The Extension That Doesn’t Apply to You
On April 20, 2026, the U.S. Department of Justice published an Interim Final Rule extending the ADA Title II web accessibility compliance deadlines by exactly one year. For public entities across most of the country, that’s real breathing room. Headlines celebrated the extension. Compliance teams exhaled.
For Colorado public entities, it’s mostly noise.
If you’re a Colorado state agency, local government, school district, or special district, the federal extension doesn’t change your compliance obligations. You’ve been legally required to meet web accessibility standards since July 1, 2025—nine months ago. The federal deadline wasn’t your deadline. Colorado’s was.
Here’s what the DOJ extension actually does, what it doesn’t do, and why Colorado public entities need to keep working on accessibility regardless of what’s happening at the federal level.
What the Federal Extension Does
The 2024 final rule from DOJ required state and local governments to bring their websites and mobile apps into conformance with WCAG 2.1 Level AA—the accepted technical standard for web accessibility—by set deadlines based on population.
Original federal deadlines:
- Large public entities (population 50,000+): April 24, 2026
- Smaller public entities and special district governments: April 26, 2027
The Interim Final Rule, signed by Acting Attorney General Todd Blanche on April 16 and effective on publication four days later, moves both dates back by one year:
New federal deadlines:
- Large public entities (population 50,000+): April 26, 2027
- Smaller public entities and any special district government: April 26, 2028
A 60-day public comment window follows publication. DOJ cited practical challenges—acknowledging it had overestimated how fast covered entities could comply and how mature the supporting technology really is—along with concern that rushed compliance efforts would expose entities to private lawsuits without actually advancing accessibility.
What the Federal Extension Does NOT Do
Three things are worth understanding clearly.
1. The Technical Standard Didn’t Change
WCAG 2.1 Level AA is still the bar. The scope, exceptions, and substantive obligations in the 2024 rule are all intact. Only the deadline moved.
If you were working toward WCAG 2.1 Level AA conformance, that’s still the target. The extension doesn’t reduce the requirements—it just gives entities more time to meet them.
2. The Underlying ADA Obligation Is Not on Pause
The deadline extension is about the specific 2024 regulation, not the 1990 statute behind it. Providing accessible services, programs, and activities has been an ADA obligation for 36 years, and that hasn’t changed.
Public entities are still required to ensure people with disabilities have equal access to their services. The regulatory deadline extension doesn’t suspend that fundamental obligation.
3. The ADA Carries a Private Right of Action
This is the most practically important point: private individuals can still sue public entities for inaccessible digital services regardless of where the DOJ’s regulatory deadline sits.
A delay in the compliance deadline doesn’t delay lawsuits. If your website or mobile app is inaccessible and that creates a barrier for someone with a disability, they can sue under the ADA right now. The extension doesn’t create a safe harbor from litigation.
DOJ has also signaled it may issue a separate rulemaking during the extension period that could revise parts of the 2024 rule. So the standard isn’t necessarily frozen in place—just on pause while they reconsider some elements.
The Colorado Layer Changes Everything
If you’re a Colorado public entity, none of the above is the story that matters. Colorado has had its own digital accessibility law on the books since 2021, and it’s been fully enforceable since July 1, 2025.
HB21-1110 — Colorado Laws for Persons with Disabilities originally carried a compliance deadline of July 1, 2024. That was extended one year to July 1, 2025 by HB24-1454 (commonly known as the Grace Period Bill).
The Colorado Office of Information Technology finalized its Rules Establishing Technology Accessibility Standards in May 2025, effective June 30, 2025. The grace period expired the next day.
Translation: Colorado state and local government entities have been legally required to comply with the state accessibility standard since July 1, 2025. The federal extension doesn’t move that date.
Where state and federal rules overlap, you’re bound by whichever is stricter. In this case, Colorado crossed the finish line first—and stayed there.
Where Colorado Is Actually Tougher
Colorado’s law goes beyond the federal rule in a few important ways.
Broader Scope
Federal Title II covers: Web content and mobile apps
Colorado HB21-1110 covers: Websites, intranets, mobile apps, digital documents, kiosks, signage, videos, audio content, and third-party tools
Critically, Colorado’s law covers both public-facing and internal-facing content. Your staff intranet counts. Your internal SharePoint site counts. The forms your employees use to do their jobs count.
If it’s digital and it’s used by your organization, Colorado expects it to be accessible.
Private Enforcement with Teeth
Colorado has no central enforcement agency for this law. Enforcement runs through the courts via private civil actions.
Any individual with a disability who experiences discrimination due to inaccessible technology can sue directly in Colorado state court.
Remedies include:
- Court-ordered remediation
- Actual monetary damages
- A statutory fine of $3,500 per violation payable to the plaintiff
Each accessibility barrier a user encounters can constitute a separate violation. A poorly remediated website with multiple accessibility issues can produce significant exposure very quickly.
Same Technical Standard
At least the technical target is consistent: WCAG 2.1 Level AA, same as the federal rule.
That means audit tools, testing methodologies, and remediation guidance developed for federal compliance work for Colorado compliance too. You’re not learning two different technical standards—just navigating two different regulatory frameworks.
What Compliance Actually Looks Like Under Colorado Rules
The OIT rules define five pathways to compliance. You don’t have to hit all of them, and the standard isn’t strict technical perfection.
Colorado’s five compliance pathways:
- Conform with WCAG 2.1 AA — Full technical conformance is the gold standard
- Provide an accessible alternate version of inaccessible content — If the primary version can’t be fixed immediately, offer an accessible alternative
- Provide reasonable accommodations on request — Responsive process for helping users who encounter barriers
- Document that the technology in use is the most accessible option meeting business needs — “We evaluated alternatives and this is the best available”
- Demonstrate ongoing progress through an annual accessibility plan — Show you’re working toward full conformance systematically
Most small public entities lean on some combination of pathways 3, 4, and 5 while working toward full conformance over time.
The rules also require a published technology accessibility statement with at least two methods of contact for assistance, and a clear process for users to request accommodations or report barriers.
Courts evaluating whether an entity acted in good faith will look for evidence: systematic testing, documented remediation work, a responsive accommodation process, and real leadership commitment. Paper compliance without actual work behind it doesn’t protect anyone.
A Quick Warning About Overlay Widgets
It’s tempting, especially under deadline pressure, to drop in an accessibility overlay or widget (UserWay, accessiBe, AudioEye, and similar products) and call the job done.
Don’t.
These tools layer JavaScript on top of existing content and can help with some edge cases, but they don’t remediate underlying accessibility defects. They can’t add meaningful alt text to images, fix broken heading structure, or correct malformed ARIA attributes.
Courts and the accessibility community generally don’t treat overlays as substitutes for real WCAG conformance—and websites relying primarily on overlays have been frequent lawsuit targets in recent years.
Why overlays fail:
- They can’t fix content that’s fundamentally inaccessible (missing alt text, poor document structure, keyboard traps)
- They introduce new accessibility barriers for some users (unexpected behavior, conflicts with assistive technology)
- They create a false sense of security (“we installed the widget, we’re compliant”)
Use overlays as supplements to real work if you want, but not as your compliance strategy. The work has to happen at the content and code level.
Practical Steps to Take Now
If you’re a Colorado public entity that hasn’t formally addressed accessibility yet, the priorities are straightforward.
1. Audit Your Digital Properties
Start with your public website, then move to digital documents (PDFs are often the biggest offenders), internal tools, and any third-party platforms you link out to.
Free tools like WebAIM’s WAVE are a reasonable starting point, but understand their limitations. Automated tools catch maybe 25-30% of real accessibility issues. A thorough audit needs a mix of automated scanning and manual expert review.
Things automated tools miss:
- Whether alt text is actually meaningful (tools can detect missing alt text but not whether “image1.jpg” is useful)
- Logical reading order and content structure
- Keyboard navigation usability
- Color contrast in dynamic states
- Screen reader experience quality
2. Publish a Technology Accessibility Statement
This is a baseline requirement under the OIT rules and one of the easiest items to check off.
Your statement should include:
- Your organization’s commitment to accessibility
- The accessibility standard you’re working toward (WCAG 2.1 Level AA)
- At least two methods of contact for accessibility assistance (email, phone, form)
- A clear process for requesting accommodations or reporting barriers
- Honest acknowledgment of known limitations and ongoing remediation work
Put this on your website in an easy-to-find location (footer link is common). Update it as your accessibility posture changes.
3. Start Documenting Everything
Keep records of:
- Audit results and remediation tickets
- Training provided to staff
- Accommodation requests and how you responded
- Vendor accessibility conformance documentation for third-party tools
- Annual accessibility plans and progress reports
This documentation is your good-faith evidence if a complaint surfaces. It’s worth a lot more than a policy binder nobody has touched.
4. Build a Real Remediation Plan
Don’t try to fix everything at once. Prioritize based on impact and risk:
High priority:
- High-traffic pages (homepage, service applications, payment pages)
- Critical public services (permit applications, meeting notices, emergency information)
- Templates and design systems (fixes here cascade to everything using the template)
Medium priority:
- Frequently accessed internal tools
- Common document types (board meeting agendas, budget reports)
- Third-party integrations (payment processors, form builders, calendars)
Fix templates and design systems before chasing individual content items. A fix to your page template might remediate hundreds of pages at once.
5. Get Legal Counsel Involved Early
The questions of which entities are covered, which compliance pathway best fits your organization, and how to document good-faith effort all benefit from a lawyer who understands Colorado’s specific framework.
Don’t wait until you receive a complaint letter to talk to an attorney. Proactive legal guidance is much cheaper than reactive defense.
The Bottom Line
The federal extension is real news nationally, but for Colorado public entities it’s background noise. The binding constraint is state law, and state law already expects you to be compliant—or to be clearly on a path to it with documented progress.
If the federal delay gave you a flicker of relief, the honest move is to redirect that energy into the work the state has been expecting for the better part of a year.
Accessibility is still the standard. The clock didn’t stop in Colorado. And the sooner an entity takes that seriously, the smaller its legal exposure and the better its digital services become for every resident who needs to use them.
Colorado crossed the finish line in July 2025. The federal government pushing back its own deadline doesn’t change when you were supposed to start running.
Need Help With Web Accessibility Compliance?
At Castle Rock Sky, we help Colorado public entities and nonprofits navigate web accessibility requirements without getting lost in the technical weeds.
We can:
- Audit your public website and digital properties for WCAG 2.1 Level AA conformance
- Identify and prioritize remediation work based on risk and impact
- Fix underlying accessibility issues in your website code and content
- Help you publish a compliant technology accessibility statement
- Document your good-faith accessibility efforts for legal protection
- Train your staff on creating accessible content going forward
- Review third-party vendor accessibility conformance documentation
If you’re a Colorado public entity trying to understand your accessibility obligations or catch up on overdue compliance work, we can help.
Schedule a web accessibility assessment
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This post summarizes current federal and Colorado regulatory requirements around digital accessibility as of April 2026 and does not constitute legal advice. Consult qualified legal counsel for guidance on your specific situation.
