Colorado HB 21-1110 Website Accessibility Requirements for Government Entities

Colorado HB 21-1110 applies directly to state and local government websites and digital services. The law requires Colorado government entities to make websites, mobile apps, documents, and other ICT accessible to people with disabilities under standards set by the Office of Information Technology. Unlike the federal ADA, HB 21-1110 provides a private right of action in state court and explicit statutory damages of $3,500 per violation. The law affects over 4,000 local government entities across Colorado, including counties, cities, school districts, and special districts.

What Is Colorado HB 21-1110?

Colorado House Bill 21-1110 amends the Colorado Anti-discrimination Act to define inaccessible government digital content as a civil rights violation. Signed into law in June 2021 and fully enforceable as of July 1, 2025, the law requires all state agencies and local government entities to meet accessibility standards established by the Colorado Office of Information Technology. Those standards currently require conformance with WCAG 2.1 Level AA for websites, mobile applications, digital documents, kiosks, videos, and third-party tools.

The law applies to both public-facing and internal-facing digital content. A government entity that fails to meet accessibility standards can be sued directly in Colorado state court by any individual with a disability who experiences discrimination due to inaccessible technology.

How to Reduce Colorado HB 21-1110 Website Accessibility Exposure

Reducing exposure under HB 21-1110 requires defensible evidence that a government entity is meeting OIT accessibility standards or demonstrating sustained progress toward compliance. We conduct structured accessibility audits against WCAG 2.1 AA, identifying barriers that create statutory violation risk and prioritizing remediation by user impact and litigation exposure.

Our senior practitioners validate fixes against original findings and document remediation closure. This produces evidence that can support a good faith defense or demonstrate full compliance under the OIT rules. We also help entities build the quarterly progress reports and accessibility statements required by statute.

Who Colorado HB 21-1110 Applies To for Websites and Digital Services

HB 21-1110 applies to all Colorado state agencies across executive, legislative, and judicial branches, as well as state-supported higher education institutions. It also covers every local government entity in Colorado, including counties, municipalities, towns, school districts, and special districts such as water, fire, and transportation authorities.

The law covers any ICT used by employees or the public to access government services, programs, or activities. This includes websites, web applications, mobile apps, digital documents such as PDFs and forms, kiosks, digital signage, videos, and third-party tools embedded into government platforms. Vendors selling digital products to Colorado government entities face indirect exposure through procurement requirements and contract compliance obligations.

Common Colorado HB 21-1110 Website Accessibility Risk Triggers

  • Inaccessible forms, PDFs, or documents that prevent users with disabilities from completing government transactions.
  • Websites lacking keyboard navigation or screen reader compatibility for essential services.
  • Video content without captions or audio descriptions on public-facing government sites.
  • Third-party tools embedded into government platforms that do not meet WCAG 2.1 AA standards.
  • Failure to publish a technology accessibility statement with two contact methods for requesting assistance.

Colorado HB 21-1110 Website Accessibility Enforcement and Lawsuit Trends

HB 21-1110 enforcement operates through private lawsuits filed in Colorado state court by individuals with disabilities who experience discrimination due to inaccessible government ICT. Unlike federal ADA Title II claims, which require filing in federal court, HB 21-1110 allows claimants to sue locally. This reduces barriers for plaintiffs in rural areas and expands litigation access statewide.

The Colorado Office of Information Technology sets accessibility standards and provides compliance guidance but does not directly enforce the law through administrative penalties. Enforcement relies entirely on private civil actions. The grace period under HB 24-1454 expired on July 1, 2025, meaning all government entities must now demonstrate compliance with OIT rules or face liability.

Courts determine whether discrimination occurred based on failure to comply with OIT-established accessibility standards. Liability attaches to the entity managing noncompliant content and separately to the entity managing the noncompliant platform.

Colorado HB 21-1110 Penalties, Attorney's Fees, and Settlement Exposure

HB 21-1110 provides three categories of remedies for accessibility violations. First, a court can order the government entity to fix the accessibility issues. Second, the plaintiff may recover actual monetary damages for harm caused by inaccessible technology. Third, the plaintiff may recover a statutory fine of $3,500 per violation, payable to each affected individual.

The per-violation structure creates significant exposure for government entities with systemic accessibility failures across multiple pages, documents, or applications. Each barrier encountered by a user with a disability can constitute a separate violation. Attorney’s fees are not explicitly addressed in the statute but may apply under broader Colorado civil rights remedies.

Small business defendants in related Colorado accessibility claims may qualify for a 50% fine reduction if they correct violations within 30 days, but this provision primarily applies to private-sector accessibility claims under C.R.S. 24-34-802, not to government entities under HB 21-1110.

WCAG Benchmarks Used in Colorado HB 21-1110 Website Accessibility Cases

Colorado OIT rules require conformance with WCAG 2.1 Level AA as the technical standard for all government ICT under HB 21-1110. This aligns with the federal DOJ Title II web accessibility rule, which also adopts WCAG 2.1 AA for state and local government websites and mobile apps.

WCAG 2.1 AA includes 50 success criteria covering perceivability, operability, understandability, and robustness of digital content. Common failure points include missing alternative text for images, insufficient color contrast, inaccessible form labels, missing captions for video content, and keyboard navigation barriers.

The OIT rules apply to websites, mobile applications, web applications, documents, kiosks, digital signage, video, audio, and third-party tools provided by or procured by government entities. Automated testing catches approximately 30-40% of WCAG issues; manual testing with assistive technologies is necessary to identify the remainder.

Common Misconceptions About Colorado HB 21-1110 Website Accessibility Compliance

The law applies to all Colorado government entities, including counties, cities, towns, school districts, and special districts such as water and fire authorities.

The grace period required demonstrating good faith efforts by July 2024, including quarterly progress reports and a published accessibility request process.

OIT standards require WCAG 2.1 AA conformance of underlying code. Overlays do not remediate source-level barriers and have been named in accessibility lawsuits.

The law covers both public-facing and internal-facing ICT used by employees to perform job duties, including internal applications and documents.

What Good Faith Looks Like Under Colorado HB 21-1110 for Websites

Good faith under HB 21-1110 is defined by the OIT compliance rules and the grace period requirements established by HB 24-1454. During the grace period, entities had to publish a technology accessibility statement with two contact methods, create a progress report updated quarterly showing concrete remediation efforts, and establish a clear process for users to request assistance with inaccessible content.

After July 1, 2025, good faith alone does not provide immunity. Entities must now meet one of five compliance pathways under OIT rules: conform with WCAG 2.1 AA, provide an accessible alternate version, provide reasonable accommodations upon request, document that the technology used is the most accessible option meeting business needs, or demonstrate ongoing progress through an annual accessibility plan.

Courts evaluating good faith will look for evidence of systematic testing, documented remediation, responsive accommodation processes, and leadership commitment to accessibility as an ongoing operational responsibility.

What Courts and Agencies Look For in Colorado HB 21-1110 Website Accessibility Cases

  • Published technology accessibility statement with two methods of contact for requesting assistance.
  • Documented accessibility plan showing progress toward removing barriers and updated annually.
  • Evidence of WCAG 2.1 AA testing and remediation across high-traffic pages and essential services.
  • Reasonable accommodations provided promptly when users request assistance with inaccessible content.
  • Quarterly progress reports demonstrating concrete and specific efforts toward compliance during any grace period.

Colorado HB 21-1110 Website Accessibility FAQs

No. HB 21-1110 applies only to Colorado state agencies and local government entities, including counties, cities, school districts, and special districts. Private businesses remain subject to ADA Title III and may face state-law exposure under other Colorado civil rights provisions, but HB 21-1110 does not directly apply to them.

HB 21-1110 requires compliance with accessibility standards established by the Colorado Office of Information Technology. OIT has adopted WCAG 2.1 Level AA as the technical standard. This applies to websites, mobile apps, documents, kiosks, videos, and third-party tools used by government entities.

Noncompliant government entities face three potential remedies: a court order requiring compliance, actual monetary damages, and a statutory fine of $3,500 per violation payable to each affected plaintiff. Each accessibility barrier encountered by a user can constitute a separate violation, creating significant exposure for systemic failures.

No. The grace period under HB 24-1454 expired on July 1, 2025. Government entities that qualified for the grace period by demonstrating good faith efforts no longer have immunity from liability. All entities must now comply with OIT accessibility rules or face enforcement through private lawsuits.

Yes. The law covers ICT used by employees to perform job duties, not only public-facing content. Internal applications, documents, and systems must meet accessibility standards to ensure employees with disabilities can access the tools required to do their jobs.

HB 21-1110 and federal ADA Title II both require WCAG 2.1 AA compliance for government websites. HB 21-1110 has earlier enforcement dates and provides explicit per-violation state-court damages that ADA Title II does not. Compliance with one law generally satisfies the other, but Colorado entities face dual enforcement pathways.

Indirectly. Government entities must ensure that third-party tools and vendor-provided platforms meet OIT accessibility standards. Vendors that cannot demonstrate WCAG 2.1 AA conformance may lose procurement opportunities or face contract compliance issues. Liability for noncompliant platforms rests with the government entity managing the platform.

Entities should maintain a published technology accessibility statement with two contact methods, an annual accessibility plan showing progress, testing documentation against WCAG 2.1 AA, remediation logs, and records of reasonable accommodations provided upon request. This evidence supports both compliance and good faith posture if challenged.

Recent Colorado HB 21-1110 Website Accessibility Lawsuits and Enforcement Actions

2025-2026

No publicly verifiable HB 21-1110 lawsuits documented as of January 2026

Plaintiff / Agency
N/A
Defendant
N/A
Venue & Jurisdiction
Colorado State Court (expected venue for future filings)
Allegations
N/A
Status / Outcome
HB 21-1110 enforcement began July 1, 2025. No publicly documented state court filings have been identified through January 2026.
Remedies / Payment
Not applicable
Why It Matters
The absence of early public filings does not indicate reduced risk. The private right of action and per-violation damages structure create ongoing exposure for noncompliant entities. Litigation patterns may emerge as the post-grace-period enforcement period matures.

2024

DOJ Title II Web Accessibility Rule (Federal)

Plaintiff / Agency
U.S. Department of Justice
Defendant
State and Local Governments Nationwide
Venue & Jurisdiction
Federal (applies to Colorado entities)
Allegations
Federal rulemaking establishing WCAG 2.1 AA as the required standard for state and local government web content and mobile apps under ADA Title II.
Status / Outcome
Final rule published April 24, 2024. Compliance deadlines: April 2026 for larger entities, April 2027 for smaller entities and special districts.
Remedies / Payment
Federal enforcement remedies under ADA Title II
Why It Matters
Colorado entities face dual compliance obligations. HB 21-1110 uses the same WCAG 2.1 AA standard as the federal rule but with earlier deadlines and explicit state-court damages.

2020

Afterhours Inc. (ADA Website Claim)

Plaintiff / Agency
Private Plaintiff
Defendant
Afterhours, Inc.
Venue & Jurisdiction
Colorado Federal Court
Allegations
Website not accessible per WCAG 2.1 standards, preventing users with visual impairments from accessing services.
Status / Outcome
Complaint filed July 28, 2020. Outcome not publicly documented.
Remedies / Payment
Not publicly disclosed
Why It Matters
Demonstrates that Colorado-based businesses face federal ADA web accessibility claims. HB 21-1110 adds a parallel state-court pathway specifically for government entities with explicit per-violation damages.

2020

Opensided MRI of Denver LLC (ADA Website Claim)

Plaintiff / Agency
Private Plaintiff
Defendant
Opensided MRI of Denver LLC
Venue & Jurisdiction
Colorado Federal Court
Allegations
Website not accessible per WCAG 2.1 standards.
Status / Outcome
Complaint filed. Outcome not publicly documented.
Remedies / Payment
Not publicly disclosed
Why It Matters
Colorado has existing federal ADA website accessibility litigation activity. HB 21-1110 creates additional exposure specifically for government entities through state courts.

N/A

Placeholder for future HB 21-1110 enforcement

Plaintiff / Agency
Expected: individuals with disabilities experiencing access barriers
Defendant
Expected: Colorado state agencies and local government entities
Venue & Jurisdiction
Colorado State Court
Allegations
Expected: failure to comply with OIT accessibility standards causing exclusion from government services
Status / Outcome
Monitoring for post-July 2025 filings
Remedies / Payment
Statutory damages of $3,500 per violation plus actual damages and injunctive relief
Why It Matters
HB 21-1110 provides the strongest state-level enforcement mechanism for government digital accessibility in the United States. Early compliance reduces exposure as litigation patterns develop.

N/A

Reserved

Plaintiff / Agency
N/A
Defendant
N/A
Venue & Jurisdiction
N/A
Allegations
N/A
Status / Outcome
N/A
Remedies / Payment
N/A
Why It Matters
Reserved for future case documentation as HB 21-1110 enforcement develops.