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Colorado website accessibility law in 2026: what HB21-1110 and the ADA require

Colorado has one of the strictest digital accessibility laws in the country, and the federal deadline for cities and counties just moved. Neither change says much about a dentist in Highlands or a roofer in Aurora, yet both get asked about it every week. Here is what the law actually says, who it reaches, and the short list of design decisions that keep any Denver site out of trouble.

12 min read · By Zach Wennstedt · Published October 22, 2026

What does Colorado’s HB21-1110 actually require?

House Bill 21-1110, “Colorado Laws for Persons with Disabilities,” was signed on June 30, 2021. It does two things that matter for websites. First, it makes it a violation of Colorado’s disability discrimination law for a public entity or state agency to exclude people with disabilities from its services, and it treats inaccessible technology as one way of doing that. Second, it directs the Governor’s Office of Information Technology (OIT) to set the technical standard that government technology has to meet.

OIT did that in its Technology Accessibility Rules, 8 CCR 1501-11. The plain-language guide to those rules spells out the standard for digital content: the applicable and achievable success criteria of WCAG 2.1 conformance levels A and AA. The rules apply to technology in active use on or after July 1, 2024 and to anything created, bought or updated after that date. Every public entity also has to post a Technology Accessibility Statement that commits to removing barriers and gives people more than one way to report a problem.

“Public entity” is broad. The OIT guide lists state government and its departments and agencies, and any local government, including its departments, special districts and other instrumentalities. In practice that means the City and County of Denver, Aurora, Lakewood, every county, and special districts such as fire, water and library districts. School districts are covered too, with a carve-out in the rules for some student services that other laws already govern.

When did the Colorado deadline hit, and is there any grace period left?

The original deadline was July 1, 2024. In May 2024 the legislature passed HB24-1454, signed May 24, 2024, which gave entities one more year: until July 1, 2025, an agency that showed good-faith progress (quarterly progress reports and a working complaint process) was shielded from liability. That shield has expired. As of today, October 2026, the law is fully enforceable and no later extension has passed; we checked the General Assembly’s bill records before publishing.

1. June 30, 2021HB21-1110 signed. State agencies owe OIT an accessibility plan by July 1, 2022.
2. July 1, 2024Original compliance date for state agencies and local governments. OIT rules apply to technology in use from this date.
3. May 24, 2024HB24-1454 signed: a one-year good-faith shield from liability.
4. July 1, 2025Good-faith shield ends. HB21-1110 fully enforceable.
5. April 20, 2026U.S. Justice Department pushes the federal Title II dates back one year (details below).
6. April 26, 2027New federal date for governments of 50,000 or more people, which includes Denver.
7. April 26, 2028New federal date for smaller governments and all special districts.

What happens if a covered entity is not accessible? The Colorado Municipal League’s summary for its member cities puts it plainly: a person who is discriminated against can seek a court order requiring compliance, monetary damages, or a fine of $3,500. That $3,500 figure is the reason the law gets so much attention: it is a set amount in state court, and Colorado public bodies such as Red Rocks Community College describe it as $3,500 per violation, or actual damages instead.

Did the federal ADA deadline for cities and counties change in 2026?

Yes. In April 2024 the Justice Department finished a rule under Title II of the ADA that, for the first time, set a technical standard for state and local government websites and apps: WCAG 2.1 Level AA. On April 20, 2026 the Department published an interim final rule in the Federal Register that moved both compliance dates back by a year. The ADA.gov fact sheet now lists:

The standard itself did not change, and the federal delay does not delay Colorado’s own law. The City and County of Denver, with a 2020 Census population of 715,522, is in the 50,000-plus group federally, but it has been on the hook under HB21-1110 since 2025. A city that relaxed after reading “ADA deadline extended” headlines has misread its exposure.

One detail matters to private companies: the ADA.gov fact sheet notes that Title II also reaches contractors that provide public services on a government’s behalf. If your firm runs a booking portal, a payment page or a public-facing app for a Colorado city or district, expect the accessibility clause in the contract to be real.

Does any of this apply to my private Denver business website?

Not HB21-1110. It is written for public entities and state agencies, and the OIT rules define their scope the same way. A private restaurant, law firm or contractor in Colorado is not covered by the state law.

That is not the same as having no obligation. Title III of the ADA covers “public accommodations,” meaning most businesses open to the public. The Justice Department’s 2022 guidance on web accessibility says the ADA’s requirements apply to the goods and services businesses offer on the web, while also saying the Department has no regulation setting detailed technical standards for them. Businesses can choose how they comply, and the guidance points to WCAG and the federal Section 508 standards as helpful references.

In practice, Title III is enforced by private lawsuits, and the volume is not small. Seyfarth Shaw’s annual count of federal website accessibility filings:

Cases filed in U.S. federal courts. Demand letters and state-court suits are not included, so the real number is higher.

Federal ADA Title III website accessibility lawsuits, 2017 to 2025

2017	814
2018	2,258
2019	2,256
2020	2,523
2021	2,895
2022	3,255
2023	2,794
2024	2,452
2025	3,117

Show the numbers as a table

Year	Lawsuits
2017	814
2018	2,258
2019	2,256
2020	2,523
2021	2,895
2022	3,255
2023	2,794
2024	2,452
2025	3,117

Source: Seyfarth Shaw, ADA Title III blog, March 2026.

The 2025 total of 3,117 was up about 27% from 2024 and made up 36% of all Title III federal filings that year, according to the same report. New York (1,021), Florida (961) and Illinois (585) led; Colorado is not among the states the report singles out. That is a real reason not to panic, and not a reason to ignore it. A demand letter costs nothing to send, the fixes that would have prevented it are cheap when they are designed in, and a site that works with a screen reader also works for the customer holding a phone in one hand on the light rail.

How inaccessible is the typical website right now?

Very. WebAIM tests the home pages of the top one million websites every year with automated tools. In its 2026 report (data collected February 2026), 95.9% of home pages had detected WCAG 2 failures, up from 94.8% in 2025 and the first increase after six years of slow improvement. The average page had 56.1 detectable errors. Automated tools only catch a portion of real problems, so those are floors, not ceilings.

The useful part of the WebAIM data is that the same six problems show up year after year, and they are design and build decisions, not exotic engineering:

Share of the top one million home pages with each automatically detected failure.

Most common WCAG failures, WebAIM Million 2026

Low-contrast text	83.9%
Images missing alternative text	53.1%
Form inputs missing labels	51.0%
Empty links	46.3%
Empty buttons	30.6%
Missing document language	13.5%

Source: WebAIM Million, 2026 report.

Low-contrast text alone shows up on almost 84 of every 100 home pages. It is also the one you can check in ten seconds with the tool below.

What is the difference between WCAG 2.1 and WCAG 2.2, and which one should a new site target?

WCAG 2.1 is the version named by both the Colorado OIT rules and the federal Title II rule. WCAG 2.2 became a W3C Recommendation on October 5, 2023. It keeps everything in 2.1, removes one obsolete criterion (4.1.1 Parsing), and adds nine new success criteria, six of them at Level A or AA:

The other three (2.4.12, 2.4.13 and 3.3.9) are Level AAA. Our advice for any new build is to design to 2.2 AA. Every 2.2 page also passes 2.1, so you satisfy what the laws name today, and the extra criteria are the ones most likely to be added when the standards get updated. OIT has said it reviews its rules periodically, and 2.2 is the obvious next step.

What should a Denver web designer actually build into the site?

Accessibility is cheapest when it is a design decision rather than an audit finding. These are the items we put in every brief, and you can hand the same list to anyone you hire.

1. Color and type that pass on day onePick the brand palette with contrast already checked: body text at 4.5:1 or better, buttons and input borders at 3:1. Light gray placeholder text and white text on a pale photo are the usual failures.
2. Real text, not text in imagesPrices, hours, service lists and offers go in HTML. Every meaningful image gets alt text that says what it shows; decorative images get an empty alt so screen readers skip them.
3. Forms that announce themselvesEvery input has a visible label tied to it, required fields say so in words, and errors say what went wrong in text, not only in red. Our post on agent-ready websites covers why the same work also lets AI assistants fill in your quote form.
4. Everything works with a keyboardMenus open with Enter and close with Escape, focus is visible, and nothing traps the cursor. A sticky header must not cover the focused element (that is the new 2.4.11).
5. Buttons and links with namesAn icon-only phone or menu button needs an accessible label. “Click here” and empty links are the fourth most common failure on the web.
6. Tap targets a thumb can hit24 by 24 CSS pixels at minimum; we use 44 for primary actions.
7. Captions and transcriptsAny video with speech gets captions; a podcast or audio clip gets a transcript.
8. Language and structureThe page declares its language, headings run in order, and landmarks (header, nav, main, footer) are real elements. This is also what makes a page easy for search engines to parse.
9. Third-party widgets you test, not trustBooking widgets, chat bubbles and review carousels are frequent offenders. Test them with a keyboard before you sign the contract.
10. An accessibility statement with a real contactRequired for Colorado public entities and a good practice for everyone: say what standard you aim for and give a phone number and an email for reporting problems. Ours is at /accessibility/.

Will an accessibility overlay or widget make my site compliant?

We do not rely on them, and we would not tell a client they make a site compliant. An overlay is a script that adds a toolbar or tries to repair the page after it loads. It cannot rewrite a form whose labels were never there, or add meaningful alt text to photos it cannot understand, and it adds JavaScript to every page load. Automated scanners catch some problems, and WebAIM’s own data is built on automated detection, but the fix still has to happen in the code. Spend the overlay subscription on fixing the templates once.

How do I test my own site in an afternoon?

1. Run a free automated scan of the home page and your most important inner page, such as WebAIM’s WAVE or the accessibility section of Lighthouse in Chrome. Fix contrast, missing alt text, missing labels and empty links first; they are the top four on the chart above.
2. Unplug the mouse. Tab through the home page and the contact form. You should always see where you are, reach every link and button, and submit the form.
3. Zoom to 200% in the browser. Text should reflow without sideways scrolling or overlapping.
4. Turn on a screen reader for five minutes: VoiceOver on a Mac or iPhone, or NVDA (free) on Windows. Listen to the menu and the form.
5. Check your third-party tools the same way: booking, chat, payments, reviews.

If you want a second set of eyes, our free website health checks post lists the tools we use, and a redesign is the cheapest moment to fix all of this at once. If you work with a Colorado public entity, the requirements are stricter and documented; the OIT guide is the place to start, and this post is general information rather than legal advice.