Colorado House Bill 21-1110

What is Colorado HB 21-1110?

Colorado House Bill 21-1110, formally titled "Colorado Laws for Persons with Disabilities," was signed into law on June 30, 2021, and strengthens existing Colorado anti-discrimination statutes by explicitly requiring government ICT to be digitally accessible to people with disabilities. The law directs the Colorado Governor's Office of Information Technology (OIT) to establish and maintain accessibility standards based on the most current Web Content Accessibility Guidelines (WCAG) published by the W3C Web Accessibility Initiative. Colorado OIT's current mandated standard, reaffirmed in its May 2025 rules amendment, is WCAG 2.1 Level AA. The law establishes a private right of action, allowing individuals with disabilities who experience discrimination due to inaccessible government technology to sue in Colorado state court. A companion bill, HB 24-1454 (signed May 24, 2024), provided a one-year immunity from liability for entities demonstrating good-faith compliance efforts, with that grace period expiring July 1, 2025. In May 2025, OIT also amended its Technology Accessibility Rules to introduce multiple compliance pathways and align more closely with the ADA Title II web accessibility rule, while retaining WCAG 2.1 AA as the core technical standard.

Who must comply?

Colorado HB 21-1110 applies to all Colorado government entities - encompassing every state agency across the executive, legislative, and judicial branches, as well as state-supported higher education institutions and community colleges. It also covers every local government entity in the state, including counties, municipalities, towns, school districts (K-12), and special districts such as water, fire, and transportation authorities. The law reaches any ICT used by employees or the public to access government services, programs, or activities - including public-facing websites, web applications, mobile apps, digital documents (including PDFs), kiosks, videos, and embedded third-party tools. Private businesses are not directly covered by HB 21-1110, though they remain subject to the ADA and other Colorado civil rights provisions.

Key requirements

• All covered government entities must bring their websites, web applications, and ICT into conformance with WCAG 2.1 Level AA success criteria, as mandated by Colorado OIT under its Technology Accessibility Rules.
• State agencies were required to submit a written digital accessibility plan to Colorado OIT (via the agency's annual IT Roadmap) by July 1, 2022. Local governments, higher education institutions, and judicial entities are not required to submit plans to OIT but must still develop and implement accessibility plans.
• Entities that qualified for the HB 24-1454 grace period were required to post quarterly progress reports and maintain a process for resolving accessibility complaints during the grace period.
• Colorado OIT must establish and regularly update accessibility standards based on the most recent W3C WCAG guidelines, and may update the required version through rulemaking without new legislation.
• Covered entities must ensure accessibility across all ICT modalities, including digital documents (PDFs, forms), mobile apps, videos (captioning), kiosks, and embedded third-party tools.
• Both public-facing and internal employee-facing digital content and systems must meet the OIT-mandated accessibility standards.
• The May 2025 OIT rules amendment introduced multiple compliance pathways: full WCAG conformance; provision of accessible alternate versions; reasonable accommodations or modifications; or demonstrated good-faith progress with an accessibility plan - giving entities structured options beyond an all-or-nothing standard.
• Entities found liable in civil court are subject to court-ordered remediation and a statutory fine of $3,500 per violation payable to each affected plaintiff, or actual monetary damages if higher, plus attorney's fees.

Key dates & deadlines

• July 1, 2022State agencies must submit a written digital accessibility plan to Colorado OIT as part of the agency's annual IT Roadmap. (Note: local governments, higher education institutions, and judicial entities are not required to file with OIT but must still plan and implement accessibility improvements.)
• July 1, 2024Original deadline for full WCAG 2.1 AA conformance across all government ICT. Extended to July 1, 2025 for qualifying entities under HB 24-1454 that demonstrated good-faith compliance efforts.
• July 1, 2025Final enforcement deadline - grace period under HB 24-1454 expired; all covered entities are subject to civil liability for inaccessible government ICT.

Penalties & enforcement

Non-compliant government entities face private civil lawsuits in Colorado state courts brought by individuals with disabilities who experience discrimination due to inaccessible ICT. If found liable, a court may order mandatory remediation of inaccessible digital content and award a statutory fine of $3,500 per violation payable to each affected plaintiff, or actual monetary damages if higher, plus attorney's fees. There is no administrative enforcement by OIT; enforcement is entirely through private right of action - any person with a disability who encounters an inaccessible government digital service may file suit in Colorado state court.

How Colorado HB 21-1110 relates to WCAG

Colorado HB 21-1110 directly mandates conformance with WCAG, directing Colorado OIT to adopt standards based on the most recent guidelines published by the W3C Web Accessibility Initiative. Colorado OIT's current required standard - reaffirmed in its May 2025 amended Technology Accessibility Rules - is WCAG 2.1 Level AA, covering all four principles (Perceivable, Operable, Understandable, and Robust) and their success criteria. OIT has stated it will consider adopting WCAG 2.2 in future rulemaking. The law's forward-looking language requiring adoption of the "most recent" WCAG version means OIT can update the standard without new legislation, keeping Colorado's requirements current with evolving international best practice.

How EqualWeb helps you meet Colorado HB 21-1110

EqualWeb's AI Accessibility Widget can be deployed on Colorado government websites with a single line of code, automatically remediating approximately 80% of common WCAG 2.1 AA issues in real time - giving agencies a meaningful starting point on their path toward HB 21-1110 compliance from day one. The widget alone does not make a site fully conformant; achieving full WCAG 2.1 AA conformance requires expert review and remediation. For entities that need to reach and certify full conformance, EqualWeb's Managed Compliance service pairs certified IAAP/CPWA experts with client-side remediation, continuous monitoring, and delivery of a signed Accessibility Compliance Certificate, a VPAT/Accessibility Conformance Report, and a full evidence pack - supporting the documented compliance posture government entities need to demonstrate good-faith efforts and withstand scrutiny in the event of a civil action. EqualWeb's Continuous Monitoring tool provides a live 0-to-100 compliance score with regression alerts, helping agencies track progress and support their accessibility plan obligations and quarterly reporting requirements. PDF Tools address a common compliance gap for government entities: checking, remediating, and serving accessible PDFs that meet PDF/UA and Section 508 standards - covering the digital documents such as forms, reports, and public notices that HB 21-1110 requires to be accessible. Together, these services give Colorado government entities a structured, evidence-backed path toward the full WCAG 2.1 AA conformance that HB 21-1110 demands, without overstating what any single automated tool can achieve on its own.

Colorado HB 21-1110 - frequently asked questions

Official sources & further reading

• HB21-1110 Bill Text - Colorado General Assembly
• Digital Accessibility Law for Colorado State and Local Government - Colorado OIT
• FAQ: HB21-1110 Colorado Laws For Persons With Disabilities - Colorado OIT

Related standards & laws