ADA covers private entities that operate places of public accommodation, and nonprofits are not exempt. A nonprofit that runs a food bank, a clinic, a museum, a school, a shelter, a recreation program, or a community facility is generally a place of public accommodation.
There is no regulation under Title III that specifies a web standard. That has not prevented web accessibility from becoming one of the most heavily litigated areas of the ADA. Where courts and the Department of Justice have looked for a benchmark, they have used WCAG. The Title II and Section 504 rules now make WCAG 2.1 Level AA the settled federal expectation across the rest of the disability-rights framework, which makes it considerably harder for any covered organization to argue that a different standard should apply to it.
If any of the following is true, your organization should be planning for WCAG 2.1 Level AA now rather than in 2027.
| If this is true of your organization… | Then |
|---|---|
| You receive HHS grant funds directly, or through a state or local pass-through, and have 15 or more employees | Section 504 applies. Compliance date May 11, 2027. |
| You receive HHS funds and have fewer than 15 employees | Section 504 applies. Compliance date May 10, 2028. |
| You deliver a program, portal, or public information under contract or MOU with a city, county, school district, or state agency | The public entity's Title II obligation reaches your content. Expect it in contract language ahead of the entity's own deadline. |
| You intend to bid on public contracts in the next three years | Accessibility conformance is becoming a responsiveness criterion. Being unable to answer the question costs bids. |
| You operate a facility or program open to the public | Title III applies. No fixed date, but WCAG 2.1 AA is the working standard and the litigation benchmark. |
| You apply for federal, state, or foundation grants | Accessibility and inclusion language is increasingly part of scoring. An inaccessible website is a visible contradiction of an equity narrative. |
| None of the above | No fixed deadline applies. The standard of care has still moved, and roughly one in four American adults reports a disability. |
A nonprofit exists to serve a community. An inaccessible website excludes members of that community from the programs the organization was funded to deliver — quietly, and without ever generating a complaint. Most people who cannot use a site simply leave.
Federal and state funders are steadily incorporating accessibility into assurances and scoring. An organization that cannot document conformance is answering a harder question every grant cycle, and a Section 504 recipient that is out of compliance has a funding condition problem, not merely a website problem.
Public entities under a WCAG obligation cannot contract for inaccessible deliverables. Nonprofits that can demonstrate conformance will be eligible for work that others are ruled out of.
The Title II rule carries a private right of action. Title III web litigation is already high-volume. A documented, dated conformance record is the difference between a manageable problem and an expensive one.
Remediating an existing site costs several times what building accessibly costs. Organizations that begin in 2026 can absorb the work across two budget cycles. Organizations that begin in 2027 will pay rush rates for the same result.
The same work that satisfies WCAG produces better structure, faster pages, working keyboard navigation, readable contrast, and content that reflows on a phone. Accessibility remediation is usually the most effective site improvement a small organization ever makes.
Working backward from a May 2027 date, with allowance for a board approval cycle and a budget year.
| When | Step |
|---|---|
| Now | Determine which path applies. Confirm whether the organization is an HHS recipient, list every public-entity contract or MOU, and count employees against the 15-employee threshold. |
| Within 60 days | Run a baseline audit against WCAG 2.1 Level A and AA. You cannot budget for work you have not measured. |
| Next budget cycle | Place remediation in the budget as a line item with a real number from the audit, and brief the board. This is a compliance obligation, not a marketing expense. |
| 6 to 9 months out | Complete remediation, including linked documents and any vendor-hosted systems. Documents and third-party portals take the longest and are consistently underestimated. |
| 3 months out | Re-test, publish an accessibility statement, and file the dated conformance record. |
| Ongoing | Train whoever posts content. Conformance degrades within months if new material is added without it. |
RLEDC provides accessibility audit and remediation support to nonprofit organizations and local governments across the seven-county Eastern Plains region, under the same process described on the ADA Web Accessibility Compliance page: baseline audit, findings report, prioritized remediation plan, implementation where needed, and verification with documentation.