ADA Updates: Web Rule, Medical Equipment, and Tax Incentives

The biggest recent ADA updates are two Department of Justice final rules: one requiring state and local governments to make their websites and mobile apps accessible, and one setting accessibility standards for medical diagnostic equipment like exam tables and X-ray machines. Both carry compliance deadlines that now fall in 2027 and 2028 after the DOJ pushed the original dates back in April 2026. The Department of Health and Human Services finalized parallel medical equipment requirements for federally funded facilities, and the federal tax incentives that help businesses pay for accessibility improvements are still on the books.

New Web and Mobile App Rule for State and Local Governments

On April 24, 2024, the DOJ published a final rule under Title II of the ADA requiring state and local governments to make their websites and mobile apps accessible to people with disabilities.¹ The rule reaches every service, program, or activity a government offers online: utility bill payments, court filings, records requests, permit applications, everything.

The technical benchmark is WCAG 2.1, Level AA, a set of internationally recognized guidelines from the World Wide Web Consortium.¹ In practice, that means text alternatives for images, captions on videos, enough color contrast for text to be readable, full keyboard navigation for users who can’t operate a mouse, and pages that still work when text is resized or zoomed.² Forms need to identify their input fields, and interactive elements need to work with screen readers.

Compliance Deadlines After the 2026 Extension

The original rule gave governments serving 50,000 or more people until April 24, 2026, and smaller jurisdictions until April 26, 2027. In April 2026 the DOJ issued an interim final rule adding a year to each. Large entities now have until April 26, 2027. Smaller entities and special district governments have until April 26, 2028.³

The extensions change the timing, not the substance. Audits should be happening now, and common barriers like missing image descriptions, inaccessible PDFs, and mouse-only forms should be on the remediation list. Missing a deadline exposes a government to a federal enforcement action or a private lawsuit for injunctive relief under Title II.

What the Web Rule Doesn’t Cover

Five categories of content sit outside the rule:¹

Archived content created before the compliance deadline, kept only for reference in a designated archive area, and left unchanged.
Preexisting conventional documents — PDFs, spreadsheets, presentations, word processing files — posted before the compliance date, unless residents still use them to apply for or participate in a service.
Content posted by independent third parties who aren’t under contract with the government. Contracted vendors still have to comply.
Password-protected documents about a specific person, property, or account.
Social media posts made before the compliance deadline.

The archived-content exception is narrower than it sounds. Slapping an “archived” label on an old page isn’t enough. It has to actually be kept for reference, stored in a separate archive section, and never updated after archiving. And the preexisting-documents exception falls away the moment a resident needs the document to apply for something, even if the file itself is an old PDF.

One boundary: this rule applies only to state and local governments under Title II. No equivalent final rule currently exists for private businesses under Title III, though private-sector web accessibility litigation has continued to increase under existing ADA obligations.

Medical Diagnostic Equipment Standards

Two parallel rules now govern accessibility for medical diagnostic equipment. HHS finalized requirements under Section 504 of the Rehabilitation Act for any facility receiving federal funding, effective July 8, 2024.⁴ The DOJ published a matching rule on August 9, 2024, applying similar standards to state and local government facilities under Title II.⁵ Together they cover exam tables, dental chairs, weight scales, mammography machines, X-ray equipment, and similar devices.

Both rules adopt the U.S. Access Board’s standards. The central technical requirement: transfer surfaces (the part of a table or chair where a patient sits or lies down) must be height-adjustable between 17 and 25 inches from the floor, with at least four additional positions between those extremes spaced no more than one inch apart. Where stirrups are provided, the equipment must also include leg supports for positioning and securing the patient.⁶

How Much Equipment Has to Be Accessible

Not every unit needs to meet the new standards. For most facilities, at least 10 percent of each type of equipment in use, and no fewer than one unit, must be accessible. Rehabilitation centers, physical therapy offices, and other facilities that specialize in mobility-related conditions face a 20 percent threshold.⁵ Facilities with multiple departments must spread the accessible units around rather than parking them all in one wing.

For exam tables and weight scales specifically, federally funded providers must have at least one accessible unit of each by July 8, 2026.⁴ State and local government facilities have until two years after the DOJ rule’s August 2024 publication. Any equipment purchased, leased, or otherwise acquired after October 8, 2024, must meet the Access Board standards on arrival, regardless of whether the facility has hit its overall percentage yet.⁵

Tax Incentives That Help Cover the Cost

Businesses looking at accessibility upgrades have two federal tax benefits, and they can use both in the same year.

The Disabled Access Credit under Section 44 of the Internal Revenue Code gives eligible small businesses a credit equal to 50 percent of accessibility expenses over $250 and up to $10,250, for a maximum annual credit of $5,000. Eligibility requires either gross receipts of $1 million or less, or no more than 30 full-time employees, in the prior tax year.⁷ Qualifying expenses include ramps, doorway widening, accessible parking, website accessibility work, and equipment modifications.

The Architectural Barrier Removal Deduction under Section 190 lets a business of any size deduct up to $15,000 per year for removing physical barriers for people with disabilities or the elderly.⁸ There’s no revenue cap or employee limit on the deduction. When a business claims both in the same year, the deductible amount is reduced by the credit amount to prevent double-dipping.⁹

Service Animal Rules Are Unchanged

The ADA’s service animal provisions have been stable since 2011, but they still generate a lot of confusion. Only dogs qualify as service animals under Titles II and III, and miniature horses may qualify as a reasonable modification in some settings.¹⁰ The animal must be individually trained to perform a task directly related to a person’s disability. A dog that senses an oncoming seizure and alerts its owner qualifies. A dog whose mere presence provides emotional comfort does not.¹¹

Emotional support animals are not service animals under the ADA and have no public access rights in businesses or government buildings. They do receive some protection under the Fair Housing Act, which requires housing providers to allow them as a reasonable accommodation, but that’s a separate law with separate rules.¹¹

When it isn’t obvious that a dog is a service animal, a business or government employee may ask exactly two questions: Is this a service animal required because of a disability? And what task has the dog been trained to perform? Nothing beyond that. They cannot ask about the person’s disability, demand medical documentation, require a vest or ID, or ask for a demonstration.¹⁰ A business can require a service animal to be removed only if the animal is out of control and the handler isn’t taking effective steps to manage it, or if the animal isn’t housebroken.

Self-Service Kiosks: A Rule Still in Progress

Self-service kiosks for hotel check-in, food ordering, airport check-in, and payment have become routine, and existing ADA standards already reach many of them. The 2010 ADA Standards for Accessible Design require operable parts — buttons, screens, card readers, and similar controls — to sit within specified reach ranges: between 15 and 48 inches above the floor for forward and side approaches by a wheelchair user.¹² ATMs and fare machines carry extra requirements: speech output for blind users, braille instructions for locating audio jacks, and privacy features for audio output.

The U.S. Access Board is developing updated rules that would apply broader accessibility standards to a wider range of self-service transaction machines beyond ATMs and fare kiosks.¹³ That rulemaking isn’t finished, so obligations for restaurant ordering kiosks and hotel check-in terminals remain somewhat unsettled. Businesses installing these machines now should meet the current reach range and operable-parts requirements and plan for broader speech output and tactile interface requirements later. Devices installed today without accessibility features may need expensive retrofitting once the Access Board finalizes its rule.

1
ADA.gov. Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments
2
W3C. Web Content Accessibility Guidelines (WCAG) 2.1
3
Federal Register. Extension of Compliance Dates for Nondiscrimination on the Basis of Disability; Accessibility of Web Content and Mobile Applications of State and Local Government Entities
4
U.S. Department of Health and Human Services. New Requirements for Accessible Medical Diagnostic Equipment
5
Federal Register. Nondiscrimination on the Basis of Disability; Accessibility of Medical Diagnostic Equipment of State and Local Government Entities
6
U.S. Access Board. Chapter 3: Technical Requirements
7
Office of the Law Revision Counsel. 26 U.S. Code 44 – Expenditures to Provide Access to Disabled Individuals
8
Office of the Law Revision Counsel. 26 U.S. Code 190 – Expenditures to Remove Architectural and Transportation Barriers to the Handicapped and Elderly
9
Internal Revenue Service. Tax Benefits for Businesses That Accommodate People with Disabilities
10
ADA.gov. ADA Requirements: Service Animals
11
ADA.gov. Frequently Asked Questions About Service Animals and the ADA
12
ADA.gov. 2010 ADA Standards for Accessible Design
13
U.S. Access Board. Self-Service Transaction Machines