ADA Title II and Colorado special districts: the dates and the *work*

When is the ADA Title II web accessibility deadline for Colorado special districts?

April 26, 2028 for special districts and public entities under 50,000 people, and April 26, 2027 for larger ones, under the Department of Justice rule as extended in April 2026. Both must meet WCAG 2.1 Level AA, and Colorado's own rule, 8 CCR 1501-11, has applied since June 30, 2025.

We checked these dates on ada.gov on 2026-10-16 (ada.gov web rule guidance; the interim final rule). The interim final rule took effect on April 20, 2026. It pushed each earlier date back by a year. Those earlier dates were April 24, 2026 and April 26, 2027. The dates have moved once, so check ada.gov again before you plan around them.

Who does ADA Title II cover?

Title II is the part of the ADA aimed at state and local government. Counties, cities, towns and school districts are in. So are special districts, the boards that run water, fire protection, libraries and parks and recreation.

The Department of Justice rule says their websites and mobile apps must meet a technical standard. The rule also reaches content that a vendor provides for the entity. So a site a vendor runs for you counts as your content.

What are the dates: April 26, 2027 and April 26, 2028?

• • Population of 50,000 or more: April 26, 2027.
• • Population under 50,000: April 26, 2028.
• • Every special district government: April 26, 2028, whatever its population.

Population means the 2020 Census count for the entity. An independent school district uses its count in the 2022 Small Area Income and Poverty Estimates. An entity with no count of its own uses the government it belongs to (ada.gov, read 2026-10-16).

In our area, Boulder County is on the 2027 date. The Town of Lyons has 2,155 residents, so it is on the 2028 date. So is every fire, water, library and recreation district.

Which standard applies, and what are the five federal exceptions?

The standard is the Web Content Accessibility Guidelines version 2.1, Level AA. Some vendor pages say the rule needs version 2.2. The ada.gov guidance and the Colorado rule text we read both say 2.1.

The federal rule has five exceptions. They cover archived web content, preexisting documents such as PDFs and spreadsheets, content from a truly unaffiliated third party, individualized password-protected documents, and preexisting social media posts. Each one has conditions. A PDF that people use to apply for a service is not exempt just because it is old.

A resident who cannot read an exempt scanned PDF from 2019 can still ask for its contents in a form they can use. The entity has to supply it.

What is Colorado's own rule, 8 CCR 1501-11?

Colorado adds its own layer. State law treats it as discrimination when a public entity fails to meet the accessibility standards set by the Office of Information Technology. It puts the liability for content on the entity that manages that content (C.R.S. 24-34-802, as amended by Senate Bill 23-244, read 2026-10-16).

The Office's rule, 8 CCR 1501-11, has been in effect since June 30, 2025. It covers state and local government and special districts, and it cites WCAG 2.1. It offers several routes to compliance. It asks for a technology accessibility statement and a plan that is updated every year (Colorado Secretary of State rules database, read 2026-10-15).

People who search for HB21-1110 are looking for the 2021 law behind this duty. Senate Bill 23-244 changed it in 2023.

Can someone sue under SB23-244, and what is the $3,500 figure?

Senate Bill 23-244 also lets a person with a disability sue. A court can order compliance. It can award actual damages. Or it can award a fine of $3,500 to each plaintiff for each violation. Violations on one website or app count as a single incident, not many.

Can you contract the duty away to a vendor?

The ada.gov guidance is direct. A public entity "can't contract away its responsibilities" under the ADA. Hiring a web vendor does not move the duty to the vendor.

The guidance suggests three steps. Read every vendor contract that touches web content or apps. Ask vendors for detailed information about how accessible their product is before you sign. Ask for a warranty that the product meets the technical standard and applicable law, with no clause that disclaims it.

What should a district document in the next 18 months?

1. 1. Name who owns accessibility, and write down who approves web content.
2. 2. List every website, web form, PDF library, portal and mobile app, including ones a vendor runs.
3. 3. Sort content by whether an exception may apply, and record why.
4. 4. Test the pages that matter most to residents: payments, permits, meeting notices, records requests and forms.
5. 5. Record each issue found, the fix and the date it was fixed.
6. 6. Review vendor contracts, and ask for accessibility information and warranties.
7. 7. Publish an accessibility statement with a way to report a barrier, and keep an annual plan.
8. 8. Train the staff who post documents and meeting packets.

Small entities can finish this inside one budget cycle if they start now. Many calendar-year governments draft next year's budget from October to December. That is when 2027 money gets set aside. A Focused build at $4,950 sits under the no-bid and direct-purchase lines at several nearby offices. See what we build for local governments and our pricing page.

How Benchford helps: for public-sector builds we build to WCAG 2.1 Level AA at a minimum and aim for 2.2 Level AA. We test against the standard on the schedule in the statement of work, and we write down each fix and its date. That is an effort stated in a contract. It is not a certification, an audit or a promise that an entity meets the rule by a date. Your own advisers and counsel decide that.

Sources: ada.gov web rule guidance (read 2026-10-16), the interim final rule (read 2026-10-16), Senate Bill 23-244 (read 2026-10-16) and the Colorado Secretary of State rules database (read 2026-10-15). Last updated October 16, 2026.