Colorado 21-1110: How to meet it and is your state next?

Handouts Media

Presented at 10:30am in Virtual D on Friday, November 10, 2023.



  • Ken Nakata, Principal, Converge Accessibility
  • Laura Ruby, Consultant, Converge Accessibility LLC

Session Details

  • Length of Session: 1-hr
  • Format: Lecture
  • Expertise Level: Intermediate
  • Type of session: General Conference


Colorado’s 21-1110 requires public entities to ensure that their digital technology is accessible by July 2024—or face lawsuits with penalties starting at $3,500 per claim. Come learn about the law, practical steps Colorado public entities can take to meet it, and how public entities in other states can prepare in the event their state adopts similar legislation.


In June 2021, Colorado passed 21-1110, a comprehensive law designed to strengthen protections for Colorado residents with disabilities. 21-1110 bolstered several provisions of Colorado’s state code. While Colorado law had already permitted plaintiffs to sue state agencies and recover injunctive relief, attorneys fees, and a penalty of up to $3,500, for discrimination on the basis of disability, 21-1110 specified that failing to create an accessibility plan and fully comply with a set of new digital accessibility standards was considered a form of discrimination. 21-1110 also tasked the state’s Chief Information Officer and the Office of Information Technology (OIT) with the job of creating those digital accessibility standards. OIT has issued a technical standard (last reviewed in September 2021) that specified that public entity “web content must align to WCAG 2.1… and at minimum must be developed in a manner which prevents” a set of 37 specific elements of WCAG 2.1 A/AA. Full WCAG 2.1 A/AA compliance by July 2024? A potential avalanche of litigation by plaintiffs’ attorneys spurred on by a $3,500 penalty per claim? As onerous sounding as 21-1110 is for public colleges, universities, and agencies in the state of Colorado, developing a strategy to minimize risk is relatively simple—and a good plan can be put in place easily by the July 2024 deadline. Part of the solution is technological, of course, and involves auditing websites and fixing content. Part of the solution is legal and means developing sound alternate means of accessing the same services available through the web through alternate means. And part of the solution is managerial and requires putting systems in place to streamline the process of ensuring that future information technology is accessible. This presentation focuses on the technological, legal, and managerial solutions that Colorado’s public entities should implement now if they want to avoid liability in July 2024.


  1. Understanding accessibility laws with an emphasis of Colorado 21-1110
  2. Practical steps to avoid liability under Colorado 21-1110… and other accessibility laws
  3. Non-technical ways to provide website accessibility

Disability Areas

All Areas

Topic Areas

Legal, Procurement, Uncategorized

Speaker Bio(s)

Ken Nakata

Ken Nakata is a technology-focused civil rights attorney. His work focuses on web accessibility from both a legal and technical perspective. He also helps organizations manage the change towards accessibility in all aspects-including crafting policies, developing stakeholder ownership, and forging awareness and commitment to the legal and business case supporting accessibility. Ken worked for twelve years as a Senior Trial Attorney with the U.S. Department of Justice. He has argued on behalf of the United States government many times before the federal courts and has helped shape the government’s policies for the Americans with Disabilities Act and Section 508 of the Rehabilitation Act. In addition to litigation, he also helped developed many of the Department’s policies, including Accessibility of State and Local Government Websites to People with Disabilities and which reflects the Department’s current view towards ADA compliance for state and local government websites. Ken is a frequent speaker on both law and technology and is equally adept at conducting one-on-one workshops with programmers and developers as well as explaining law and policy to large audiences. He is a Founding and former Board Member of the International Association of Accessibility Professionals (IAAP). Ken is admitted to the bars of New York, Washington, and the District of Columbia and is a graduate of the University of Pennsylvania Law School. He also received his undergraduate degree in mathematics from the Johns Hopkins University. He is also certified as a privacy professional with the International Association of Privacy Professionals (IAPP), a Certified Professional in Accessibility Core Principals (CPACP) with the IAAP, and a Sun Certified Programmer for the Java 2 Platform.

Laura Ruby

Laura Ruby is one of the world’s leading experts in digital accessibility and communications technology policy. As Microsoft’s Director of Worldwide Accessibility Policy and Standards she developed technology regulatory policy and industry-wide standards that ensure accessible technology for people with disabilities around the globe. Over her 22 years at Microsoft, Laura spearheaded Microsoft’s accessibility compliance program, partnered with governments around the world to develop laws, regulations, and policies that promoted digital accessibility, and collaborated with national and international disability organizations and industry associations. Through this work, Laura helped lead Microsoft’s transformation into a global leader in digital accessibility.

Prior to working at Microsoft, Laura spent ten years at AT&T Wireless Services as a Manager of Law & Government Affairs. At AT&T, she oversaw all Federal disability related regulatory proceedings and advised the company on accessibility compliance matters.


PowerPoint Presentation