Level Access

Author: Level Access

The grace period for compliance with Colorado Laws For Persons With Disabilities (HB 21-1110) is coming to an end on July 1, 2025—which means state and local government organizations, including educational institutions, have limited time to ensure their digital services are accessible to people with disabilities. The law extends to both public-facing and employee-facing experiences, and it doesn’t just impact government entities—it also has implications for their vendors.

Neglecting to meet Colorado’s accessibility requirements by the deadline comes with consequences. Government entities risk facing substantial penalties, and product vendors who sell to these organizations may lose valuable business opportunities.

Unsure whether HB 21-1110 impacts your organization, or what actions you’ll need to take to comply? In this blog, we’ll unpack HB 21-1110 and related Colorado accessibility laws, including what they require and how they’re enforced.

House Bill 21-1110: Laying the groundwork for accessibility

Enacted in 2021, HB 21-1110 provides a legal framework for digital accessibility in Colorado’s public sector. This law requires all state and local government offices—such as cities, counties, local departments, and public K-12 schools and universities—to bring their digital platforms into conformance with the Web Content Accessibility Guidelines (WCAG) 2.1 AA standards.

Government entities must also develop comprehensive accessibility plans, and submit these plans to Colorado’s Office of Information Technology (OIT), the regulatory authority that oversees the law’s enforcement. HB 21-1110 compliance timeline

HB 21-1110 provides Colorado state and local government organizations with a multi-year timeline for meeting the law’s requirements:

  • July 1, 2022: State and local government entities must submit comprehensive accessibility planning documents to the OIT.
  • July 1, 2024: All government digital platforms must fully conform to WCAG 2.1 AA success criteria to ensure accessibility for individuals with disabilities. (A subsequent bill, HB 24-1454, allows organizations to qualify for a one-year grace period, which extends this deadline to July 1, 2025.)
  • July 1, 2025: The one-year grace period for meeting the original 2024 deadline ends—meaning all entities covered by the law must achieve WCAG 2.1 AA conformance.

Penalties for non-compliance with HB 21-1110

Organizations that fail to meet the law’s accessibility requirements may be subject to legal action and responsible for financial damages. They may also receive a $3,500 statutory fine for each violation, to be made to each affected individual for every instance of non-compliance.

HB 21-1110 and business-to-business (B2B) product vendors

While HB 21-1110 applies specifically to state and local government organizations in Colorado, B2B and business-to-government (B2G) companies that sell digital products to Colorado’s public sector should also be prepared to prioritize WCAG conformance. That’s because HB 21-1110 holds state and local governments responsible for the accessibility of digital products purchased from third parties—not just products they create themselves.

Public entities must verify that the technology they procure is accessible, so as not to incur penalties. Typically, that means requesting that vendors provide documented proof of accessibility, in the form of the Voluntary Product Accessibility Template (VPAT®).

For B2B and B2G organizations, obtaining a credible, up-to-date VPAT demonstrating WCAG 2.1 AA conformance is critical for protecting existing contracts with state and local entities in Colorado, and for winning new business.

Senate Bill 23-244: Strengthening enforcement and resources

Colorado Senate Bill 23-244 (SB 23-244) reinforces HB 21-1110. Passed in 2023, this bill clarifies processes for enforcing the law, including penalties. It also extends the timeline for organizations to receive digital accessibility funding and defines the OIT’s role in maintaining standards.

Specifically, SB 23-244 introduces the following changes:

  • Clearer enforcement measures: The bill outlines the specific penalties entities may face if they fail to comply with accessibility requirements.
  • Extended funding timeline: SB 23-244 grants government entities additional time to allocate financial resources for digital accessibility compliance, allowing them to secure funding through the 2025-26 fiscal year.
  • Rulemaking authority given to the OIT: With the passing of SB 23-244, the OIT is authorized to establish and update compliance standards that are aligned with the latest version of WCAG.

House Bill 24-1454: A grace period for compliance

Recognizing the challenges some organizations encounter during their accessibility journeys, HB 24-1454 extends the timeline for compliance with HB 21-1110, offering state and local offices a one-year grace period for achieving WCAG 2.1 AA conformance. With the original compliance deadline set for July 1, 2024, this grace period ends on July 1, 2025.

To qualify for the extension, government entities must meet the following requirements:

  • Regular compliance updates: Organizations are required to submit progress reports every quarter detailing their efforts to meet accessibility standards.
  • Resolution framework: Organizations must implement a structured process for identifying and addressing accessibility concerns related to digital products.

Colorado OIT resources on accessibility requirements

To support organizations’ compliance efforts, Colorado’s OIT has published a variety of educational resources. These include an FAQ document on HB 21-1110, which explains state and local entities’ responsibilities under the law, penalties for non-compliance, and exemptions.

Uphold your obligations under Colorado accessibility laws

With the July 1, 2025 deadline fast approaching, Colorado state and local government entities—and vendors who sell to these entities—must act now to meet HB 21-1110’s digital accessibility requirements. And by conforming with WCAG, organizations do more than avoid legal and business risks—they contribute to a more inclusive digital world for every Colorado resident.

However, aligning with WCAG can be complex—particularly if your team is new to accessibility. An expert partner, like Level Access, can provide the tools and support you need to fulfill your obligations and sustain long-term compliance.

For more than 25 years, Level Access has helped organizations across sectors—including government, education, and technology—comply with state and federal accessibility laws. Contact us today to take the next step toward accessibility success.

Frequently asked questions

Who is required to comply with Colorado’s digital accessibility laws?

All state and local government entities, including agencies, municipalities, and public K-12 and higher education institutions, are required to comply with HB 21-1110 and related legislation. This includes ensuring that their websites, applications, and digital content meet WCAG 2.1 AA standards.

Individuals can file civil actions against entities whose websites and other digital content pose barriers to accessibility. Entities that fail to meet accessibility requirements may face court orders, monetary damages, and statutory fines of $3,500 per violation. These fines are payable to each plaintiff for each instance of non-compliance. Entities may also be required to pay attorney’s fees.

To achieve compliance with accessibility laws in Colorado, organizations should:

  • Prepare, submit, and implement accessibility plans, if they have not yet done so.
  • Conduct accessibility audits.
  • Implement necessary updates to digital platforms.
  • Provide staff training on accessibility best practices.
  • Establish a process for addressing accessibility concerns.
  • Ensure that technology purchased from third-party vendors is accessible.

Engaging with accessibility experts can streamline compliance efforts and ensure long-term accessibility success.

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