Colorado's Website Accessibility Law, Explained

The short answer for Colorado

If you run a website or other information technology for a Colorado state agency, city, county, school district, or special district, Colorado's own accessibility law already applies to you — separately from, and on top of, federal law. Since July 1, 2024, House Bill 21-1110 (2021), as amended by Senate Bill 23-244 (2023) and implemented through the Office of Information Technology's (OIT) technology accessibility rule, has required Colorado public entities to make their information and communication technology accessible to people with disabilities, with the applicable and achievable success criteria of WCAG 2.1 Levels A and AA as the core technical benchmark (oit.colorado.gov/accessibility).

That deadline has already passed. For a Colorado public entity today, the live question isn't when this starts — it's where you actually stand against it, and what the law's own text says happens if you're not there yet. This page covers what HB21-1110 requires, who it covers, the standard adopted, what's changed since 2021, enforcement and remedies as the statute writes them, how this sits alongside federal Title II, and what a public entity or vendor should do. It's educational information about a public statute, not legal advice; see the note at the end.

What HB21-1110 requires

Colorado House Bill 21-1110, "Colorado Laws for Persons with Disabilities," was signed by Governor Jared Polis on June 30, 2021 (signed act, leg.colorado.gov). Rather than creating a freestanding new statute, it amended several existing sections of the Colorado Revised Statutes (C.R.S.): it redefined "public entity" at C.R.S. § 24-34-301 to mean any state or local government, or any department, agency, special district, or other instrumentality of one — replacing a prior definition that simply cross-referenced federal ADA Title II; it added "accessible"/"accessibility" definitions to C.R.S. § 24-85-102 and directed OIT's Chief Information Officer, at C.R.S. § 24-85-103, to establish accessibility standards for state agencies' information technology using the most recent Web Content Accessibility Guidelines published by the W3C's Web Accessibility Initiative — or a successor or international group — rather than a version frozen at enactment; it amended C.R.S. § 24-34-802 to make a public entity's or state agency's failure to comply with those OIT-established standards itself a form of disability discrimination, and to bar any Colorado rulemaking body from adopting a rule giving less protection than the federal ADA; and it appropriated $312,922 to OIT for the 2021–22 state fiscal year to implement the act (signed act, all sections).

Bill sponsor Rep. David Ortiz described the aim plainly: "We're talking about basic access, not convenience. Access that everybody else that's able-bodied takes for granted. This should be a priority." (oit.colorado.gov/accessibility-law)

Who has to comply

Two defined terms do the work here, and they aren't the same size. "Public entity" (C.R.S. § 24-34-301) is the broad one: any state or local government, or any department, agency, special district, or other instrumentality of either. "State agency" (C.R.S. § 24-37.5-102) is narrower — OIT's plain-language description of it is "an agency or state agency," including "any board, bureau, commission, department, institution, division, section, or officer of the state" (oit.colorado.gov/accessibility-rules).

Both terms appear side by side in the operative compliance clause, C.R.S. § 24-34-802(1)(c): discrimination "includes the failure of a public entity or state agency … to fully comply … with the accessibility standards … established by [OIT]" (SB23-244 §3). OIT's own rule confirms the practical answer directly: its "Applicability" section states the standards "apply to public entities in Colorado," listing both "any Colorado state government, or any department, agency, or other instrumentality of a state government" and "any local government, department, agency, special district, or any other instrumentality of a local government," citing § 24-34-802(1)(c) as its authority (oit.colorado.gov/accessibility-rules). OIT publishes separate responsibilities for "State Agencies" and "Local Governments," treating both as covered today (oit.colorado.gov/accessibility-law).

In short: cities, counties, school districts, special districts, and state departments and agencies are all covered. Private businesses are not — a Colorado business open to the public remains governed by federal ADA Title III instead, covered in our guide on whether your website needs to be ADA compliant.

The standard Colorado adopted

The statute itself doesn't freeze a single WCAG version in the law's text. As amended by SB23-244, C.R.S. § 24-85-103(2.5) directs OIT to promulgate rules that establish accessibility standards "based on and including, but not limited to" the most recent Web Content Accessibility Guidelines published by the W3C's Web Accessibility Initiative, "or any successor group or organization" (SB23-244 §2) — a rolling reference by design, not a version number written into statute.

OIT's own rule pins the current standard down concretely. Its Technical Standards definition sets the bar at the applicable and achievable success criteria of WCAG 2.1 conformance levels A and AA, as published September 21, 2023 (oit.colorado.gov/accessibility-rules), and OIT's public accessibility page states it plainly: "Following WCAG 2.1 AA as our minimum standard of accessibility" (oit.colorado.gov/accessibility). For technology with closed functionality — kiosks and similar devices — the same WCAG 2.1 A/AA bar applies, alongside a requirement to interoperate with assistive technology; for hardware specifically, separate Section 508 ICT standards apply instead (oit.colorado.gov/accessibility-rules).

Meeting the Technical Standards, though, is only one of five ways a public entity can be considered in compliance under the current rule — not the sole route, as the next section covers.

How compliance actually works: five paths, not one mandate

Colorado's rule — "Rules Establishing Technology Accessibility Standards," codified as 8 CCR 1501-11 — gives each public entity five alternative ways to satisfy section 11.5's compliance requirement (oit.colorado.gov/accessibility-rules):

1. Meet the Technical Standards — conform with the applicable and achievable WCAG 2.1 A/AA success criteria, unless a listed exception applies.
2. Provide a conforming alternate version that carries the same information and functionality.
3. Make reasonable modifications or accommodations when someone asks, at no cost to the person requesting them.
4. Publish an accessibility plan, updated annually, that shows real progress: what you're fixing, in what order, and how people can ask for help in the meantime.
5. Choose the most accessible option among the technologies that meet your business needs.

Every public entity, regardless of path, must also publish a Technology Accessibility Statement naming at least two ways to request an accommodation or report a problem (oit.colorado.gov/accessibility-rules). OIT's own framing: "Progress, not perfection: Public entities don't have to make all their digital content accessible overnight. However, they must show they are making progress toward accessibility and make it easy for people with disabilities to request assistance." And: "Compliance with the rules = compliance with the law" (oit.colorado.gov/accessibility-law).

The deadline, and what's changed since 2021

As originally enacted in 2021, the law had two dates: state agencies had to submit a written accessibility plan to OIT by July 1, 2022, and fully implement it by July 1, 2024 (signed act §5).

Senate Bill 23-244, "Technology Accessibility Cleanup," signed April 20, 2023, changed several things (bill summary, leg.colorado.gov; signed act): it removed the July 1, 2022 plan-submission-to-OIT step, simplifying the law to the single July 1, 2024 date; it converted OIT's standard-setting authority into a formal rulemaking duty, which is what produced 8 CCR 1501-11 as an actual promulgated rule rather than unwritten policy; it added "reasonably" to the statutory definition of "accessible"; it clarified that a violation across a single website or application counts as one incident, not a separate violation per page; and it added a 50% statutory-fine reduction for a qualifying small-business defendant (25 or fewer employees, no more than $3.5 million in annual gross income) that corrects a violation within 30 days of a complaint — a provision inside the same shared remedies section that covers other Colorado anti-discrimination claims, not one written specifically for public-entity websites.

OIT then finalized 8 CCR 1501-11 under that mandate, and amended the rule again in May 2025 "to help clarify and define the standards and compliance parameters" of both HB21-1110 and SB23-244 (oit.colorado.gov/accessibility-law).

Net effect: July 1, 2024 remains the operative date under both the statute and the current rule, and neither source describes a further blanket extension of it. What's changed since 2021 is less the date and more how "comply" is defined — the five-path, "progress not perfection" framework above, layered on what the original 2021 text read as a flatter, plan-and-implement mandate.

Enforcement and remedies, as the statute writes them

There is no state enforcement agency for this law. OIT does not audit public entities or require anyone to submit compliance documentation to it. As OIT's own page states: "Compliance with Colorado's digital accessibility laws is enforced through the courts. There is no enforcement agency, and there is no requirement to submit documentation to an enforcement agency or comply with audits from an enforcement agency." (oit.colorado.gov/accessibility-law)

The private right of action is written into C.R.S. § 24-34-802(2)(a): an individual with a disability who is subject to a violation "may bring a civil suit in a court of competent jurisdiction" and is entitled to any of the following remedies (SB23-244 §3):

• (I) a court order requiring compliance with the applicable section;
• (II) recovery of actual monetary damages; or
• (III) a statutory fine of $3,500, payable to each plaintiff for each violation.

Two further provisions shape how that plays out for a website specifically. Under § 24-34-802(2)(b), a violation on a single digital product — including a website or an application — is one incident, not multiplied per page. Under § 24-34-802(2)(d), a qualifying small-business defendant gets a 50% fine reduction if it corrects the violation within 30 days of the complaint — unless it knowingly caused the barrier — though this never reduces actual damages (SB23-244 §3).

Liability is also split by role: § 24-34-802(1)(c) puts liability for noncompliant content on whichever public entity or state agency manages that content, and liability for a noncompliant platform on whichever manages the platform (signed act, as amended) — worth knowing if a public entity's site runs on a vendor-managed platform.

How this relates to federal ADA Title II

Colorado's law sits alongside federal law, not instead of it — complying with one doesn't satisfy the other, and neither preempts the other. Our guide on whether your website needs to be ADA compliant covers the federal side in full: DOJ's Title II rule sets its own WCAG 2.1 Level AA conformance dates of April 26, 2027 (population 50,000 or more) and April 26, 2028 (under 50,000, and special district governments), after a one-year extension published in April 2026 (ADA.gov: New Rule on Web and Mobile App Accessibility; 28 CFR Part 35, Subpart H).

The practical point: Colorado's own July 1, 2024 date required WCAG 2.1 A/AA-level work more than two years before either federal date arrives. An entity that's kept up with Colorado's own law has, in substance, already been working toward close to the same bar the federal rule will separately require. One that hasn't should treat the Colorado deadline as already overdue — not the federal date as the first checkpoint.

What a Colorado public entity — or a vendor building for one — should do

This is educational, not a compliance guarantee for any specific site:

1. Confirm which bucket you're actually in — state agency, city, county, school district, and special district are all covered, per the statute's own definitions (§ 24-34-301, § 24-37.5-102) — rather than assuming.
2. Publish or update a Technology Accessibility Statement naming at least two ways someone can request an accommodation or report a barrier.
3. Pick at least one of the five compliance paths deliberately, and document it. An annually-updated accessibility plan showing genuine progress satisfies the rule even short of full conformance.
4. State agencies should work with OIT's Technology Accessibility Program (TAP) team directly; local governments can start with Colorado Counties Inc, the Colorado Municipal League, the Special District Association of Colorado, or BOCES, all named in OIT's own guidance (oit.colorado.gov/accessibility-law).
5. Start with a free automated scan — our own free ADA audit or OIT's recommended WAVE tool — then follow with manual keyboard navigation and screen-reader testing; no scan catches everything a person actually encounters.
6. If you're a vendor building or hosting a public entity's site, clarify who's responsible for content versus platform in writing — the statute assigns that liability separately, and an unclear contract is where this tends to go wrong.
7. Know the exceptions and defenses that exist — third-party content, certain preexisting or password-protected documents, undue burden, undue hardship, fundamental alteration, direct threat — but treat each as a case-by-case defense to document if it genuinely applies, not a reason to skip the underlying work.
8. If you'd rather hand this off, the ADA agency directory we publish — also a Grow Wild Agency property — lists agencies and consultants serving Colorado by the standards they state they work to.