Colorado HB21-1110 and documents: what applies now that the July 1, 2025 grace period has ended

Colorado enacted the first state law in the United States to attach statutory damages to inaccessible government technology, and it did so with a definition broad enough to reach every PDF a city, county, school district, or state agency publishes. The federal ADA Title II rule now overlaps it, but Colorado's dates came first and its remedies are sharper. This guide is written for the position in September 2026: the compliance date and the good-faith extension have both passed.

What the law says

House Bill 21-1110, signed June 30, 2021, amended the Colorado Anti-Discrimination Act. In OIT's summary, it made it discrimination to exclude a person with a disability from participation in, or deny them the benefits of, services, programs, or activities provided by any Colorado government entity, and it made it discrimination for a government entity to fail to develop an accessibility plan by July 1, 2022 and to fail to fully comply with the accessibility standards developed by OIT by July 1, 2024. The statute also broadened the state's accessibility standards to cover all individuals with disabilities as defined by the ADA, rather than people with vision impairments only.

The standard: OIT's rules and WCAG 2.1 AA

OIT publishes the Technology Accessibility Rules at 8 CCR 1501-11, alongside a plain-language guide, an accessible documents toolkit, and procurement and vendor guides. The rules adopt WCAG 2.1 Level AA as the technical standard. OIT's FAQ states that the law relates to "all technology, hardware, and software, that is both public-facing and internal-facing", including "any technology provided by or procured by a government entity that is used by the public or used by a government entity employee", and lists "websites, applications, kiosks, digital signage, documents, video, audio, and third-party tools". Documents are named directly, and internal-facing documents are included, which is broader than the federal Title II rule.

The extension and its expiry

HB24-1454, approved by the Governor and effective on May 24, 2024, responded to the July 2024 deadline by providing, in the General Assembly's summary, "a one-year extension to July 1, 2025, of immunity from liability for failure to comply with the digital accessibility standards for an agency that demonstrates good faith efforts toward compliance or toward resolution of any complaint of noncompliance". Eligibility required the agency to post quarterly progress reports. The extension protected entities from liability; it did not move the underlying standard or the obligation. Since July 1, 2025 no such immunity exists, and a Colorado government entity's exposure for inaccessible documents is the ordinary exposure under the Act.

Remedies

OIT's FAQ sets out the consequences. Any individual with a disability subjected to discrimination may bring a civil action, and the entity may be subject to a court order requiring compliance, monetary damages, attorney's fees, or "a statutory fine of $3,500 payable to each plaintiff for each violation". OIT's example is direct: after the deadline, if an individual tries to use a website that is not accessible, the entity may be subject to the $3,500 fine payable to that individual for each violation. Liability for noncompliant content lies with the entity that manages the content; liability for a noncompliant platform lies with the entity that manages the platform. Enforcement is through private civil action rather than administrative penalties from OIT.

How it interacts with the ADA Title II rule

Every Colorado state and local government entity is also a public entity under the ADA, so the federal Title II web rule applies too, with WCAG 2.1 AA required from April 26, 2027 for entities with a population of 50,000 or more and April 26, 2028 for smaller entities and special districts. The standards coincide, which simplifies the work: a document that meets WCAG 2.1 AA satisfies both. The dates do not coincide, and Colorado's has passed. The federal rule's exceptions for archived and preexisting documents (see the Title II exceptions) are federal; Colorado's statute contains no equivalent document cutoff, so a Colorado entity should not rely on the federal exceptions to defer work on state-law exposure.

What a Colorado public body should do now

1. Inventory documents, public and internal. The free website PDF scanner lists public PDFs and where they are linked; internal document stores need their own sweep.
2. Prioritise by use. Forms, applications, notices, agendas, board packets, and anything an employee must use to do their job come first, because those are the documents a complaint will cite.
3. Choose a path per document. Accessible HTML is often the better public reading experience; a remediated PDF is needed where the document must remain a PDF. The remediation paths guide compares them, and the government solution describes the workflow at scale.
4. Use OIT's toolkits. The accessible documents toolkit, procurement toolkit, and vendor accessibility guide are written for Colorado entities and align with the rules.
5. Keep evidence. Checker reports, manual review notes, and version records are what demonstrate compliance, and, where a defect is found, good faith.

Frequently asked questions

Sources

The statements above rest on the primary sources below. Where a source is a law or standard, the version and date named in the text are the ones checked on the review date. This guide is general information, not legal advice.

1. Colorado OIT: FAQ, HB21-1110 Colorado Laws for Persons with Disabilities . The plan and compliance dates, the scope including documents, the penalties, and the allocation of liability, as quoted.
2. Colorado General Assembly: HB24-1454, one-year extension for good-faith efforts . Bill summary, approval and effective date of May 24, 2024.
3. Colorado General Assembly: HB21-1110 as signed (PDF)
4. University of Colorado Denver: Colorado Law HB21-1110 . A covered institution's summary of the OIT standard as WCAG 2.1 AA.
5. eCFR: 28 CFR Part 35, Subpart H (ADA Title II web rule)