HB21-1110: How to Comply With Colorado’s Accessibility Law

Colorado’s HB21-1110 is the state’s digital accessibility law. It amended the Colorado Anti-Discrimination Act to treat inaccessible government technology as disability discrimination, and it requires every state and local government entity to bring its websites, apps, documents, and other digital content into line with technical standards set by the state’s Office of Information Technology. Individuals with disabilities who are shut out of government services by non-compliant technology can sue in Colorado court and recover either actual damages or a $3,500 statutory fine per violation, plus attorney fees.¹

Which Entities Have to Comply

The law reaches every “public entity” in Colorado. That term is defined broadly to cover any state or local government and any department, agency, special district, or other instrumentality of state or local government. In practice, state agencies, counties, cities, towns, school districts, water districts, and transportation authorities all fall within its scope.

Private businesses are not the target. The obligation runs to government bodies that deliver services, programs, or information through digital channels. A private company that sells to the public is subject to federal ADA requirements and other laws, but not to HB21-1110.

What Counts as Covered Digital Content

The scope is wider than most people expect. It covers all technology, hardware, and software that is either public-facing or internal-facing, including websites, mobile applications, kiosks, digital signage, documents, video, audio, and third-party tools a government entity uses or provides.²

The internal-facing piece catches agencies off guard. An employee portal used to request leave, pull pay stubs, or complete required training must be as accessible as the public site where residents pay utility bills. If a government employee with a disability cannot use an internal system, that is a potential violation.

The law also broadened who is protected. Earlier Colorado technology accessibility statutes focused on vision impairments. HB21-1110 extends protection to all individuals with disabilities as defined by the federal Americans with Disabilities Act, covering physical, sensory, cognitive, and neurological conditions.²

The Technical Standard: WCAG 2.1 Level AA

The Office of Information Technology sets the specific technical benchmark, and the current standard is the Web Content Accessibility Guidelines version 2.1, Level AA, published by the World Wide Web Consortium.³ The underlying statute references “the most recent” WCAG guidelines, which lets OIT update the standard as new versions are released.⁴

WCAG 2.1 AA covers a wide range of practical requirements. Text must have enough contrast against its background for people with low vision. All functionality must be operable through a keyboard alone, without requiring a mouse, which matters for users with limited motor control. Videos need captions. Audio content needs transcripts. Forms and interactive elements must be labeled so screen readers can identify them. Page layouts must adapt to different screen sizes without losing content or functionality.

These are testable criteria, not abstract ideals. A PDF a screen reader cannot parse, a video without captions, or a form that traps keyboard users are each concrete failures that could trigger a lawsuit.

Five Ways to Satisfy the Rule

OIT amended its accessibility rules in May 2025 to clarify what compliance actually looks like. A government entity does not need pixel-perfect conformance with every WCAG criterion. It must publish a technology accessibility statement that includes at least two methods of contact for requesting assistance, and it must meet at least one of five compliance pathways:³

Conform with the applicable and achievable WCAG success criteria, or with the relevant Section 508 criteria.
Offer an alternate version of the content that does conform with the technical standards.
Provide reasonable accommodations that allow individuals with disabilities to access the content or service.
Post an accessibility progress plan on the entity’s website that shows active work toward removing barriers.
Document that the technology in use is the most accessible option among those that meet the entity’s business needs.

This framework gives smaller entities with limited budgets a realistic path. A rural water district that cannot afford a full site rebuild might document that it is using the most accessible platform available while maintaining a progress plan and a clear process for residents to request accommodations.

Where the Deadlines Stand

HB21-1110 set July 1, 2024, as the original compliance deadline.⁵ When that date arrived with many entities still short of the mark, the legislature passed HB24-1454, which granted a one-year extension of immunity from liability through July 1, 2025, for entities that could show good faith efforts, maintained a visible process for requesting help, and posted quarterly progress reports.⁶

That grace period has expired. As of July 1, 2025, every Colorado government entity is expected to comply with OIT’s accessibility rules without the shield HB24-1454 provided. Entities that have not reached compliance are exposed to lawsuits.

How the Law Is Enforced

There is no enforcement agency. No state body conducts audits, reviews documentation, or issues administrative fines. The law is enforced entirely through private lawsuits brought by individuals with disabilities.³

Under C.R.S. 24-34-802, an individual with a disability who is excluded from or denied the benefits of a government entity’s services because of inaccessible technology can sue in Colorado court. A successful plaintiff is entitled to a court order requiring the entity to fix the problem, plus one of two financial remedies:¹

Actual monetary damages for the harm caused by the exclusion.
A statutory fine of $3,500 per violation, available whether or not the plaintiff can prove specific financial harm.

The plaintiff picks one of the two, not both. The court can also award attorney fees and costs to the prevailing plaintiff, and those fees often exceed the fine itself.¹ For an entity with dozens of inaccessible pages or documents, exposure compounds quickly, because multiple plaintiffs can assert separate violations and each violation carries its own $3,500 figure plus legal costs.

Third-Party Vendors Do Not Shift the Liability

A government entity cannot escape responsibility by pointing at an outside vendor. If a county buys scheduling software, embeds a third-party payment portal, or uses a contractor-built application, the county remains legally responsible for the accessibility of that technology.²

That shifts weight onto procurement. Entities that fail to vet accessibility claims before signing contracts can end up liable for problems they did not create but are obligated to fix. Asking vendors for a current Voluntary Product Accessibility Template before purchase has become standard practice for agencies taking the law seriously.

How This Fits With the Federal ADA Title II Rule

Colorado is out ahead of the federal government. The U.S. Department of Justice published a final rule in April 2024 requiring state and local governments nationwide to make web content and mobile apps accessible under WCAG 2.1 Level AA, the same technical standard Colorado uses.⁷ The federal deadlines are later: an April 2026 interim final rule extended them to April 26, 2027, for entities serving populations of 50,000 or more, and April 26, 2028, for smaller entities and special districts.⁸

Colorado entities that satisfy HB21-1110 and OIT’s rules will likely satisfy the federal rule as well, since both point to WCAG 2.1 AA. The federal rule carves out some categories Colorado’s law does not explicitly address, including archived web content, pre-existing conventional electronic documents, third-party social media posts, and password-protected individualized documents. Entities sitting on large archives of legacy content should track both sets of rules as the federal deadlines approach.

The enforcement structure is where the two diverge most sharply. The federal rule is backed by DOJ oversight and potential investigations. Colorado’s law relies on residents and advocacy organizations filing suits in state court, which means compliance pressure arrives as a complaint and a filing fee rather than a regulatory audit.

1
Justia Law. Colorado Revised Statutes 24-34-802 – Violations
2
Office of Information Technology. FAQ: HB21-1110 Colorado Laws For Persons With Disabilities
3
Office of Information Technology. Digital Accessibility Law for Colorado State and Local Government
4
Colorado General Assembly. HB21-1110 – Colorado Laws For Persons With Disabilities
5
Colorado General Assembly. HB24-1454 Grace Period Noncompliance Digital Accessibility
6
Colorado Judicial Branch. Judicial Evidence of Accessibility Plan
7
ADA.gov. Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments
8
Federal Register. Extension of Compliance Dates for Nondiscrimination on the Basis of Disability Accessibility of Web Content and Mobile Apps