Colorado HB21-1110: Complete Compliance Guide for Digital Accessibility

What is Colorado HB21-1110?

Colorado House Bill 21-1110, officially known as “Colorado Laws for Persons with Disabilities,” is groundbreaking state legislation that requires all Colorado state and local government entities to ensure their digital platforms are accessible to individuals with disabilities. Signed into law by Governor Jared Polis on June 30, 2021, this historic bill makes Colorado the first state to establish comprehensive digital accessibility requirements with specific compliance deadlines and enforcement mechanisms.

Why Was HB21-1110 Passed?

The passage of HB21-1110 was directly influenced by the challenges revealed during the COVID-19 pandemic. When lockdowns and social distancing measures prevented in-person access to government services, people with disabilities faced significant barriers accessing essential services through government websites and digital platforms. The pandemic highlighted critical gaps in digital accessibility that effectively excluded disabled individuals from receiving vital government benefits and services during a time of unprecedented need.

The legislation recognizes that equal access to government services includes equal access to digital government services. By codifying digital accessibility requirements into state law, Colorado addressed the discrimination that occurs when government websites fail to accommodate the needs of people with disabilities.

Current Compliance Timeline

Key Dates:

• July 1, 2022: Government entities required to submit accessibility plans to Colorado’s Office of Information Technology (OIT)
• July 1, 2024: Original full compliance deadline (extended)
• July 1, 2025: Final compliance deadline under HB24-1454 grace period extension

The grace period allows qualifying entities additional time to achieve compliance, provided they demonstrate good-faith efforts toward accessibility and maintain accessible complaint processes.

Who Must Comply with HB21-1110?

State Agencies

All Colorado state departments, divisions, and administrative bodies.

Local Government Entities

• City councils and municipal departments
• County governments
• Town municipalities
• School districts and educational institutions
• Special districts and authorities

Content Creators and Managers

Individual responsibility extends to:

• Webmasters and digital content managers
• Communications departments
• IT departments and developers
• Any government employee creating digital content

What Digital Content Must Be Accessible?

HB21-1110 applies to all government-provided digital content, including:

Websites and Applications

• Public-facing websites
• Internal employee portals
• Mobile applications
• Web-based tools and services

Digital Documents

• PDFs and downloadable documents
• Microsoft Office files (Word, Excel, PowerPoint)
• Online forms and surveys
• Email communications

Multimedia Content

• Videos (must include captions)
• Audio content (requires transcripts)
• Interactive presentations
• Digital signage

Third-Party Tools

• Contracted software and platforms
• Embedded widgets and plugins
• Customer service chatbots
• Payment processing systems

Accessibility Standards: WCAG 2.1 Level AA

To comply with HB21-1110, all digital content must meet Web Content Accessibility Guidelines (WCAG) 2.1 Level AA standards. These guidelines are built on four fundamental principles:

1. Perceivable

Content must be presentable in ways users can perceive:

• Provide text alternatives for images
• Offer captions for videos
• Ensure sufficient color contrast (4.5:1 ratio for normal text)
• Make content adaptable to different presentations

2. Operable

Interface components must be operable by all users:

• Make all functionality keyboard accessible
• Give users enough time to read content
• Avoid content that causes seizures
• Help users navigate and find content

3. Understandable

Information and UI operation must be understandable:

• Make text readable and understandable
• Make content appear and operate predictably
• Help users avoid and correct mistakes

4. Robust

Content must be robust enough for various assistive technologies:

• Maximize compatibility with assistive technologies
• Use valid, semantic HTML markup
• Ensure content works across different browsers and devices

How Government Agencies Can Achieve Compliance

Step 1: Conduct Accessibility Audits

• Perform automated testing using accessibility scanning tools
• Conduct manual testing with assistive technologies
• Engage users with disabilities for user testing
• Document all accessibility barriers identified

Step 2: Develop Implementation Strategy

• Prioritize high-impact accessibility fixes
• Create remediation timelines for different content types
• Establish accessibility workflows for new content
• Train staff on accessibility requirements

Step 3: Remediate Existing Content

• Fix website navigation and structure issues
• Add alternative text to images
• Ensure proper heading hierarchy
• Remediate PDF documents and other files
• Add captions to video content

Step 4: Establish Ongoing Processes

• Implement accessibility review in content creation workflows
• Set up regular accessibility monitoring
• Create accessible procurement standards
• Establish user feedback and complaint processes

Step 5: Maintain Compliance Documentation

• Document accessibility testing results
• Track remediation progress
• Maintain accessibility statements
• Update compliance plans regularly

Enforcement and Penalties

HB21-1110 includes significant enforcement mechanisms:

Legal Enforcement

• Individuals with disabilities can file lawsuits in Colorado state courts
• Private right of action allows direct legal challenges
• Courts can issue compliance orders

Financial Penalties

• $3,500 statutory fine per violation paid to each affected individual
• Additional monetary damages may apply
• Attorney’s fees for successful plaintiffs
• Ongoing violations can result in cumulative penalties

Required Compliance Elements

To avoid penalties, entities must:

• Publish accessibility statements with contact information
• Provide two methods for requesting assistance
• Demonstrate progress toward removing barriers
• Document good-faith compliance efforts

Best Practices for Maintaining Compliance

Accessibility-First Approach

• Integrate accessibility into design and development processes
• Train all content creators on accessibility requirements
• Use accessibility-focused procurement practices
• Regular accessibility auditing and monitoring

User-Centered Design

• Include people with disabilities in user testing
• Gather feedback through accessible channels
• Continuously improve based on user needs
• Maintain open communication with disability communities

Technology Solutions

• Choose accessible content management systems
• Implement automated accessibility monitoring
• Use accessibility-focused development frameworks
• Maintain compatibility with assistive technologies

Common Compliance Challenges and Solutions

Challenge: Legacy Content

Solution: Prioritize high-traffic and essential content for immediate remediation while creating systematic plans for addressing remaining content.

Challenge: Third-Party Tools

Solution: Require accessibility conformance statements (VPATs) from vendors and include accessibility requirements in all procurement contracts.

Challenge: Limited Resources

Solution: Focus on high-impact improvements first, leverage automated tools where appropriate, and consider accessibility service partnerships.

Challenge: Staff Training

Solution: Implement comprehensive accessibility training programs and establish clear accountability for accessibility compliance.

Challenge: New PDF Documents

Solution: Establish accessibility workflows for all document creation and remediation, and train all staff who create PDFs on accessibility requirements.

Getting Started with HB21-1110 Compliance

1. Assess Current State: Conduct comprehensive accessibility audits of all digital properties
2. Develop Strategy: Create detailed compliance plans with realistic timelines
3. Secure Resources: Allocate budget for remediation tools, training, and potential service providers
4. Implement Changes: Begin systematic remediation starting with highest-priority issues
5. Monitor Progress: Establish ongoing monitoring and continuous improvement processes

Colorado HB21-1110 represents a significant step forward in ensuring digital equity for people with disabilities. While achieving compliance requires substantial effort and resources, the result is more inclusive digital experiences that benefit all users while meeting legal requirements and supporting Colorado’s commitment to civil rights and equal access.