Peradeo Blog · United States · Published 2026-08-28 · 6 min read
Colorado's HB21-1110: The State Law That Made WCAG 2.1 AA Mandatory for Government Websites
By Vatsal Shah — Founder & CEO, IAAP WAS-Certified Accessibility Professional
Colorado passed the most aggressive state-level digital accessibility law in the United States. HB21-1110, signed in 2021, amended the Colorado Anti-Discrimination Act to declare that a government entity with inaccessible digital services is committing discrimination — and attached a private right of action with statutory fines. It has been fully enforceable since July 1, 2025.
Who is covered
All Colorado state agencies and local government entities — more than 4,000 organizations, including counties, cities and towns, school districts, colleges and universities, libraries, and special districts. The obligation covers public-facing and employee-facing technology: websites, web applications, mobile apps, online documents (PDFs and Office files), kiosks, videos, and embedded third-party tools.
The requirements and timeline
| Date | Requirement |
|---|---|
| July 1, 2022 | Accessibility plans submitted (state agencies, via OIT IT roadmaps) |
| July 1, 2024 | Full compliance with OIT accessibility standards — WCAG 2.1 Level AA |
| July 1, 2025 | End of the HB24-1454 good-faith grace period; full enforceability for all covered entities |
The penalties
A person who encounters an inaccessible government digital service can bring a civil action and obtain:
- A court order requiring compliance;
- Actual monetary damages;
- A statutory fine of $3,500 per violation, payable to each plaintiff — and each barrier encountered can count as a separate violation;
- Attorney's fees.
For an entity with systemic barriers across thousands of pages and documents, the arithmetic gets serious quickly.
Vendors: this law reaches you too
Because the covered entity is liable for everything it publishes or procures, Colorado governments now push WCAG 2.1 AA obligations into contracts. A SaaS product, payment portal, or learning platform sold to a Colorado school district is expected to conform — with an Accessibility Conformance Report (ACR/VPAT) to prove it. Vendors without credible conformance documentation are losing Colorado public sector deals, mirroring the federal Section 508 procurement dynamic and the ADA's Title II deadlines arriving nationally in April 2026.
Practical steps
- Government entities: audit everything in scope against WCAG 2.1 AA — including documents, videos, and third-party tools — and keep a prioritized remediation log;
- Fix service-critical journeys first (payments, permits, enrollment, emergency information);
- Vendors: get an independent audit and a defensible ACR/VPAT before your next Colorado RFP;
- Train content authors — the biggest recurring exposure is newly published inaccessible PDFs;
- Establish a barrier-report channel and respond fast: engaged remediation is your best defence posture.
How Peradeo can help
Peradeo is a web accessibility company based in Regina, Saskatchewan, Canada. Our IAAP-certified specialists audit websites and web applications against WCAG 2.0, 2.1, and 2.2 AA using real assistive technologies (NVDA, JAWS, VoiceOver), remediate the issues hands-on as developers, and prepare the compliance documentation — including VPAT® / Accessibility Conformance Reports and accessibility statements — that regulators and procurement teams ask for.
- Learn more about our web accessibility audit & remediation services
- Request a free accessibility check of your website
This article is provided for general information only and is not legal advice. Requirements change over time — consult a qualified lawyer for advice about your specific obligations.