New Federal Accessibility Rules

Update, 17 April 2026: The compliance date for rules has been pushed back a year. According to the Federal Register, “The compliance date for State and local government entities with a total population of 50,000 or more is extended from April 24, 2026, to April 26, 2027. The compliance date for public entities with a total population of less than 50,000, or any special district government, is extended from April 26, 2027, to April 26, 2028.”

Original article:

Back in July 2025 Colorado’s information technology accessibility rules went into effect. Colorado’s rules, established by the state law HB21-1110, allowed individuals to sue public entities that did not make their information technology compliant with at least WCAG 2.1 AA standards. Soon, in April 2026, new federal rules for website and mobile app accessibility will also go into effect for many state and local government entities. Luckily the two sets of rules don’t differ all that much, so if you are already complying with the state law you are probably also in compliance with the new federal regulations.

The federal rules, established under the Americans with Disability Act (ADA), are more limited than Colorado’s rules. The ADA rules apply only to public-facing websites and mobile applications. The Colorado rules apply to any information technology necessary for accessing public services or performing work for public entities. 

For most state and local governments the new federal rules go into effect on April 24, 2026. Smaller public entities, like a town or a library district, may have an extra year to comply. Governments serving fewer than 50,000 people and “Special district governments” have until April 26, 2027. These different compliance timelines do not apply to Colorado’s regulations, however. And, as noted previously, if you are already complying with Colorado’s rules you are probably also in compliance with the new federal rules. 

Exceptions to Federal Rules

Not all content is covered by the new federal rules. The rules spell out several exceptions, which are very similar to exceptions to Colorado’s accessibility rules. 

1. Archived web content
2. Preexisting conventional electronic documents
3. Content posted by a third party not under contract
4. Individualized documents that are password-protected
5. Preexisting social media posts

See the ADA website’s Fact Sheet for a detailed description of the exceptions and examples of each category. Exceptions to Colorado’s rules are described in the Office of Information Technology (OIT) Plain Language Guide to the State Technology Accessibility Rules. The similarity of the two sets of exceptions is intentional: OIT revised its rules in June 2025 to better harmonize with the coming federal regulations.