barrierops.com/tools/colorado-hb21-1110 · last verified 8 September 2026
Colorado HB21-1110 readiness check
Which rules apply to you
If this check does not answer, every combination is in the table below.
Colorado’s own accessibility obligation has been in force since 1 July 2025. The federal deadline is separate and later. Both apply to the same website.
Last verified 8 September 2026.
Before you buy anything, use the licences the state already pays for
Colorado runs a grant programme that gives local governments PDF remediation licences.
It exists because documents are the most acute part of this problem. Forrester names PDF support a gap across the market, and government is the most document-intensive sector there is: minutes, budgets, permits, forms, agendas and board packets.
A licence is a tool, not a programme. It does not find the documents for you, it does not tell you which of your 1,180 files matter, and it does not produce a record that anything was fixed.
412 of your 1,180 PDFs are not accessible.
Each file is validated against PDF/UA-1 with veraPDF, and the clause that failed is named per document — 7.1.11, 6.2.1, 7.1.10 — so the person doing the remediation knows what to change.
- Files over 25 MB are not checked, and say so.
- Word, Excel and PowerPoint files are recorded but not yet validated, and say so.
We do not administer this programme, we are not a grantee, and we are paid nothing if you use it. We are telling you because it is the cheapest thing on this page.
The programme is the State of Colorado’s, not ours. There is no link here yet, because this page links a state page only once someone has opened it and checked that it is still the right one.
What Colorado HB21-1110 requires
- Who it covers
- Every state agency, public university, county, municipality, school district and special district in Colorado.
- The standard
- WCAG 2.1 level AA — the same standard as the federal rule, which is why one programme satisfies both.
- Since when
- The grace period expired 1 July 2025. The obligation is live.
- Enforcement
- A private right of action. A person may sue; enforcement does not wait for a state agency to act.
- Statutory damages
- $3,500 per violation.
- Relationship to federal law
- Additive. Colorado does not replace ADA Title II and Title II does not pre-empt Colorado. Both apply to the same page.
We do not multiply that figure by anything. A violation in a statute is not a scanner result, the arithmetic assumes a claim per finding, and nobody has litigated it. What is true is that the damages are statutory rather than proven, which is why this obligation behaves differently from the federal one. That is the whole of what we will say about it.
What “ready” means here, and what it does not
On this page, ready is the list below, and every line of it is something you can show somebody.
- You know which rules apply to you.
- You have an inventory — pages, documents, and the systems that run on somebody else’s host.
- You have a written plan with dates against it.
- A member of the public has a way to report a barrier, and somebody answers it.
- You can show what was tested, what was fixed, and who checked it.
Ready does not mean conformant, and this page does not issue that verdict. No screen, report, export or API response in this product issues it either.
Automated testing detects roughly 30–40% of real barriers. Manual testing covers the rest. 16 of the 50 WCAG 2.1 AA success criteria have any automated coverage — 32%.
Why this page carries a date
Colorado is the reason we keep regulatory content in data with a verification date rather than in copy. SB24-205 was delayed twice, challenged in court, judicially enjoined, then repealed and replaced within eleven days — without ever having been in effect for a single day.
Every figure on this page has a last-verified date and a citation you can check yourself. If the date at the top is more than six months old, the page says so where you can see it.
What usually fails on a Colorado government site
Documents
Untagged PDFs, with no structure tree, no document title and no language set. It is the largest category on almost every site, and the one automated testing says least about.
1.3.1 Info and Relationships, Level A · 1.1.1 Non-text Content, Level A
Contrast
Reported as: Element has insufficient color contrast (4.1:1, expected 4.5:1)
1.4.3 Contrast (Minimum), Level AA
The systems that are not on your website
The agenda portal, the payment page and the permit system are in scope for your obligation and are not on your domain. They usually run on granicus.com, tylertech.com, civicplus.com and accela.com.
Forms without labels
A permit form or a payment form whose fields are recognisable by eye and by nothing else.
3.3.1 Error Identification, Level A · 4.1.2 Name, Role, Value, Level A
Navigation
One issue in a shared template, appearing on 1,238 pages — which is one row in this product, not 1,238.
Every combination
The state obligation is the same for every row: in force since 1 July 2025. It is a statute rather than an interim rule, so the note in the federal column does not apply to it.
| Entity type | Colorado HB21-1110 CRS 24-85-103 | Federal deadline | Citation |
|---|---|---|---|
| Municipality, population 50,000 or more | In force since 1 July 2025 | 26 April 2027Interim final rule; a legal challenge is pending. | 28 CFR 35.200 · 91 FR 20902 |
| Municipality, population under 50,000 | In force since 1 July 2025 | 26 April 2028Interim final rule; a legal challenge is pending. | 28 CFR 35.200 · 91 FR 20902 |
| County | In force since 1 July 2025 | By population, as aboveInterim final rule; a legal challenge is pending. | 28 CFR 35.200 · 91 FR 20902 |
| School district | In force since 1 July 2025 | By population servedInterim final rule; a legal challenge is pending. | 28 CFR 35.200 · 91 FR 20902 |
| Special district, any size | In force since 1 July 2025 | 26 April 2028Interim final rule; a legal challenge is pending. | 28 CFR 35.200 · 91 FR 20902 |
| State agency | In force since 1 July 2025 | 26 April 2027Interim final rule; a legal challenge is pending. | 28 CFR 35.200 · 91 FR 20902 |
| Public college or university | In force since 1 July 2025 | From state population — 26 April 2027Interim final rule; a legal challenge is pending. | 28 CFR 35.200 · 91 FR 20902 |
Questions Colorado entities ask
Has the deadline already passed?
Colorado’s obligation took effect on 1 July 2025 — it is live now. The federal deadline under ADA Title II is 26 April 2027 or 26 April 2028 depending on population, and it has not.
Does the federal rule replace the state one?
No. They are additive. A Colorado entity is subject to both, against the same standard, WCAG 2.1 level AA, which is why one programme satisfies both.
Are special districts really covered?
Yes, at any size, under both rules. The federal deadline for a special district is 26 April 2028 regardless of population.
What does $3,500 per violation actually mean for us?
It means the damages are set by statute rather than proved in court, and that a person may bring a claim directly. It does not mean a scanner finding is a violation, and we will not multiply the two together for you.
Can we use the state’s PDF licences and still use BarrierOps?
Yes, and that is the order we recommend. Use the state licences to remediate documents. Use this product to find which documents matter, to record what was fixed and by whom, and to keep the rest of the site from regressing.
Does a clean scan mean we are compliant?
No. Automated testing detects roughly 30–40% of real barriers, and no tool issues that verdict. BarrierOps finds and reports issues against WCAG 2.1 AA success criteria and records what your team fixed.