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Your Panelists

John Egan

Partner at Seyfarth

John is a subject matter expert in ADA Title III, and digital accessibility in particular.  He partners with clients, not only to defend them against digital accessibility class and single-plaintiff litigation in courts nationwide and before agencies such as the United States Department of Justice,  but also to develop robust digital accessibility compliance programs. Read John's complete bio on the Seyfarth website.

Brooke Porter

Business Development at UsableNet

With over a decade of experience in digital accessibility, Brooke Porter helps public agencies and organizations implement strategies that meet DOJ compliance expectations, reduce legal risk, and ensure inclusive, user-friendly digital experiences.

Frequently Asked Questions About the 2026 Deadline Extension

Does the extension change what the rule requires?

No. The Interim Final Rule extends the compliance dates only. WCAG 2.1 Level AA is still the technical standard. Scope, exceptions, and vendor obligations discussed in this webinar are unchanged.

Are the new deadlines final?

The IFR is effective immediately. DOJ opened a 60-day public comment period on publication, and has signaled it may issue a new proposed rulemaking on the rule's substance during the extension period. Until that happens — if it happens — the 2024 rule and the extended deadlines govern.

Should we slow down our compliance work?

No. Remediation for a mid-sized public entity typically takes 12–18 months. Private right of action exposure does not wait for the compliance date. Agencies in the strongest position a year from now will be the ones using the extension to build a defensible, documented program — not pausing.

Why did DOJ extend the deadlines?

DOJ cited correspondence from higher education associations, K-12 groups, the Small Business Administration's Office of Advocacy, and a congressional letter — all of which flagged that the original timeline underestimated the staffing and technology challenges of compliance. DOJ explicitly noted that generative AI "does not yet reliably automate the remediation of inaccessible content at scale."

Does this webinar's content still apply?

Yes. Every substantive topic covered — WCAG requirements, exceptions, vendor accountability, testing strategies, enforcement risk — is the same today as when the session was recorded. The only thing that changed is the calendar.

 

Where can I read the full analysis?

See our updated analysis of the IFR for the complete breakdown of what changed and what agencies should do next.

⚠️ A note on timing

This webinar was recorded on September 24, 2025, before DOJ's April 20, 2026 Interim Final Rule extending compliance deadlines by one year. References in the recording to "April 24, 2026" and "April 26, 2027" should now be read as April 26, 2027 and April 26, 2028, respectively. The rule's substantive requirements discussed in the session — WCAG 2.1 Level AA, scope of covered content, exceptions, vendor responsibilities, and enforcement mechanisms — are unchanged.