Colorado HB 21‑1110 is law.
Is your site compliant?
Every Colorado state and local government digital platform must conform with WCAG 2.1 AA. Non-compliance carries penalties of $3,500 per violation per affected individual — and any resident with a disability can file suit directly in state court.
What HB 21-1110 Requires
Signed into law in 2021 and fully enforceable as of July 1, 2025, Colorado HB 21-1110 is one of the strictest state-level digital accessibility laws in the country.
WCAG 2.1 AA Conformance
All public-facing and internal digital content — websites, apps, PDFs, forms, videos, kiosks, and third-party tools — must meet WCAG 2.1 Level AA success criteria.
78 success criteria to meet →$3,500 Per Violation Fines
Non-compliant entities face a statutory fine of $3,500 payable to each plaintiff for each violation. Multiple violations on a single site compound rapidly.
10 violations = $35,000+ exposure →Citizen Enforcement
Any Colorado resident with a disability can file suit directly in state court. No federal agency complaint required — the enforcement mechanism is built into the law itself.
Direct civil action pathway →Accessibility Plans Required
Entities must submit formal accessibility plans to the OIT, including training processes for staff and ongoing monitoring systems for sustained compliance.
OIT oversight & reporting →Third-Party Liability
If your site uses third-party tools, embedded apps, or vendor platforms — your entity is liable for their accessibility failures, not the vendor.
You own the risk →Broad Scope
Goes beyond websites. Covers all digital content: documents, PDFs, videos, audio, digital signage, kiosks, internal systems, and anything procured by the entity.
Public-facing + internal →Does This Apply to Your Entity?
HB 21-1110 applies to all Colorado state and local government entities — if you manage public digital content, you're covered.
State Agencies
All departments, divisions & commissions
Cities & Counties
Municipal websites, portals & digital services
K–12 & Higher Ed
School districts, community colleges & universities
Public Health
Clinics, health departments & public hospitals
Libraries & Museums
Public library systems & cultural institutions
Transit & Utilities
Transportation authorities & utility districts
Courts & Legal
Judicial branch & legal aid portals
Special Districts
Fire, water, parks & recreation districts
What Non-Compliance Actually Looks Like
These aren't edge cases. They're the most common WCAG failures we find on government sites — and every one of them is a violation under HB 21-1110.
Images With No Alt Text
Screen readers announce "image" with no context. Every informational image, chart, logo, and button graphic without alt text is a separate failure — and a separate $3,500 exposure.
WCAG 1.1.1 — Non-text ContentLow Color Contrast
Light gray text on white backgrounds, colored text on colored backgrounds — if the contrast ratio falls below 4.5:1 for body text or 3:1 for large text, it's a failure. Extremely common on government sites.
WCAG 1.4.3 — Contrast (Minimum)Keyboard Navigation Broken
Dropdown menus, modal dialogs, and interactive elements that only work with a mouse lock out users who navigate by keyboard — including people who use switch devices, voice control, and screen readers.
WCAG 2.1.1 — KeyboardForms Without Labels
Input fields that rely on placeholder text instead of proper labels are invisible to assistive technology. Users can't tell what information is being requested — and form submissions become impossible.
WCAG 1.3.1 — Info and RelationshipsVideos Without Captions
Embedded videos, public meeting recordings, and instructional content without synchronized captions exclude deaf and hard-of-hearing users from critical government information.
WCAG 1.2.2 — Captions (Prerecorded)Inaccessible PDFs & Documents
Scanned PDFs, untagged documents, and forms without proper reading order are completely opaque to screen readers. HB 21-1110 explicitly covers all digital documents — not just web pages.
WCAG 4.1.2 — Name, Role, ValueFull-Scope HB 21-1110 Compliance
We don't just audit and hand you a report. We fix the problems, build the documentation, and set you up to stay compliant — not just pass a test.
WCAG 2.1 AA Compliance Audit
Manual + automated testing of your full digital footprint — websites, PDFs, forms, embedded tools, and internal systems. Automated tools catch ~30% of issues. We catch the rest. You get a detailed report with every failure mapped to its WCAG success criterion, severity level, and remediation path.
Full-Site Remediation
We fix the issues — not just flag them. Code-level fixes for navigation, color contrast, alt text, form labels, ARIA attributes, keyboard access, screen reader compatibility, and more. Your site gets brought into conformance, not just closer to it.
Accessibility Plans & VPATs
We build the formal accessibility plan required by OIT, including training documentation, monitoring protocols, and a Voluntary Product Accessibility Template (VPAT) for any digital products you procure or publish.
Monitoring & Maintenance
Compliance isn't a one-time fix — it's ongoing. We provide continuous monitoring, quarterly reporting, and staff training to ensure your entity stays compliant as content changes. New pages, new PDFs, new forms — we catch regressions before they become violations.
From Non-Compliant to Protected
A clear, structured path to HB 21-1110 compliance — with no surprises and no jargon.
Free Assessment
We run a preliminary scan of your site and walk you through your current risk exposure — no commitment, no sales pitch.
Full Audit
Manual + automated WCAG 2.1 AA audit across your entire digital footprint. Every violation documented and prioritized.
Remediate & Build
We fix accessibility issues, rebuild non-compliant elements, and prepare your OIT accessibility plan and documentation.
Monitor & Maintain
Ongoing monitoring, quarterly reports, and staff training to keep your entity compliant as your digital content evolves.
What Compliance Gets You
HB 21-1110 compliance isn't just about dodging penalties. An accessible site is a better site — for everyone who uses it.
Legal Protection
Eliminate your exposure to $3,500-per-violation fines and citizen-initiated lawsuits under HB 21-1110 and ADA Title II.
Better SEO
Proper headings, alt text, semantic HTML, and structured content are exactly what search engines reward. Accessibility and SEO share the same foundation.
Broader Reach
~26% of U.S. adults have a disability. Accessible digital services mean more residents can actually use what you've built — without workarounds or frustration.
Better UX for Everyone
Clear navigation, readable text, logical forms, and captioned video don't just help people with disabilities — they make the experience better for all users.
Federal ADA Alignment
The DOJ's 2024 Title II rule also requires WCAG 2.1 AA. Compliance with HB 21-1110 puts you in alignment with federal requirements simultaneously.
Procurement Readiness
A documented VPAT and accessibility plan positions your entity to confidently procure and evaluate vendor products — and hold them accountable.
Public Trust
Accessible digital services signal that your entity takes inclusion seriously — not as a checkbox, but as a value. That matters to constituents.
Reduced Support Burden
When digital services work for everyone, fewer residents need to call, visit in person, or request accommodations — saving staff time and resources.
The Grace Period Is Over
As of July 1, 2025, every covered Colorado government entity is fully liable under HB 21-1110. The citizen-enforcement model means any individual with a disability who encounters an accessibility barrier can file suit — and the fines compound per violation, per individual.
Compliance is cheaper than consequences.
The law is live. The fines are real. And the enforcement is citizen-driven — which means any resident with a disability who encounters a barrier on your site can take action. Let's find out where you stand before someone else does.
Get Your Free Compliance Assessment →Frequently Asked
If you're a Colorado state agency, local government office, public school district, community college, university, special district, or any entity that manages public-facing digital content funded by Colorado taxpayers — yes, you're covered. The law applies to all technology, hardware, and software that is both public-facing and internal-facing.
WCAG 2.1 AA includes 78 success criteria organized under four principles: Perceivable, Operable, Understandable, and Robust. In plain terms, it means your digital content must work with screen readers, be navigable by keyboard, have sufficient color contrast, include captions for video, provide alt text for images, use proper heading structures, and make forms usable by assistive technology — among many other requirements.
No. Overlay widgets and plugins cannot detect or resolve the majority of WCAG issues. Automated tools catch roughly 30% of accessibility problems. The remaining 70% require manual testing and code-level remediation. The Colorado OIT has not endorsed overlay-based solutions, and the broader accessibility community has documented their significant limitations. We recommend — and deliver — real remediation, not a band-aid.
Under HB 21-1110, your entity is liable for the accessibility of all digital platforms and content you manage — including third-party tools. If a vendor's embedded application on your site isn't accessible, the liability falls on your entity, not the vendor. We help you audit vendor tools, request VPATs, and build procurement language that protects your entity going forward.
It depends on the size and complexity of your digital footprint. A small municipal site with a few dozen pages can often be audited and remediated in 4–6 weeks. Larger entities with hundreds of pages, multiple subdomains, document libraries, and embedded tools may take 3–6 months. We'll give you an honest timeline after the initial assessment.
Costs vary by scope. Audit-only engagements for smaller sites start in the low thousands. Full audit + remediation + documentation for a typical municipal site runs $5,000–$25,000+. Ongoing monitoring retainers are additional. We're transparent about pricing and can scope your project after the free initial assessment. For context — a single violation fine is $3,500. Most non-compliant sites have dozens of violations.
We're based in Philadelphia, but accessibility compliance is digital — it doesn't have a zip code. What matters is expertise and execution, not proximity. That said, we've studied HB 21-1110 and its companion bills (SB 23-244, HB 24-1454) closely and understand the specific OIT requirements, reporting obligations, and enforcement landscape unique to Colorado.