WordPress Accessibility Checklist for Public Agencies and HHS-Funded Nonprofits (2026)

A Practical WCAG 2.1 AA Checklist for Public Agencies and HHS-Funded Organizations

If you run a government website, or a nonprofit that receives HHS funding, federal rules now set a firm accessibility deadline. Here's how to get your WordPress site ready.

Who these rules cover

Two federal rules now require specific organizations to make their websites accessible:

  • State and local governments under ADA Title II, including cities, counties, public universities and school districts, transit and utility agencies, and special districts.
  • Organizations that receive HHS funding under Section 504, including community health centers, behavioral health providers, Head Start programs, human service nonprofits, and private colleges and research institutions with NIH or other HHS grants.

Both rules require WCAG 2.1 Level AA for websites, mobile apps, and the documents you post. For the people you serve, an inaccessible site can mean they can’t pay a bill, apply for services, or find help.

If your organization doesn’t fall into either group, these deadlines may not apply to you directly, but this checklist is still the right standard to build toward. It’s practical guidance from a team that builds accessible WordPress sites, not legal advice.

Blind person using a computer with a braille display and headphones

Federal Accessibility Deadlines

The DOJ and HHS pushed these dates back in spring 2026. The standard, WCAG 2.1 Level AA, did not change.

April 26, 2027
State and Local Governments, 50,000+ Population

Rule: ADA Title II

  • Cities and counties
  • Public universities and school districts
  • Transit and utility agencies

Websites, mobile apps, and posted documents must conform to WCAG 2.1 AA.

April 26, 2028
Smaller Governments and Special Districts

Rule: ADA Title II

  • Public entities serving fewer than 50,000 people
  • Special districts such as water, park, and fire districts

Same WCAG 2.1 AA standard, one extra year to get there.

May 11, 2027
HHS Funding Recipients, 15+ Employees

Rule: Section 504 (HHS)

  • Public and private organizations that receive HHS funding
  • Includes many health, human service, and community nonprofits

If you have an HHS grant or contract, check whether this applies to you.

May 11, 2028
HHS Funding Recipients, Under 15 Employees

Rule: Section 504 (HHS)

  • Smaller organizations receiving HHS funding

A full redesign can take six months or more, so smaller teams should still plan well ahead.

The WordPress Accessibility Checklist

Eleven areas that cover most of what WCAG 2.1 AA asks of a government or HHS-funded organization's website

  1. Color contrast
    • Body text has a contrast ratio of at least 4.5:1 against its background.
    • Large text (about 24px, or 19px bold) and buttons, icons, and form borders reach at least 3:1.
    • Color is never the only signal. Error messages, required fields, and chart data also use text, icons, or patterns.
  2. Alternative text for images
    • Meaningful images have alt text that says what the image communicates, not just what it shows.
    • Purely decorative images have empty alt text so screen readers skip them.
    • Charts, infographics, and maps have a text equivalent on the page.
  3. Heading structure
    • Each page has one H1, usually the page title.
    • Sections use H2, subsections use H3, with no skipped levels.
    • Editors choose headings for structure, not for font size. Screen reader users navigate by headings.
  4. Keyboard navigation and focus
    • Every menu, link, button, form, and pop-up works with Tab, Enter, Space, and Esc.
    • A visible focus outline shows where you are on the page.
    • A skip link lets users jump past the navigation to the main content.
    • Sliders, modals, and embeds never trap keyboard focus.
  5. Forms
    • Every field has a visible label, not just placeholder text.
    • Required fields are marked in text, not only with an asterisk or color.
    • Error messages explain what went wrong and how to fix it.
    • Test your donation, contact, and registration forms with a keyboard and a screen reader.
  6. Links and buttons
    • Link text makes sense on its own: Read the 2025 annual report, not Click here.
    • Buttons with only an icon (search, menu, close) have an accessible name.
    • Links to PDFs or other files say so.
  7. Video and audio
    • Videos have accurate captions. Review auto-generated captions before publishing.
    • Podcasts and audio recordings have transcripts.
    • Nothing plays automatically with sound, and moving content can be paused.
  8. PDFs and documents
    • Documents posted on your site, such as annual reports, agendas, and applications, are tagged and readable by screen readers.
    • Where possible, publish key content as a web page instead of a PDF.
    • Archive or remove outdated documents nobody needs. The federal rules include limited exceptions for archived content, but new documents must conform.
  9. Zoom, reflow, and mobile
    • Pages work at 200% browser zoom without content being cut off.
    • Content reflows to a narrow (320px) screen without sideways scrolling.
    • Pinch-to-zoom is not disabled on mobile.
  10. Third-party tools and embeds
    • Donation platforms, event calendars, maps, chat widgets, and payment forms are part of your site in the eyes of your visitors and the law.
    • Ask vendors for an Accessibility Conformance Report (ACR or VPAT) before you sign.
    • Test embedded tools the same way you test your own pages.
  11. Accessibility statement and feedback
    • Publish an accessibility statement that names your standard and how you test.
    • Give people a way to report a barrier and request content in another format.
    • Link the statement from your footer. (Here’s ours.)

How to Test Your Site

Automated scanners are a good first pass, but they only catch a portion of accessibility problems. A real review combines tools with hands-on testing:

  • Run an automated scan with a free tool such as WAVE or axe DevTools, or install the Accessibility Checker plugin to flag issues as editors work. We use it on our own site.
  • Put the mouse away and move through key pages using only the keyboard.
  • Try a screen reader: VoiceOver is built into every Mac and iPhone, and NVDA is free for Windows.
  • Zoom to 200% and check your pages on a phone.
  • Test your most important tasks, such as donating, applying, registering, or finding contact information, from start to finish.
Web developer testing website code on multiple screens
Designer reviewing color palette samples next to a laptop

Plugins and Overlays: What They Can and Can’t Do

Accessibility in WordPress starts with the theme. A well-built theme handles headings, focus styles, menus, and contrast across every page. Plugins can help you catch problems, but they can’t fix a theme that wasn’t built for accessibility.

Be cautious with overlay widgets that promise one-line compliance. They don’t repair the underlying code, many people who rely on assistive technology find them disruptive, and in 2025 the FTC fined one major overlay vendor $1 million over misleading claims that its tool could make any site compliant.

The durable fix is accessible design and code, plus editors who know how to keep new content accessible. Our accessibility services cover all three.

Where to Start if Your Site Falls Short

Most sites won’t pass every item on day one. Prioritize the fixes that help the most people fastest:

  1. Fix your templates first. The header, navigation, footer, and forms appear on every page, so one fix there repairs hundreds of pages.
  2. Focus on high-stakes pages: applying for services, paying bills, finding care, registering, and contacting you.
  3. Address documents people actually use, such as applications, agendas, and notices, and retire the ones they don’t.
  4. Train your editors on alt text, headings, and link text so new content stays accessible.
  5. Publish your statement and schedule a recheck. For agencies and grantees, a documented plan also shows good-faith progress.

If your site is already on WordPress, many of these fixes can be done as an enhancement project rather than a full rebuild.

Exterior of a city hall building with a clock tower

Frequently Asked Questions

The DOJ’s ADA Title II rule and the HHS Section 504 rule both require WCAG 2.1 Level AA. WCAG 2.2 AA is the newer version and a good target if you’re redesigning anyway.

State and local governments serving 50,000 or more people must comply by April 26, 2027. Smaller governments and special districts have until April 26, 2028. The DOJ extended both deadlines by a year in April 2026.

Any organization that receives federal financial assistance from HHS, such as grants or contracts through HRSA, SAMHSA, NIH, or the Administration for Children and Families, including funds passed through a state or county agency. Deadlines are May 11, 2027 for organizations with 15 or more employees and May 11, 2028 for smaller ones. If you’re unsure whether your funding counts, check with your grants officer or legal counsel.

These two rules may not apply to you directly. Accessibility is still the right standard to build toward: many funders and partners expect it, and private organizations can face ADA lawsuits over inaccessible websites.

No. Scanning plugins help you find issues, and overlays change how a page looks on top of existing code, but neither fixes the underlying problems. Compliance comes from accessible design, code, and content.

A small site with a solid theme can often be remediated in a few weeks. Large sites with custom features and many PDFs can take several months. Fixing shared templates first resolves many issues at once.

Inclusive team meeting around a table with a laptop

Get an Accessibility Review

HyperArts builds WCAG compliance into every WordPress site we create, and we audit and remediate existing sites for government agencies, research institutions, and HHS-funded nonprofits.

We’ll review your site against WCAG 2.1 AA, show you which issues matter most, and give you a realistic plan to meet your 2027 or 2028 deadline. Planning a redesign anyway? See what a nonprofit website costs in 2026.

Ready to Meet Your Accessibility Deadline?

Schedule a free consultation and we’ll show you where your site stands against WCAG 2.1 AA, what to fix first, and how to get there before your deadline.