WCAG Compliance Requirements by State and Industry

An ADA and HHS Guide for All 50 States and the District of Columbia

Sources checked October 1, 2026

Which Organizations Must Meet WCAG?

Explicit federal requirements cover state and local public entities, covered recipients of HHS financial assistance, covered federal ICT, and certain airline websites. Nonprofits can qualify through HHS funding or public-service arrangements. Other businesses and nonprofits may have ADA accessibility obligations without one universally prescribed WCAG version.

Use the national schedule to identify the federal rule, then find your state and industry to check additional requirements. Coverage depends on the organization, its funding, the service, and the applicable law or contract. WCAG Level AA includes Level A criteria; a technical score alone does not establish compliance with every legal duty.

At a Glance: Federal WCAG Requirements

Rule & Official Source	Who Qualifies	Explicit WCAG Standard	Compliance Schedule
ADA Title II	State/local public entities, including public schools, utilities, libraries, transit, and hospitals	WCAG 2.1 AA for covered web content and mobile apps	Apr 26, 2027: population 50,000+ except special districts. Apr 26, 2028: population below 50,000 and all special districts.
HHS Section 504	Covered HHS assistance recipients, including qualifying nonprofits and subrecipients	WCAG 2.1 AA for covered web content and mobile apps	May 11, 2027: 15+ employees. May 10, 2028: fewer than 15 employees.
Section 508	Covered federal ICT; suppliers through applicable procurement requirements	WCAG 2.0 A/AA plus additional ICT requirements	Already effective. Confirm applicable procurement and contract milestones.
Air Carrier Access Act / DOT	Covered carriers’ primary websites marketing passenger air transportation to U.S. customers	WCAG 2.0 AA	Already effective. Carrier and website conditions are in 14 CFR §382.43(c).
ADA Title III	Qualifying businesses and nonprofits that are public accommodations	Accessibility obligation; no universal federally prescribed WCAG version	Existing duties apply. No general Title II or HHS deadline can be imported.

Which Requirements Apply to Your Organization?

State and Local Government: ADA Title II

Title II covers state and local government programs and services, including public education, libraries, courts, public health, transportation, utilities operated by public entities, and parks. The web and mobile app rule adopts WCAG 2.1 Level AA, including Level A criteria, for covered content provided directly or through contractual or licensing arrangements. A vendor-operated payment portal or learning platform is not automatically exempt.

Current technical compliance dates: Apr 26, 2027 for public entities with populations of 50,000 or more, other than special district governments; Apr 26, 2028 for entities with populations below 50,000 and all special district governments. Population is determined under the rule; it is not the number of website visitors or employees. These dates reflect DOJ’s 2026 extension.

Sources: DOJ Title II overview and 28 CFR §35.200: current standard and deadlines.

Businesses and Nonprofits Serving the Public: ADA Title III

Title III covers qualifying public accommodations, including stores, restaurants, lodging, banks, medical offices, private schools, recreation facilities, and many service businesses. DOJ’s position is that their online goods and services must be accessible. Title III does not have the same general WCAG 2.1 AA regulation or 2027/2028 timetable as Title II. Courts differ on the treatment of online-only businesses and the required connection to a physical location.

WCAG is an important implementation and testing benchmark, but it should not be presented as a universally codified Title III standard. A court order, settlement, contract, or other applicable law may specify an exact version. Nonprofit status is not itself an exemption. Title III has specific exclusions, including religious entities and qualifying private clubs; other laws or funding conditions can still apply.

Sources: DOJ guidance on web accessibility and the ADA and ADA Title III regulations

Recipients of HHS Financial Assistance: Section 504

HHS’s Section 504 rule reaches covered recipients of HHS financial assistance, not just hospitals. Depending on funding and program structure, this can include social-service organizations, health plans, universities, community programs, and other public, private, or nonprofit recipients. Identify the recipient and covered program or activity before assigning an obligation; HHS rules do not automatically govern every recipient of funding from a different federal agency.

Covered web content and mobile apps must meet WCAG 2.1 Level AA, subject to the rule’s exceptions and defenses. Current technical compliance dates are May 11, 2027 for recipients with 15 or more employees and May 10, 2028 for recipients with fewer than 15 employees. HHS extended these deadlines in 2026. General duties to provide accessible services and effective communication continue before these dates.

Sources: 45 CFR §84.84: HHS web and mobile requirements and HHS announcement of the deadline extension

Does Government Funding Require a Nonprofit to Meet WCAG?

Sometimes. Covered HHS funding creates an explicit WCAG 2.1 AA web/app requirement. Other government support requires a funding-specific review; nonprofit status and government funding alone do not establish one universal WCAG standard. HHS rule; Section 504 statute.

Does the Nonprofit Receive HHS Assistance, Directly or Through Another Recipient?

If yes, determine whether it is a covered recipient or subrecipient and apply the HHS rule and employee-based schedule above. Qualifying pass-through assistance can count; an ultimate individual beneficiary is not a recipient. Coverage can extend beyond one grant-funded webpage because the definition of “program or activity” can include all operations of covered education, healthcare, housing, or social-service organizations. HHS definitions

Does the Funding Come From Another Federal Agency?

Review that agency’s Section 504 regulations and the award conditions. Section 504 creates disability nondiscrimination duties, but HHS’s WCAG standard and deadlines do not automatically apply to another agency’s recipients. Receiving a federal grant does not automatically trigger Section 508. Section 504 coverage; Section 508 scope

Is the Support Funded Solely by a State or Locality?

Check state law, grant conditions, and contract terms for an express accessibility standard. State/local support alone does not trigger federal Section 504. First trace the original funding source: money administered by a state may be federal pass-through assistance. The state entries identify additional rules only within the scope supported by their cited sources.

Does the Nonprofit Deliver a Public Entity’s Digital Service?

The public entity must ensure that covered web content and apps supplied through contractual or other arrangements meet the Title II rule. The nonprofit’s unrelated operations do not automatically become subject to Title II. Check both the service arrangement and any separate funding duties. Outsourced public services

Does the Nonprofit Serve the Public Without Qualifying Funding?

It may still be a Title III public accommodation, subject to applicable exclusions. No government funding is needed for that route. Title III does not itself prescribe a universal WCAG version for all covered websites. DOJ web accessibility guidance

Covered Health Programs: ACA Section 1557

Section 1557 remains relevant to covered health programs and activities, including applicable health insurers and health services within broader organizations. Its ICT provision requires accessible health programs and addresses websites and apps through Section 504 requirements interpreted consistently with ADA Title II. It is an additional coverage analysis, not a law that applies to every business in every industry. An organization can be subject to both Section 1557 and the HHS Section 504 rule.

Source: 45 CFR §92.204: accessible information and communication technology

Federal Agencies and Their Technology Suppliers: Section 508

Section 508 governs ICT developed, procured, maintained, or used by federal agencies. Its revised standards incorporate WCAG 2.0 Level A and AA for covered web and other electronic content, alongside additional ICT requirements. Suppliers may need to meet those requirements through federal procurement contracts. Receiving federal funding alone does not automatically make a private organization subject to Section 508. State adoption of 508 standards is a separate source of obligation.

Sources: GSA Section 508 frequently asked questions and U.S. Access Board ICT standards

Employers, Education, Transportation, and Overlapping Rules

Employers covered by ADA Title I must address disability discrimination and reasonable accommodation in applications and employment. The usual private-employer threshold is 15 employees; it is not a blanket exemption from Title III for a smaller public-facing business. Review recruiting sites, onboarding, training, and employee systems. Title I is not itself a universal WCAG-version mandate. EEOC: Job Applicants and the ADA.

Public schools and public universities fall within Title II; covered private educational institutions may fall within Title III. Section 504 can separately apply to federally assisted education programs. Determine which funding agency’s rules apply rather than importing the HHS timetable into every educational institution. U.S. Department of Education: disability discrimination.

Airlines have a separate Air Carrier Access Act framework. Under 14 CFR §382.43(c), covered U.S. and foreign carriers operating at least one aircraft designed for more than 60 passengers must make covered primary websites marketing passenger air transportation to the U.S. public conform to WCAG 2.0 AA. This is not a general rule for every travel company or every airline app. Other transportation providers require a service-specific ADA/DOT review. DOT airline website rule.

A public university hospital, for example, may have Title II, HHS Section 504, Section 1557, employment, and state obligations. A retailer may have Title III and state civil-rights duties. A software supplier may have contractual accessibility duties when selling to public entities even if its own business does not independently fall within a public-accommodation category. Meet every applicable obligation; a later federal deadline does not automatically postpone an existing state or contractual requirement.

How to Use the State-by-State Analysis

Each state starts with its distinctive state rule or policy, followed by a table of covered industries, technical standards, deadlines, scope qualifications, and official sources. In the tables, “2027/2028” refers to the exact population- or employee-based schedule in the national comparison table; it is not a choice of dates. Earlier state or contract deadlines may still apply. Federal rules apply nationwide, so federal citations do not imply that a state enacted those rules. WCAG Level AA includes Level A. Apply state-agency policies only to entities within their stated scope.

For private and nonprofit organizations in every entry, start with Title III where the organization is a public accommodation, Title I where applicable, and the relevant federal-funding rules. Add state civil-rights laws, industry rules, contracts, and any court orders that apply. The absence of a private-sector WCAG mandate in a cited government policy does not establish that private organizations have no accessibility obligations.

Scope of verification: the entries distinguish express technical requirements from policy commitments and implementation guidance. Agency-specific statements are identified as such and are not evidence of a statewide private-sector mandate. This is a practical national overview, not an exhaustive survey of every local ordinance, judicial decision, funding agreement, or sector regulation. Organization-specific legal conclusions should be reviewed with qualified counsel.

State-by-State Requirements

State Source: Alabama Governor’s Office accessibility statement

The Governor’s Office accessibility statement identifies WCAG 2.0 AA as its website target. That is an office-specific statement, not a verified law imposing WCAG 2.0 AA on every Alabama organization. Public agencies and local governments should apply the federal Title II WCAG 2.1 AA rule and check any additional agency or procurement requirements.

Alabama Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	The Governor’s Office’s older WCAG 2.0 target does not lower the federal requirement for other public services.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Agency guidance is not a universal sector mandate.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Agency guidance is not a universal sector mandate.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Agency guidance is not a universal sector mandate.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Alaska Look and Feel Standards

Alaska’s Look and Feel Standards apply to covered executive-branch public-facing websites, including certain subcontracted sites. They reference accessibility laws and WCAG without establishing a single current version in the cited page. The standards expressly exclude web applications from that document’s scope; that exclusion does not remove federal accessibility duties for apps.

Alaska Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Executive-branch sites must also follow the Look and Feel Standards where applicable; that policy’s app exclusion does not remove federal app coverage.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Arizona Statewide Policy 1300

Statewide Policy 1300 requires accessible electronic and information technology for covered state budget units and adoption of a Section 508-compliant standard. For websites and online applications, it permits use of current WCAG Level A and AA criteria. The federal Title II rule separately supplies the WCAG 2.1 AA requirement for covered public web content and apps.

Arizona Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered state budget units must also apply Policy 1300 when procuring or delivering accessible ICT.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Arkansas official procurement compilation, Appendix 7A

Arkansas Code §§25-26-201 et seq. addresses nonvisual access to information technology for blind and visually impaired people, including technology purchased with state funds and covered state or state-assisted organizations. This is an access and procurement obligation; it should not be reduced to an unsupported statewide WCAG-version claim. Title II separately governs covered public websites and apps.

Arkansas Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Add the state’s nonvisual-access requirements for technology purchased with state funds and covered state-assisted organizations.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: California Government Code §11546.7

Government Code §11546.7 requires covered state agencies and entities to post biennial website accessibility certifications addressing §§7405 and 11135 and WCAG 2.0 or a subsequent version at Level AA. Federal Title II adds the WCAG 2.1 AA baseline for covered public content. CA.gov itself reports a WCAG 2.2 AA target; that statement should not be represented as the text of §11546.7.

Additional civil-rights considerations: California’s Unruh Civil Rights Act creates additional exposure for qualifying business establishments, including disability discrimination and ADA-based claims. Do not promise that a WCAG score guarantees immunity, or that statutory damages follow automatically from every technical defect.

Additional sources: CA.gov accessibility policy and California Civil Code §51.

California Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered state agencies also have the website certification duties in Government Code §11546.7.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Colorado OIT technology accessibility rules

Colorado’s technology accessibility rules, 8 CCR 1501-11, apply to state and local public entities and ICT in active use. Their technical criteria reference WCAG 2.1 A and AA, but the 2025 amendments also provide specified compliance options, including accommodations and a published plan demonstrating good-faith progress, together with an accessibility statement. Describing the current state rule as only a strict WCAG pass/fail requirement would be incomplete.

Colorado Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	State and local public entities must also address 8 CCR 1501-11; its state compliance options do not replace federal duties.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	State/local public-entity technology rules also apply.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities. Review Colorado’s public-entity rules.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Connecticut digital accessibility policy

Connecticut’s Accessibility & Inclusivity Policy for Websites and Digital Assets applies to state agencies defined in General Statutes §4d-1(3). It establishes WCAG 2.1 AA as the minimum for new digital content, assigns accessibility responsibility, and requires accessibility to be addressed in vendor contracts. State guidance distinguishes this agency policy from municipalities’ separate federal responsibilities.

Connecticut Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered state agencies must also follow the digital-assets policy and its WCAG 2.1 AA minimum for new content.	Title II; State source
Public education	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered state agencies must also follow the digital-assets policy and its WCAG 2.1 AA minimum for new content.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Delaware DTI digital accessibility policy

Delaware’s Department of Technology and Information identifies WCAG 2.1 Levels A and AA for state websites, digital documents, online services, and web-based tools. Its published guidance includes third-party tools used to deliver state services and describes governance, testing, and remediation as ongoing work.

Delaware Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	DTI’s WCAG 2.1 A/AA policy also addresses documents, online services, and third-party state-service tools.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: DC Office of Disability Rights: legal requirement

DC’s Office of Disability Rights states that all DC government programs, services, and activities must be accessible under ADA Title II. DC.gov also publishes a portal accessibility policy referencing Section 508. The current federal Title II web rule provides the WCAG 2.1 AA technical requirement for covered public content and apps.

District of Columbia Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	District agencies must apply Title II to their programs and services, including digital services supplied by contractors.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Florida Statutes §282.601

Florida Statutes §282.601 requires comparable access to covered state electronic information and IT for employees and the public, subject to the statute’s undue-burden provision. It covers the executive, legislative, and judicial branches within its terms. Federal Title II provides the separate WCAG 2.1 AA web and app requirement; the statute should not be described as imposing that version on all Florida businesses.

Florida Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered state branches must also provide comparable IT access under §282.601, including employee-facing technology.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Georgia Digital Services accessibility compliance guidance

The Georgia Technology Authority’s Digital Services program directs state agencies to WCAG 2.1 AA and now identifies the extended federal compliance date, Apr 26, 2027. Some older Georgia checklists still display the superseded federal date; use the current federal rule when determining the federal deadline.

Georgia Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	State agencies should apply Georgia Digital Services guidance to forms, documents, apps, and vendor integrations.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Hawaii ETS disability access standards

Hawaii’s Electronic Information Technology Disability Access Standards apply to state entities across the executive, legislative, and judicial branches. The standards combine Section 508 requirements with WCAG 2.1 Levels A and AA, or a subsequent version adopted by DOJ, and call for accessibility language in contracts. Use the current ETS standards rather than an older generic website template.

Hawaii Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered state entities must also meet ETS’s Section 508 and WCAG 2.1 A/AA standards and contract requirements.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tool	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.1 AA	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Idaho ITS digital accessibility resources

Idaho Information Technology Services maintains a central digital accessibility resource hub for agencies and confirms the extended state Title II deadline of Apr 26, 2027. Its training and procurement materials support implementation. The hub is not evidence of a separate statewide WCAG mandate for every private organization.

Idaho Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Use ITS implementation resources; a municipality must determine its own Title II deadline rather than adopt the state-agency date.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Illinois IITAA 2.1 standards

The Illinois Information Technology Accessibility Act is implemented through IITAA standards. IITAA 2.1 requires WCAG 2.1 AA for covered IT developed, procured, or substantially modified after Jun 24, 2024. Earlier technologies remain subject to IITAA 2.0 under the state transition rules, but that does not exempt covered public web content from the newer federal Title II requirement.

Illinois Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered state entities must also apply IITAA 2.1 to covered newly developed, procured, or substantially modified IT.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	IITAA also covers public universities within the Act.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Indiana IN.gov accessibility policy

IN.gov’s accessibility policy identifies WCAG 2.1 for state information technology used by the public or state employees and references Indiana Code 4-13.1-3. The federal Title II rule establishes Level AA for covered public web content and apps. Use the state policy and the purchasing agency’s current specifications together.

Indiana Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	State information technology must also follow IN.gov’s accessibility policy and applicable purchasing specifications.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Iowa Department of Management digital accessibility policy

Iowa’s Digital Accessibility Policy ADMN.303.02.E, effective Sep 1, 2026, covers the Department of Management and supported entities, including people and vendors working for them. WCAG 2.1 AA is the binding target, with compliance by Apr 26, 2027; WCAG 2.2 AA is encouraged for new or substantially revised content. Covered procured products need a current Accessibility Conformance Report before deployment.

Iowa Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	DOM-supported entities and their vendors must also meet ADMN.303.02.E, including its conformance-report requirement for procured products.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Kansas ITEC 1210-P implementation guidance

Kansas ITEC Policy 1210-P, Revision 4, requires WCAG 2.1 AA alongside its adopted Section 508 and ADA requirements. The state’s implementation guidance gives Apr 24, 2025 as the deadline for full compliance with that revision. This existing state policy timetable is distinct from the subsequently extended federal Title II dates.

Kansas Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Entities within ITEC 1210-P’s scope must also meet its independent state timetable and adopted ICT standards.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Kentucky COT KITS report, accessibility entry 7025

The Commonwealth Office of Technology’s published KITS report includes a Web Accessibility Standard for agency-created pages and third-party development. Its accessibility entry still references legacy WCAG 1.0 AA and Section 508 language. Those older references are not the current federal target: covered government web content and apps must meet the Title II WCAG 2.1 AA rule.

Kentucky Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Legacy WCAG 1.0 wording in KITS does not replace the federal WCAG 2.1 AA target.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Louisiana revised PPM 74

Louisiana PPM 74 applies to executive-branch boards, commissions, departments, agencies, institutions, and offices. Its revised policy sets WCAG 2.1 AA as the minimum and requires an accessibility coordinator, agency policy, and accessibility statement. The revision replaced an earlier WCAG 2.2 requirement. The posted PPM still contains an Apr 24, 2026 implementation date; the later federal extension should not be assumed to amend that state text automatically.

Louisiana Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered executive entities must also follow PPM 74’s WCAG 2.1 AA minimum and accessibility governance requirements.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Maine digital accessibility and usability policy

Maine’s Digital Accessibility and Usability Policy requires WCAG 2.1 A and AA and revised Section 508 standards within its scope. It addresses public-facing content, specified internal content, vendor responsibilities, testing, and accessible alternatives. Its exceptions do not waive obligations imposed by other applicable laws.

Maine Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered agencies must also address Maine’s broader digital-content and revised Section 508 policy.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Maryland Digital Accessibility Policy

Maryland’s Digital Accessibility Policy covers executive-branch departments and agencies and both internal and external IT. It specifies WCAG 2.1 A and AA testing and accessible documents and vendor solutions. Maryland’s nonvisual-access procurement rules also matter. The policy’s older federal-date references must be read alongside the current federal rule and any independent state requirements.

Maryland Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered executive agencies must also apply the state Digital Accessibility Policy to internal and external IT.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Massachusetts Enterprise Digital Accessibility Policy

The Enterprise Digital Accessibility Policy applies to executive departments, certain other entities using EOTSS services, and contracted firms creating or configuring digital assets for covered agencies. It adopts WCAG 2.1 or later at Levels A and AA for specified digital assets and separate standards for authoring tools and hardware.

Massachusetts Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered executive departments and EOTSS-service entities must also follow the Enterprise Digital Accessibility Policy.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Michigan Digital Standards for Websites and Applications

Michigan’s Digital Standards for Websites and Applications require at least WCAG 2.1 AA for state websites and web or mobile applications that are created or procured. The accessibility provisions reach internal-facing systems as well as public-facing services. The standards also establish review requirements.

Michigan Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	State-created or procured websites and apps must also meet Michigan’s WCAG 2.1 AA digital standards.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Minnesota IT Services accessibility standards

Minnesota’s state accessibility standard incorporates WCAG 2.1 AA and selected Section 508 requirements. The WCAG 2.1 update took effect Jul 1, 2024. The state’s statutory guidance connects this standard to state-agency technology obligations; older descriptions treating WCAG 2.1 only as optional are outdated.

Minnesota Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered state-agency technology must also meet Minnesota’s WCAG 2.1 AA and selected Section 508 standards.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Mississippi MS.gov accessibility policy

MS.gov publishes an accessibility policy committing its webpages and services to access for people with disabilities. The cited portal policy does not establish a universal private-sector WCAG version. Public entities still have the specific WCAG 2.1 AA obligation under the federal Title II web rule.

Mississippi Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	MS.gov’s portal commitment does not replace the federal technical requirement for an individual public entity.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Agency guidance is not a universal sector mandate.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Agency guidance is not a universal sector mandate.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Agency guidance is not a universal sector mandate.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Missouri official accessibility policy

Missouri’s official portal identifies a state accessibility law based on Section 508 and a state accessibility standard conforming to WCAG 2.2 AA. Missouri Assistive Technology links these duties to RSMo §161.935 and the development, procurement, maintenance, and use of ICT, including relevant contracts and grants.

Missouri Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered state ICT must also meet Missouri’s WCAG 2.2 AA standard; examine the scope of relevant grants and contracts.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Montana SITSD digital accessibility resource center

Montana’s State Information Technology Services Division provides a digital accessibility resource center addressing the Title II WCAG 2.1 AA requirement and supporting agency implementation. This resource explains government duties; it should not be characterized as a separate technical mandate for every private organization.

Montana Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	SITSD’s implementation resources support this federal obligation; they do not establish a universal private-sector rule.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Agency guidance is not a universal sector mandate.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Agency guidance is not a universal sector mandate.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Agency guidance is not a universal sector mandate.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Nebraska NITC Policy 2-101

NITC Policy 2-101 requires covered state-agency ICT to conform to the revised Section 508 standards, with stated state modifications. Its current text also expressly requires state agencies to follow 28 CFR Part 35, Subpart H, for web and mobile accessibility. That is more precise than an older description treating WCAG 2.1 merely as a recommendation.

Nebraska Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered state agencies must also meet NITC 2-101’s revised Section 508 provisions and express Title II requirements.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Nevada state digital accessibility program

Nevada’s state digital accessibility program identifies WCAG 2.1 AA as the federal technical standard and offers agency resources for websites, documents, mobile content, and testing. The state’s ADA Technology Accessibility Guidelines also address state-entity responsibilities. These government standards are not proof of an identical private-sector mandate.

Nevada Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Use the state digital accessibility program and applicable agency technology guidelines for covered government projects.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: New Hampshire IT Accessibility Policy NHS0305

New Hampshire’s Information Technology Accessibility Policy NHS0305, Version 4, assigns agencies responsibility for accessible IT and compliance with applicable federal accessibility law. Its published material includes monitoring of agency web content against WCAG 2.1. The federal Title II standard is WCAG 2.1 AA for covered web content and mobile apps.

New Hampshire Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered agencies must also apply NHS0305 throughout procurement, development, and content management.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: New Jersey government web accessibility guidance

New Jersey’s Web Presence Hub gives accessibility guidance for government websites, documents, and applications. Some older state pages still reference earlier WCAG versions; use the current federal Title II WCAG 2.1 AA standard and dates for the federal obligation. The New Jersey Law Against Discrimination separately prohibits disability discrimination in covered public accommodations.

Additional civil-rights considerations: Businesses, restaurants, schools, medical providers, and other covered services must consider the LAD as well as federal law. The LAD’s general nondiscrimination provisions should not be described as a universal WCAG 2.1 AA technical regulation.

Additional source: New Jersey Division on Civil Rights: Law Against Discrimination.

New Jersey Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Use the state Web Presence Hub; legacy state pages do not reduce the current federal technical standard.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: New Mexico government accessibility guidance

New Mexico’s Office of Broadband Access and Expansion provides accessibility guidance explaining the federal WCAG 2.1 requirements. Individual agencies may publish their own targets; for example, the Environment Department describes a WCAG 2.2 AA improvement goal. An agency goal is not equivalent to a state statute imposing that version on all organizations.

Agency example: New Mexico Environment Department accessibility statement.

New Mexico Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Agency-specific targets, including the Environment Department’s WCAG 2.2 AA goal, must be distinguished from binding statewide requirements.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Agency guidance is not a universal sector mandate.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Agency guidance is not a universal sector mandate.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Agency guidance is not a universal sector mandate.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: New York NYS-P08-005 accessibility policy

NYS-P08-005 requires WCAG 2.2 AA for covered state-entity ICT and addresses Executive Law §170-f and State Technology Law §103-d. The policy covers state-managed systems and relevant third-party services. It describes Jan 1, 2027 requirements for agency websites and public progress reporting where an agency cannot comply. Newly launched or substantially changed state websites have specific state-law treatment.

New York Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered state-entity ICT must also address NYS-P08-005’s WCAG 2.2 AA requirements and related state-law duties.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: North Carolina Digital Commons accessibility guidance

North Carolina’s Digital Commons guidance identifies a statewide Digital Accessibility and Usability Standard for public-facing websites and online services. The state portal identifies WCAG 2.1 AA in its accessibility framework. The federal rule also covers qualifying web and mobile services supplied through third parties.

Additional source: North Carolina state website accessibility framework.

North Carolina Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered public-facing state services must also follow the Digital Accessibility and Usability Standard.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: North Dakota published IT standards

North Dakota’s published IT standards include an accessibility standard for executive-branch agencies, including the University System Office but excluding other higher-education institutions from that particular standard’s stated scope. NDIT’s accessibility hub supports implementation of the federal rule and identifies the extended state deadline, Apr 26, 2027.

Implementation source: NDIT digital accessibility hub.

North Dakota Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Executive agencies within NDIT’s scope must also apply the state IT accessibility standard.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Campus exclusion from executive IT policy does not remove Title II.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Ohio DOT 2026 document standards and IT-09 guidance

Ohio Administrative Policy IT-09 addresses digital accessibility for state-controlled websites and applications. Current state implementation materials identify WCAG 2.1 AA; older pages describing WCAG 2.0 alone should not be used as the federal target. State content owners and vendors should check the current administrative policy and agency requirements.

Ohio Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	State-controlled websites and apps must also follow current IT-09 and agency implementation requirements.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Oklahoma OMES ICT accessibility standard

Oklahoma’s current Accessibility of Information and Communication Technology Standard applies to state-agency ICT and requires at least WCAG 2.1 AA or the current DOJ-required standard, subject to applicable exceptions. It includes procurement clauses, conformance documentation, verification, designated responsibility, and remediation. Older summaries citing only the state’s WCAG 2.0 adoption are incomplete.

Oklahoma Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered state-agency ICT must also meet OMES’s WCAG 2.1 AA-or-current-DOJ standard and procurement controls.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Oregon website accessibility statement

Oregon’s official accessibility statement identifies WCAG 2.1 AA and ADA Title II. Enterprise Information Services provides implementation resources for government web content and apps. Older state explanatory documents may still list the original federal dates; the current federal regulation governs the extended federal timetable.

Oregon Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Apply the state accessibility statement and EIS resources alongside the federal web and app rule.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Pennsylvania Digital Accessibility Policy

Pennsylvania’s current Digital Accessibility Policy applies to offices, departments, boards, commissions, and councils under the Governor’s jurisdiction and other entities connecting to the Commonwealth Network. It requires revised Section 508 standards and at least WCAG 2.1 A and AA. It also addresses vendor conformance reports, testing, remediation, and contractual obligations.

Pennsylvania Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered Governor’s-jurisdiction and Commonwealth Network entities must also meet the current Digital Accessibility Policy.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Rhode Island accessibility and usability resources

Rhode Island’s published web accessibility resources include legacy W3C Priority 1 and Section 508 references. These establish the state’s accessibility commitment but are not an adequate description of the current federal technical requirement. Covered state and local web content and apps are subject to Title II’s WCAG 2.1 AA rule.

Rhode Island Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Older Priority 1 and Section 508 web resources do not displace the current federal WCAG 2.1 AA requirement.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: South Carolina SC.gov accessibility policy

SC.gov’s accessibility policy describes the portal’s accessibility standards and expressly places responsibility for compliance on individual state agencies and local governments. It also directs agencies and educational institutions to accessibility resources. The federal Title II rule supplies the WCAG 2.1 AA requirement for covered public web content and apps.

South Carolina Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Each agency or local government remains responsible for its services; SC.gov’s portal does not ensure their compliance.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: South Dakota online accessibility policy

South Dakota’s Online Accessibility Policy for State Government identifies BIT web-development standards and references W3C recommendations and federal Section 508 standards. The cited public statement does not identify a distinct current WCAG version binding every organization. Apply the federal Title II WCAG 2.1 AA rule to covered public services.

South Dakota Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered state projects must also follow applicable BIT specifications; the portal policy is not a complete technical checklist.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Tennessee accessibility requirements and standards

Tennessee’s current accessibility statement distinguishes ADA Title II, Section 504, and state adoption of Section 508-based ICT standards. It identifies WCAG 2.1 AA as the federal standard for covered government web content and apps and correctly notes that Section 508 applies directly to federal agencies.

Tennessee Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered state ICT must also address the state’s Section 508-based standards, separately from the federal web and app rule.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Texas DIR procurement and vendor accessibility resources

Texas Government Code Chapter 2054 and 1 TAC Chapters 206 and 213 establish accessibility requirements for covered state agencies and institutions of higher education. DIR’s current procurement guidance states that its contracts require compliance with those authorities and WCAG 2.1 AA. Federal Title II separately governs covered state and local web content and apps.

Additional source: Texas Governor’s Office: access to electronic information.

Texas Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered state agencies must also address Chapter 2054, 1 TAC Chapters 206/213, and applicable DIR purchasing requirements.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Covered higher-education institutions also have state ICT/procurement duties.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Utah Design System accessibility requirements

Utah’s official Design System identifies WCAG 2.1 AA for state agencies under §63A-16-209 and Rule R895-14. It separately explains federal Title II requirements for state and local public entities. Individual agencies can set additional targets, so suppliers should check the contract rather than assume every Utah policy uses the same version.

Utah Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered state agencies must also meet the state WCAG 2.1 AA requirements identified under §63A-16-209 and R895-14.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Vermont universal digital accessibility guidance

Vermont’s Communications and Marketing Office directs state digital content to WCAG 2.1 AA. The state web template supports accessibility, but publishers must maintain it when adding content. The Agency of Digital Services also provides statewide web and accessibility policies.

Vermont Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Use the state’s universal digital accessibility guidance and the agency’s applicable procurement requirements.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Virginia Code §2.2-3502

Virginia’s Information Technology Access Act now addresses accessibility for people with disabilities more broadly than its earlier nonvisual-access focus. Code §2.2-3502 requires covered entities’ ICT to provide equivalent access and conform to 28 CFR §35.200, whether developed internally or procured. VITA also provides procurement and implementation guidance.

Procurement source: VITA update to Information Technology Access Act contract language.

Virginia Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Entities covered by the Information Technology Access Act must also meet §2.2-3502 for internally developed and procured ICT.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Washington WaTech digital accessibility standard

Washington replaced the older Policy 188 framework with Digital Accessibility Policy USER-01 and Standard USER-01-01-S. The current standard specifies WCAG 2.2 AA for covered technology; Washington’s Open Data program identifies the change as effective Jul 1, 2026. Older state pages still referencing 2.1 AA do not fully describe the current standard.

Additional civil-rights considerations: Covered agencies and vendors should check the current standard and contract. Private public accommodations also need to consider the Washington Law Against Discrimination, but that civil-rights law should not be conflated with WaTech’s state-technology WCAG 2.2 requirement.

Additional sources: Washington Open Data accessibility commitment and Washington Human Rights Commission: public accommodations.

Washington Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Covered state technology must also meet USER-01-01-S’s WCAG 2.2 AA standard.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: West Virginia official accessibility statement

WV.gov’s accessibility statement references Section 508 and describes reasonable accommodations and alternate-format requests for state services. This portal statement does not verify a single statewide private-sector WCAG requirement. Covered state and local web content and mobile apps must satisfy the federal Title II rule.

West Virginia Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	WV.gov’s Section 508 statement does not replace the federal web and app rule for individual public services.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Agency guidance is not a universal sector mandate.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Agency guidance is not a universal sector mandate.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Agency guidance is not a universal sector mandate.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Wisconsin.gov website policies

Wisconsin.gov identifies a state website accessibility policy and access commitments. Public higher education also has institution/system-specific requirements; the Universities of Wisconsin publishes guidance referencing WCAG 2.1 AA and System Policy 655. An institutional policy should not be presented as binding every Wisconsin business or every public body.

Education source: Universities of Wisconsin digital accessibility guidance.

Wisconsin Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	Apply the state website policy where relevant; institution-specific standards do not automatically bind every public body.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Universities of Wisconsin: review System Policy 655.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Apply additional state policy only if the entity is within its scope.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

State Source: Wyoming Administration and Information accessibility statement

Wyoming’s Department of Administration and Information publishes a website accessibility statement and links to WCAG resources. This is an agency-specific statement, not verified evidence of a uniform statewide technical mandate for every organization. The federal Title II WCAG 2.1 AA rule applies to covered public web content and apps.

Wyoming Vertical	Covered Organizations	WCAG	Deadline	Additional State Requirement / Scope	Official Sources
Government & public services	State/local agencies, municipalities, courts, special districts	2.1 AA	Title II: 2027/2028; state dates may differ	The Administration and Information statement is agency-specific; other public entities still have the federal obligation.	Title II; State source
Public education	Public K–12, community colleges, public universities	2.1 AA	Title II: 2027/2028	Agency guidance is not a universal sector mandate.	Title II; State source
Healthcare	Public hospitals/clinics; covered HHS-funded providers, including nonprofits	2.1 AA	Title II and/or HHS: 2027/2028	Agency guidance is not a universal sector mandate.	Title II; HHS
Health insurance & managed care	Plans receiving covered HHS assistance; not every insurer	2.1 AA	HHS: 2027/2028	Recipient status controls federal coverage; assess any applicable state duties.	HHS; Recipients
Nonprofits & human services	HHS recipients/subrecipients; public social services; outsourced public-service content	2.1 AA where HHS/Title II applies	HHS and/or Title II: 2027/2028	Other government funding is not an automatic HHS WCAG trigger. Review grant and service terms.	HHS; Recipients; Title II
Public transportation	Public transit entities; covered route, fare, and service-application tools	2.1 AA	Title II: 2027/2028	Agency guidance is not a universal sector mandate.	Title II
Public utilities	Government-operated utilities; covered billing/account/service tools	2.1 AA	Title II: 2027/2028	Private regulated utilities are not automatically public entities.	Title II
Libraries, parks & culture	Government-operated libraries, museums, parks, recreation programs	2.1 AA	Title II: 2027/2028	Independent nonprofits need their own funding/coverage analysis.	Title II
Federal agencies & suppliers	Covered federal ICT; supplier deliverables governed by applicable contracts	2.0 A/AA plus other 508 criteria	Already effective; contract milestones vary	Federal rule applies nationwide. A grant alone does not trigger Section 508.	Section 508
Airlines	Carriers and primary websites meeting DOT’s coverage conditions	2.0 AA	Already effective	Nationwide rule; not a separate state mandate or a rule for every travel business.	DOT rule

How The Rules Apply: Four Illustrative Scenarios

These are hypothetical examples, not client case studies or legal determinations. They show which facts an organization must verify before selecting its standard and deadline.

A Colorado Nonprofit Receives an HHS-funded Subgrant Through The State

The nonprofit should trace the award to HHS and confirm covered-recipient status. If covered, the HHS WCAG 2.1 AA rule and employee-based deadline apply; the state’s role as an intermediary does not make the award state-only funding. It must separately assess any public-service contract and relevant Colorado obligations. Review program applications, eligibility documents, and participant portals. HHS recipient definition; HHS web rule.

A Washington Public University Purchases a Learning Platform

The university’s public status supplies the Title II WCAG 2.1 AA obligation for covered online services, including services delivered through a vendor. Determine the university’s coverage under Washington’s current state standard before assigning an additional WCAG 2.2 AA obligation; do not assume every state IT policy covers every campus. Review enrollment, course content, authentication, and the vendor contract together. Title II; see the sources in the Washington entry.

A Private Healthcare Practice Offers Online Scheduling

First establish whether the practice receives covered HHS assistance. If it does, apply the HHS WCAG 2.1 AA web/app rule. A qualifying public accommodation may also have Title III duties, and Section 1557 may apply to a covered health program. If HHS coverage has not been established, do not assign its technical deadline merely because the business provides healthcare. HHS web rule; DOJ ADA guidance; Section 1557 ICT provision.

A Municipal Utility Uses a Third-party Payment Portal

The municipality cannot exclude the portal from its Title II analysis simply because a vendor operates it. Determine the public entity’s deadline, document the contractual accessibility requirements, and test the complete payment journey. A vendor’s conformance report is evidence to evaluate, not a transfer of the public entity’s legal responsibility. Title II contractual arrangements.

Frequently Asked Compliance Questions

Does every organization in a listed industry have to meet WCAG?

No. Each state table identifies the qualifying organizations within an industry. Public status, covered assistance, a specific regulation, or a contract can create an express technical requirement. A private business may instead have an ADA accessibility duty without a universally prescribed WCAG version. DOJ web guidance.

Does my state require WCAG 2.1 or WCAG 2.2?

Start with the federal rule, then add the state requirement only if your entity or project is within its scope. Some covered state systems use WCAG 2.2 AA while federal Title II and HHS rules incorporate 2.1 AA. A state agency’s aspirational target is not automatically binding law for every organization. Use the state-specific summary and linked source before selecting a version.

Does a federal extension postpone an earlier state or contract deadline?

Not automatically. The revised federal rule governs its own deadline; an independent state policy or contractual milestone needs a separate amendment or applicable legal basis to change. The state summaries flag independent timetables and older source references. Current Title II schedule; current HHS schedule.

Are third-party portals, documents, and mobile apps included?

Covered web content and apps provided through contractual, licensing, or other arrangements are within the Title II and HHS rules. Defined exceptions may apply to particular content, but outsourcing and password protection are not blanket exemptions. Review documents used to apply for or receive services as part of the workflow. Title II; HHS; Title II exceptions.

Does passing a WCAG scan establish ADA compliance?

No. WCAG conformance requires evaluation beyond an automated scan, and legal duties can include effective communication, reasonable modifications, and accessible services outside a website. Combine automated checks with appropriate manual and assistive-technology testing. W3C evaluation overview; DOJ web guidance.

Does an accessibility statement or overlay satisfy these requirements?

An accessibility statement explains commitments and reporting channels; it does not prove that the underlying service conforms. Evaluate any overlay or other tool by whether the actual content and user journey meet the applicable requirements. Do not describe a product installation as an automatic legal exemption or compliance guarantee.

Sources, Review Method, and Update History

This guide prioritizes the current federal regulations, official state statutes and rules, and official state technology policies. Agency statements and implementation guidance are identified separately. Federal requirements are repeated in state tables only to show local coverage; they are not presented as laws enacted by that state.

Where a state source uses a legacy WCAG version or an older federal date, the summary distinguishes that wording from the current federal requirement. State-specific findings are limited to the entities and technology covered by the cited source. An absence of a separately identified rule does not establish that no other law, local ordinance, grant term, or court order applies.

Source checks and legal review are different activities. The source-check date records the research used for this guide. Organization-specific legal conclusions require review of the organization’s actual facts.

Update history — Oct 1, 2026: Expanded the original healthcare-focused guide across covered industries; incorporated current federal deadline extensions; clarified nonprofit and pass-through funding coverage; distinguished state policy from universal private-sector mandates; added comparative tables, a funding decision guide, and illustrative examples.

Turn The Requirements Into an Accessibility Program

Identify your coverage. Record public/private status, public-accommodation activities, employee thresholds, funding agencies, applicable state policies, and contract requirements. Use the rule’s method to determine an entity’s deadline.
Define the required standard for each service. Record the WCAG version and level, covered content, compliance date, and any other ICT requirements. A newer design target can be useful, but still test against the exact standard incorporated into the applicable law or contract.
Inventory complete user journeys. Include websites, mobile apps, PDFs, forms, video, authentication, payment, enrollment, scheduling, learning platforms, and relevant employee systems. Prioritize barriers that prevent people from obtaining essential services.
Test and remediate. Combine automated checks with manual keyboard, screen-reader, visual, and workflow testing appropriate to the product. Validate vendor conformance reports against the version you actually use. A scan or accessibility statement alone does not prove compliance.
Address vendors and exceptions explicitly. Put accessibility requirements, evidence, remediation responsibilities, and ongoing maintenance into contracts. Document the legal basis for any exception or burden determination and provide the access or accommodation still required. Do not assume outsourcing transfers the public entity’s responsibility.
Maintain access. Assign accountable owners, train authors and developers, publish an accessible reporting channel, respond to barriers, and retest after changes. Accessibility is an ongoing service requirement, not a one-time launch task.

Important Limits on Exceptions

The Title II and HHS web rules have defined exceptions for certain archived material, preexisting conventional documents, third-party posts, individualized secured documents, and old social-media posts. These categories have conditions; they are not blanket exemptions for all PDFs, all password-protected services, or all vendor content. For example, documents currently used to access a public program generally do not qualify simply because they are old. Underlying effective-communication and equal-access duties remain.

Sources: 28 CFR §35.201: Title II exceptions and 45 CFR §84.85: HHS exceptions.

Enforcement and Review

Federal ADA and HHS obligations can lead to complaints, investigations, corrective action, and litigation. State civil-rights remedies and procurement consequences vary by jurisdiction and claim. A state’s lack of a separately identified WCAG statute is not a safe harbor. For a multistate organization, review the services and people it reaches, its funding, and its contracts rather than assuming only the headquarters state matters.

This guide reflects the official sources available on the review date. Where a source still displays an older federal deadline or a legacy standard, the entry identifies that issue rather than silently treating it as current. Confirm subsequent amendments and organization-specific application before relying on a deadline or publishing a legal conclusion.

Legal Disclaimer

This is provided for general informational and educational purposes only. It does not constitute legal advice, and ClearPath Access does not practice law or provide legal services. Nothing on this site is intended to create, and receipt of it does not constitute, an attorney-client relationship or a professional legal relationship. Readers should not act or rely on any information on this website without seeking independent legal counsel regarding their specific circumstances.

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