What Colorado HB21-1110 is
Colorado HB21-1110 is a 2021 state law that treats a public entity’s failure to meet state accessibility standards as discrimination. It was signed on June 30, 2021. It gave the Governor’s Office of Information Technology, known as OIT, the job of setting those standards, and it lets residents enforce them in state court.
The core text, as shown in the 2024 amending act:
… discrimination pursuant to this section includes the failure of a public entity or state agency, as those terms are defined in section 24-34-301, to fully comply, on or before July 1, 2024, with the accessibility standards for individuals with a disability established by the office of information technology pursuant to section 24-85-103. Liability for noncompliance as to content lies with the public entity or state agency that manages the content.
That last sentence matters for a clerk. If your town manages the content, the liability for that content sits with your town, whoever built the website.
Who HB21-1110 covers
HB21-1110 covers state agencies and every local public entity in Colorado: counties, municipalities, and any department, agency or special district of a local government. Unlike the federal rule, it does not sort entities by population. A town of 300 people and a city of 300,000 share the same state standard.
The OIT rules set out when they apply:
The rules apply to all ICT that is in active use on or after July 1, 2024, and any ICT that is newly created, developed, acquired, altered, updated, or purchased on or after July 1, 2024.
ICT means information and communication technology. OIT’s plain language guide lists documents posted to the internet, “Google formats, PDF, Word, Excel, and PowerPoint,” among the things covered. That includes your agendas and minutes.
The deadline and the good-faith period
The deadline in HB21-1110 was July 1, 2024. In May 2024, HB24-1454 gave public entities that showed good-faith efforts immunity from liability until July 1, 2025. That good-faith period has ended. The act repealed its own immunity provision effective July 1, 2025, so it no longer shields anyone.
HB24-1454 was signed on May 24, 2024. To qualify, an entity’s good-faith efforts had to include, by July 1, 2024, a progress-to-date report on its front-facing web pages, updated every quarter, and a clear, easy-to-find process for requesting redress, with contact options that did not depend on web access. If sued, the entity could ask the court to decide whether it had made good-faith efforts.
The habits it asked for are still worth keeping. A dated account of progress and an easy way to ask for help are close to what the OIT rules ask for today.
What the OIT rules ask of a town
The OIT rules ask a town to post a technology accessibility statement with more than one contact method, and then to meet at least one of five compliance paths. The paths range from meeting WCAG 2.1 Levels A and AA to publishing an accessibility plan, updated every year, that shows progress.
OIT lists the five paths on its accessibility law page:
- Meet the technical standards: the applicable and achievable WCAG 2.1 success criteria at Levels A and AA.
- Provide an alternate version that does meet them.
- Provide reasonable accommodations or modifications.
- Publish a plan on your website, updated each year, that shows progress toward removing barriers.
- Document that you use the most accessible option that meets your needs.
The statement, under rule 11.6, should include a commitment to respond quickly and a prominent notice that “includes more than one contact method,” covering how to request accommodations and how to report inaccessible technology (OIT plain language guide). OIT sums up the approach as “Progress, not perfection.” OIT amended the rules in May 2025, with the amendments taking effect on June 30, 2025.
How enforcement works
Enforcement of HB21-1110 happens in court, not through an agency. An individual with a disability can sue in a Colorado court. If a public entity is found liable, the court can order it to fix the problem and award either actual damages or a statutory fine of $3,500 per violation.
A statutory fine of three thousand five hundred dollars, payable to each plaintiff for each violation.
SB23-244 also added a limit that matters: for claims about accessibility standards, a violation on a single digital product, including a website or an application, counts as a single incident rather than as separate violations. OIT says it plainly: “There is no enforcement agency.” Nor is there a duty to send documents to one or to face its audits (OIT). This guide does not estimate how often suits are filed; we have not found a reliable public count.
How the state and federal rules fit together
The state and federal rules overlap but do not match. Colorado’s standard has applied since July 1, 2024 and offers several paths to meet it. The federal ADA Title II web rule starts on April 26, 2028 for towns under 50,000, asks for WCAG 2.1 Level AA itself, and has its own exceptions.
A few differences to keep straight:
- Archived content. Colorado defines it with three conditions and no creation date test. The federal rule has four conditions, including a creation date; see the archived content guide.
- Older documents. Colorado’s exception covers documents last updated and made available before July 1, 2024 and not in current use, including by employees. The federal exception turns on your federal compliance date.
- Who is covered when. Colorado has one standard for all sizes. The federal rule sets dates by population, and special districts share the 2028 date; see the special districts guide.
The Colorado rules say it themselves: “Compliance with these rules does not necessarily ensure compliance with other laws, rules, and regulations.” For the federal side, read the pillar guide.
A worked example: a Colorado town of 2,500
A worked example: a hypothetical Colorado town of 2,500 posts board agendas, packets and minutes as PDFs, and its clerk handles the website between other duties. Under state law it is already expected to follow the OIT rules. Under federal law, its WCAG 2.1 Level AA date is April 26, 2028.
First, the town posts a technology accessibility statement with two ways to reach a person, such as an email address and a phone number, and explains how to ask for help or report a problem.
Next, it picks its paths. It might meet the technical standards for new meeting documents, publish a yearly accessibility plan, and answer every request promptly. Old minutes stay online, as OIT advises, with a note of which exception applies.
Finally, it keeps dated notes of what it fixed and when. The same monthly work serves the state rules now and the federal rule in 2028.
What we do about it
What we do about it starts in Colorado. We scan your site monthly, fix new agendas, packets, minutes and notices, and keep the dated Readable Record that can sit behind a published accessibility plan. We do not rebuild websites or promise outcomes; see how it works.
This guide explains the rule in plain language. It is not legal advice. For decisions about your town, talk to your attorney.
Questions
Is the HB24-1454 good-faith period still available?
No. HB24-1454 gave public entities that showed good-faith efforts immunity from liability until July 1, 2025. To qualify, they needed a progress report on their front-facing web pages, updated quarterly, and a clear process for requesting redress. The act repealed that provision effective July 1, 2025, so the period has ended.
What standard do the Colorado rules use?
The Colorado rules use the applicable and achievable success criteria of WCAG 2.1 Levels A and AA for digital content. The rules are 8 CCR 1501-11, issued by the Governor's Office of Information Technology. They also allow other ways to meet them, such as providing reasonable accommodations or publishing an accessibility plan that shows progress each year.
Does meeting the Colorado rules mean we meet the federal rule?
Not necessarily. The Colorado rules themselves say that meeting them does not necessarily ensure compliance with other laws, rules and regulations. The federal ADA Title II web rule has its own date, April 26, 2028 for towns under 50,000, its own exceptions and its own conditions. It makes sense to plan for both at once.
Who enforces HB21-1110?
Courts do. The Office of Information Technology says there is no enforcement agency and no requirement to submit documentation or undergo audits by one. An individual with a disability can sue in a Colorado court. If the court finds a public entity liable, it can order a fix and award actual damages or a statutory fine of $3,500 per violation.
Do we have to take old documents down?
No, and the state advises against it. The Office of Information Technology says public entities should not remove inaccessible documents and resources from their websites. Instead, make it easy for people to find a contact for requesting an accommodation while you work on making those resources accessible. Older documents may also fall under an exception in the rules.
Sources
- HB21-1110, Colorado Laws for Persons with Disabilities (Colorado General Assembly)
- HB24-1454, Grace Period Noncompliance Digital Accessibility (Colorado General Assembly)
- SB23-244, Technology Accessibility Cleanup (Colorado General Assembly)
- Digital accessibility law for Colorado state and local government (Colorado OIT)
- Plain language guide to the state technology accessibility rules (Colorado OIT)
- 8 CCR 1501-11, Rules Establishing Technology Accessibility Standards (Colorado OIT)
- 28 CFR 35.200, federal requirements for web and mobile accessibility (eCFR)
- 28 CFR 35.104, federal definitions, including archived web content (eCFR)