Grace Period Ending Soon: Are You Ready for Colorado's HB21-1110?

Colorado has taken significant steps to promote digital accessibility and protect people with disabilities from any discrimination. With the belief that accessibility is a commitment to providing equitable access to all services; not an item on a project checklist, the state has established a robust legal framework to ensure access to digital services for all. In May 2025, the Office of Information Technology amended the final Rules Establishing Technology Accessibility Standards to help clarify and define the standards and compliance parameters of Colorado’s accessibility laws, HB21-1110 and Senate Bill 23-244.

HB21-1110, passed in 2021, sets the foundation for accessibility across Colorado’s public sector. It mandates that digital platforms of government entities adhere to Web Content Accessibility Guidelines (WCAG) 2.1 AA standards. As the compliance grace period ends on July 1, 2025, it’s essential to understand the laws and its implications for public entities, educational institutions, state agencies and vendors.

Insights into HB21-1110

The Colorado Laws for Persons with Disabilities: HB21-1110 expand existing statutes to prohibit discrimination based on disability. This includes ensuring that public entities and state agencies:

• Do not exclude people with disabilities from services, programs, or activities.
• Provide equitable access to digital platforms in compliance with Web Content Accessibility Guidelines (WCAG) 2.1 AA.
• Develop and implement comprehensive accessibility plans in collaboration with the Office of Information Technology.

To prevent disparities, the law also mandates that state rules align with or exceed protections under the Americans with Disabilities Act (ADA).

ADA Testing: A systematic approach towards testing web and mobile ensuring compliance with ADA Title II regulations.

HB21-1110: A Framework for Digital Accessibility

Enacted in 2021, HB21-1110 establishes foundational accessibility standards for government Information Technology. Key elements include:

• Accessibility Standards: The Chief Information Officer is responsible for setting and maintaining IT accessibility standards, aligned with WCAG and international guidelines.
• Agency Compliance: Each state agency must submit a written accessibility plan by July 1, 2022, and fully implement these standards by July 1, 2024.
• Liability Provisions: Noncompliance regarding content or platforms is the responsibility of the managing public entity or agency.

Compliance Deadlines and Grace Period

HB21-1110 provides a structured timeline:

• July 1, 2022: Deadline for submitting accessibility plans to the Office of Information Technology
• July 1, 2024: Full implementation of WCAG standards required.
• July 1, 2025: Grace period ends, enforcing compliance for all covered entities.

The grace period, introduced by House Bill 24-1454, offers additional time for organizations to meet the stringent requirements. However, agencies must submit regular progress reports and demonstrate proactive measures.

Consequences of Non-Compliance

Failure to comply with HB21-1110 and related laws has significant repercussions:

• Legal Liability: Noncompliance is deemed discriminatory under the state law.
• Financial Penalties: Fines of $3,500 per violation can be levied for each affected individual.
• Lost Opportunities: Vendors who fail to meet accessibility standards risk losing contracts with public entities.

Vendor Responsibilities and WCAG Compliance

The HB21-1110 law extends beyond government agencies to include vendors providing digital services or products. These vendors must:

• Demonstrate WCAG compliance through a Voluntary Product Accessibility Template (VPAT®).
• Ensure their platforms and services do not create accessibility barriers for public entities.
• Align their offerings with state requirements to secure and maintain contracts.

Customers, Federal and state governments can evaluate the accessibility conformance of your products with accurate VPAT and ACR.

Reinforcing Accessibility with SB 23-244

The Senate Bill 23-244 (SB 23-244) complements HB 21-1110 by:

• Enhancing Enforcement: Defining specific penalties for non-compliance.
• Extending Funding Timelines: Allowing agencies to allocate resources for accessibility compliance through the 2025-26 fiscal year.
• Rule making Authority: Empowering the Office of Information Technology to update and refine compliance standards based on the latest WCAG updates.

Funding Accessibility in Colorado

To support compliance efforts, Colorado has invested in accessibility through state appropriations. For instance, in the 2021-22 fiscal year, $312,922 was allocated to the governor’s office for use by the Office of Information Technology, enabling resource allocation for enterprise solutions and supporting staff expansion.

Steps to Take Now

1. Audit Your Accessibility: Conduct thorough evaluations of your digital platforms.
2. Develop Accessibility Plans: If you haven’t already, submit and implement a detailed plan.
3. Collaborate with Experts: Partner with accessibility professionals to ensure WCAG conformance.
4. Update Vendor Documentation: Vendors must secure up-to-date VPATs demonstrating WCAG conformance.

Our ACE Learning course on "Getting Started with VPAT" will break down VPAT components, explores different versions (Section 508, WCAG, EN 301 549, INT VPAT) and helps you navigate accessibility compliance with confidence.

Conclusion

HB 21-1110 accessibility laws reflect Colorado’s commitment to creating an inclusive digital environment. Beyond legal compliance, aligning with WCAG standards benefits everyone by:

• Enhancing usability for all users, including those with disabilities.
• Fostering trust and engagement among constituents.
• Opening doors for innovation in accessible design.

As the July 1, 2025, compliance deadline approaches, Colorado’s public entities and vendors must act swiftly to meet these comprehensive accessibility requirements. These laws go beyond legal obligations—they represent a shared vision of inclusivity and equity. By embracing these standards, organizations can pave the way for a truly accessible future. Looking for assistance in navigating accessibility compliance?

Accessibility experts at BarrierBreak can provide tailored solutions to ensure your platforms are inclusive and compliant, helping you avoid risks while ensuring a more accessible digital space for everyone. Get in touch with us at sales@barrierbreak.com to learn how we can help you achieve accessibility compliance with Colorado’s HB 21-1110.