State Government ADA Compliance: Key Takeaways from the 2025 NASCIO Report

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Key Findings at a Glance

1Only 1 state has fully implemented a plan for ADA compliance
254% of CIOs have no dedicated funding for accessibility services
334% of states lack dedicated IT accessibility coordinators
4Accessibility climbed to the 6th most important priority in NASCIO's annual CIO survey
5The April 24, 2026 deadline will "open the door to lawsuits"

The State of State Government Accessibility

On February 4, 2026, the National Association of State Chief Information Officers (NASCIO) published a landmark 20-page report from its IT Accessibility Working Group — the product of nine months of research, expert presentations, and working group sessions. The report is a practical roadmap for state and local governments facing the Department of Justice's April 24, 2026 deadline to bring all public-facing websites and mobile applications into compliance with WCAG 2.1 Level AA accessibility standards.

The findings are sobering. As of the CIO survey distributed last July, only one state out of all 50 indicated it had fully implemented a plan for compliance. More than half of state CIOs reported having zero dedicated funding for accessibility services. Over a third of states don't even have a dedicated person leading the work.

This isn't a theoretical problem. The DOJ finalized its ADA Title II rule in April 2024, requiring all state and local government digital content — from websites to mobile apps to PDF documents — to meet specific technical accessibility standards. States and large local governments (serving 50,000+ people) face an April 24, 2026 deadline. Smaller entities have until April 2027. And as Texas Statewide Digital Accessibility Officer Marie Cohan warned in a recent GovTech interview: "When the deadline comes, the door will open to lawsuits."

About the NASCIO IT Accessibility Working Group Report

The NASCIO IT Accessibility Working Group was created to provide a collaborative space for digital accessibility coordinators nationwide as they prepare for compliance with the 2024 DOJ Final Rule. The multi-part paper series, developed from nine months of working group sessions and expert presentations, covers the core components of an enterprise accessibility program:

✓Policy development — Creating clear, enforceable accessibility policies across agencies
✓Procurement integration — Embedding accessibility requirements into vendor contracts and RFPs
✓Remediation planning — Prioritizing which systems and content to fix first
✓Training strategies — Building accessibility competency across government workforce
✓Testing and quality assurance — Establishing automated and manual testing processes

The advisory committee was chaired by Jay Wyant (Minnesota's Chief Information Accessibility Officer) and co-chaired by Marie Cohan (Texas' Statewide Digital Accessibility Officer), with members from Michigan, Maryland, Maine, and Illinois. The report draws on CIO survey data, working group findings, and state-by-state case studies.

The Four Dominant Barriers to State Compliance

NASCIO's research identified four primary challenges that are preventing states from meeting the April 2026 deadline. Each barrier compounds the others, creating a crisis of readiness across state governments.

1. No Dedicated Funding (54% of States)

The single biggest obstacle is money. According to the NASCIO CIO survey, 54 percent of surveyed CIOs reported they did not have any dedicated funding for accessibility services. This is staggering given the scope of work required — every state government operates dozens (sometimes hundreds) of public-facing websites, portals, and applications that must all meet WCAG 2.1 AA standards.

NASCIO Policy Analyst Kalea Young-Gibson identified funding as a "dominant barrier" to compliance. The problem isn't just the initial assessment — it's that remediation can be extraordinarily costly. Enterprise accessibility platforms used by large government agencies typically cost $50,000 to $200,000+ per year, and manual accessibility audits for a single website can run $5,000 to $25,000.

For a state with 100+ agency websites, portals, and applications, the math becomes punishing. Traditional enterprise tools could cost millions annually — budgets that simply don't exist for most states, especially when accessibility must compete with cybersecurity, modernization, and AI initiatives for limited IT dollars.

2. No Accessibility Coordinators (34% of States)

34 percent of states lack dedicated IT accessibility coordinators — the individuals responsible for driving compliance strategy across entire state enterprises. Without a dedicated coordinator, accessibility work falls to already overburdened IT staff who may not have the specialized knowledge needed.

Young-Gibson emphasized that the partnership between a CIO and accessibility coordinator is "the most vital part" of ensuring accessibility across an entire enterprise. If a state does not have an accessibility coordinator, she said, its next step should be to hire one.

The states that have invested in dedicated accessibility leadership — like Colorado, Pennsylvania, and Texas — are demonstrably further along in their compliance journeys. This suggests that the coordinator role isn't a luxury; it's a prerequisite for enterprise-wide progress.

3. Vendor Accountability Gaps

States don't build all their own software. Third-party vendors provide many of the platforms used to deliver government services, and NASCIO found that vendors may not accurately disclose how their products conform to accessibility standards.

Vendor-submitted Voluntary Product Accessibility Templates (VPATs) are the primary mechanism for assessing third-party compliance, but the NASCIO report warns agencies to be cautious. A VPAT showing a product as fully supporting accessibility standards with no qualifying comments "could indicate the VPAT was created by a sales team," the working group warned. The report also flagged that agencies "should be wary of vague and/or AI-generated responses" in vendor documentation.

As Cohan explained: "They have the burden of accessibility in their products, government has the burden of compliance." This disconnect — where vendors control the product but governments bear the legal liability — makes procurement language and contract requirements essential tools for ensuring compliance.

4. Fragmented Governance

The fourth barrier is structural. State governments are complex enterprises with dozens of agencies, each potentially managing their own websites, applications, and digital services. Fragmented governance — where there's no centralized authority or consistent standards for accessibility — makes it nearly impossible to assess the full scope of non-compliance, let alone remediate it systematically.

This is compounded by the sheer volume of digital content. Texas Accessibility Officer Marie Cohan noted that some states have millions of PDFs that need to be assessed and potentially remediated, urging states to follow document retention schedules and purge content that doesn't need to be online to reduce the remediation burden.

State-by-State Readiness: Who's Leading, Who's Lagging

While only one state has fully implemented a compliance plan, some states are demonstrably further along than others. The NASCIO report and recent reporting from GovTech and StateScoop profile three states that illustrate different approaches to digital accessibility — and the factors that differentiate leaders from laggards.

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Colorado: Ahead of the Curve

State-level law preceded federal mandate

Colorado stands out as a national leader in digital accessibility. A state-specific law required all government entities in Colorado to meet accessibility standards by July 2024 — nearly two years before the federal deadline. And Colorado's requirements go further than the DOJ rule.

"The federal rules are just for public-facing websites, web content, mobile sites, and mobile content," explained Karen Pellegrin, senior program manager for Colorado's Technology Accessibility Program. "For Colorado, it goes way beyond that; it's both internal and external products."

Colorado's approach includes the Empathy Lab, which Pellegrin described as a think tank enabling government to work with people with lived experiences from the disability community. The state has also shifted accessibility work to start earlier in the technology lifecycle by embedding accessibility language in contracts, "creating the foundation" to prevent issues before they arise.

The lesson from Colorado: accessibility needs to be built in from the start, not bolted on after the fact. And it helps immensely when state law creates earlier deadlines and broader requirements than federal mandates.

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Pennsylvania: Ahead of Schedule

Baseline testing on track by March 2026

Pennsylvania is another bright spot. The state's Chief Accessibility Officer Kris Adams reported that Pennsylvania is ahead of both its own June internal deadline and the DOJ's April deadline, with baseline testing for high-impact applications on track to finish by March 2026.

Pennsylvania's success stems from institutional investment in digital experience. The state created the Commonwealth Office of Digital Experience specifically to support the accessibility and user experience of digital services through a lens of human-centered design. A shared ownership model spreads accessibility responsibility across state government rather than isolating it in a single team.

"It's just as important as security," Adams said of digital accessibility. "It needs to be embedded in the software development life cycle."

Adams offered practical advice for states further behind: "There's no better time than to start now." The deadline, he explained, serves as a milestone rather than the finish line — inclusion work is ongoing.

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Texas: Federated Model, New Legislation

Agencies self-managing with state-level coordination

Texas takes a different approach. With a federated governance model, the Department of Information Resources (DIR) issues rules, but each state agency is responsible for its own compliance timeline. DIR's Statewide Digital Accessibility Officer Marie Cohan leads coordination across this decentralized landscape.

"No one is going to be 100 percent compliant," Cohan acknowledged, while noting that state agencies and universities are in a good position. Many are actively working on PDF remediation and website redesigns. Texas is also working to implement a new statute (HB 5195) that would improve web accessibility standards, currently in the rulemaking process.

Cohan co-chaired NASCIO's accessibility working group and participates in a multistate collaborative, sharing best practices and solutions to common challenges across state lines. She emphasized practical risk management: states should document everything they're doing toward compliance, and IT leaders should conduct risk assessments to identify agencies most at risk of non-compliance and ensure action plans for "April 25 and beyond."

On the volume challenge, Cohan urged states to follow retention schedules and purge documents that don't need to be online: "state retention cycles should be followed closely so that documentation that is not required to be on a website can be purged to reduce the number of PDFs — millions, in some cases — that need to be addressed."

The Broader State Landscape: Where the Other 47 States Stand

Beyond Colorado, Pennsylvania, and Texas, the NASCIO report and CIO survey paint a concerning picture for the remaining states. While the specific state that reported full compliance wasn't named, we can assess the broader landscape based on available data:

States With Dedicated Coordinators (~66%)

Approximately 33 states have dedicated IT accessibility coordinators — a critical first step, though having a coordinator doesn't mean compliance is achieved. These states have at minimum established organizational responsibility for accessibility.

States Without Coordinators (~34%)

Roughly 17 states lack a dedicated accessibility coordinator entirely. For these states, accessibility work either isn't happening systematically or falls to general IT staff without specialized expertise.

States With Own Accessibility Laws

States like California, Colorado, and Illinois have state-level accessibility laws that may exceed federal requirements. These states tend to be further along because they've been working toward compliance for longer.

Accessibility as NASCIO Priority #6

In NASCIO's most recent membership survey, accessibility climbed to the 6th most important priority for state CIOs — behind cybersecurity, modernization, digital services, and AI (which topped the list for the first time). Awareness is growing, but budget allocation hasn't followed.

The NASCIO working group's advisory committee included accessibility leaders from Minnesota, Texas, Michigan, Maryland, Maine, and Illinois — representing states that have invested in dedicated accessibility roles. But these are the exception, not the rule. Many states, particularly in the South and Midwest, have been slower to establish formal accessibility programs.

For specific state-by-state accessibility requirements and readiness assessments, see our state guides for California, New York, and all 50 states.

After April 24: "The Door Will Open to Lawsuits"

The most urgent warning from the NASCIO findings and GovTech reporting is what happens after the deadline passes. Multiple state accessibility leaders emphasized that the deadline is a beginning, not an end.

The Litigation Risk Is Real

Marie Cohan stated plainly: "When the deadline comes, the door will open to lawsuits, and states will be managing litigation risks." She added that IT leaders are already talking about risk assessment to support agencies at risk of non-compliance and ensure they have an action plan: "That's the unknown, and I think that's where a lot of action is going to happen."

The litigation landscape for government accessibility is already active and growing. ADA website lawsuits have surged in recent years, and state governments present particularly attractive targets because Title II provides clear grounds for action and prevailing plaintiffs can recover attorneys' fees.

Accessibility Is an Ongoing Commitment

Colorado's Karen Pellegrin likened accessibility to cybersecurity — "it never goes away" — calling it "an ongoing and evolving area of technology in which IT leaders must continually invest." This framing is critical: compliance isn't a one-time checkbox but a continuous process of testing, monitoring, and remediation.

Cohan echoed this sentiment: "The deadline is going to come and go... Having a plan in place and roles assigned for the work that follows it is essential." She added that she hopes accessibility remains a "foundational pillar for technology" alongside security and privacy.

Looking ahead, NASCIO's Young-Gibson predicted that accessibility is likely to intersect with other "hot-button" technology issues, including AI and cybersecurity — further embedding it in the fabric of government technology operations.

Beyond Compliance: Why This Actually Matters

It's easy to reduce accessibility to a compliance checkbox. But the human stakes are enormous. According to the CDC's Behavioral Risk Factor Surveillance System, 29% of Americans have at least one disability, including 14% with a cognitive disability. More than 1 in 4 U.S. adults rely on accessible digital services to interact with their government.

Cohan illustrated the real-world impact through Texas's experience with natural disasters: "People who have disabilities are typically the last to find out or they're stranded or trapped or they don't have power and they need a machine that needs power to operate to help them live or to administer medication or to communicate with the outside world."

Accessible government services aren't just legally required — they're essential infrastructure. When a government website is inaccessible, it means a blind veteran can't file for benefits, a deaf parent can't register their child for school, or a person with a mobility impairment can't renew their driver's license online. These aren't edge cases; they represent millions of Americans.

There's even a financial argument: Cohan noted that people with disabilities increasingly start their own businesses, paying sales tax, franchise tax, and unemployment taxes. Making government forms accessible for permits, applications, and tax filing could be indirectly profitable for states. As she put it: "When you design for people with accessibility, when you design with that in mind, you're actually helping the rest of the population."

NASCIO's Recommendations for States Behind Schedule

For the majority of states that will not be fully compliant by April 24, NASCIO and the accessibility leaders interviewed by GovTech and StateScoop offered practical guidance. The working group's report encourages states to:

1. Secure Leadership Buy-In

NASCIO emphasizes starting with governance — clarifying roles and securing stakeholder buy-in to support policy adoption. The CIO-accessibility coordinator partnership is "the most vital part" of enterprise-wide progress.

2. Keep Policy Simple

The StateScoop coverage of the report highlighted NASCIO's advice to "keep it simple" on policy. Overly complex policies stall implementation. Create clear, enforceable standards that agencies can actually follow.

3. Prioritize High-Impact Systems First

You can't fix everything at once. Focus on the systems used by the most people for the most critical services — tax portals, benefits applications, permit systems, and emergency information.

4. Embed Accessibility in Procurement

Update RFP language and contracts to require accessibility compliance from vendors. Scrutinize VPATs carefully — be wary of reports that show full conformance with no qualifying comments, as these "could indicate the VPAT was created by a sales team."

5. Document Everything

Colorado's Pellegrin advised states not yet compliant to "document everything they're doing to get there." This documentation demonstrates good faith effort and can be critical in litigation defense.

6. Establish Shared Responsibility

Accessibility can't be one team's problem. Pennsylvania's shared ownership model and NASCIO's emphasis on "shared responsibility" across agencies reflect the reality that every content creator, developer, and procurement officer plays a role.

7. Start Automated Monitoring Now

Automated accessibility scanning provides immediate visibility into the scope of non-compliance across all digital properties. It won't catch everything (manual testing is still needed for roughly 30% of WCAG criteria), but it establishes a baseline and enables continuous monitoring as content changes.

The Vendor Problem: VPATs, AI-Generated Reports, and Accountability

One of the most actionable findings from the NASCIO report relates to vendor management. State governments rely heavily on third-party vendors for everything from content management systems to citizen service portals, and the accessibility of these products directly impacts state compliance.

The report identifies several red flags in vendor accessibility documentation:

⚠Full conformance with no comments — A VPAT showing 100% support with no qualifying notes likely wasn't completed by someone who actually tested the product
⚠AI-generated responses — NASCIO explicitly warns against vague or AI-generated VPAT responses that don't reflect actual product testing
⚠No standardized scoring — Unlike cybersecurity frameworks, accessibility reporting lacks a standardized, objective scoring scale, making vendor self-reporting inherently unreliable

The takeaway for state procurement officers: don't trust vendor claims at face value. Independent testing and monitoring of vendor-provided platforms is essential. Tools like RatedWithAI's free accessibility checker can independently verify vendor claims by scanning the actual deployed product against WCAG 2.1 AA criteria.

The Cost Problem: Why 54% of States Can't Afford Traditional Solutions

The funding gap identified by NASCIO is directly tied to the cost structure of traditional enterprise accessibility tools. Let's look at the math that makes compliance feel impossible for most state budgets:

Traditional Enterprise Tools

$50K–$200K+/yr

• Annual contracts required
• Per-page or per-domain pricing
• Implementation takes 3–6 months
• Separate cost for remediation services
• Complex procurement process needed

Modern Automated Monitoring

$29/mo

• No annual contract
• Continuous monitoring included
• Scan results in minutes
• Actionable remediation guidance
• Start immediately, no procurement delay

For a state agency with a dozen websites, the traditional approach could easily cost $100,000+ annually — money that 54% of states simply don't have allocated. But modern tools have fundamentally changed the economics. Automated WCAG scanning and continuous monitoring can be deployed for orders of magnitude less, covering the roughly 70% of WCAG criteria that can be tested automatically.

This doesn't eliminate the need for manual testing and remediation, but it dramatically reduces the barrier to getting started. A state agency can establish baseline compliance monitoring across all its properties for the cost of a single lunch meeting — rather than waiting months for a procurement cycle to approve a six-figure enterprise contract.

Practical Action Plan for State Agencies (58 Days to Deadline)

With less than two months until the April 24, 2026 deadline, here's a realistic action plan for state agencies that are behind:

Week 1: Baseline Assessment

Run automated accessibility scans across all public-facing websites and applications. Use a tool like RatedWithAI's free accessibility checker to get immediate WCAG 2.1 AA compliance scores. Document every result — this becomes your baseline and evidence of good-faith compliance effort.

Week 2: Triage and Prioritize

Rank all digital properties by public impact (traffic volume, critical services). Focus remediation on the highest-impact systems first — per NASCIO's guidance. Identify and categorize violations by severity (critical, serious, moderate, minor).

Weeks 3–6: Fix Critical Violations

Address the most impactful WCAG failures first: missing alt text, form labels, color contrast, keyboard navigation, and page structure. These are the most common failures and often the easiest to fix. Purge unnecessary documents per Cohan's advice — follow retention schedules.

Weeks 7–8: Vendor Accountability

Review all third-party vendor platforms for accessibility. Request current VPATs and independently verify claims. Update contract language to include WCAG 2.1 AA requirements per NASCIO's procurement checklist.

Ongoing: Continuous Monitoring

Set up continuous accessibility monitoring. Websites change constantly — new content, updated pages, redesigned components — and each change can introduce new violations. Automated monitoring catches regressions before they become litigation risks.

What This Means for Local Governments Too

While the NASCIO report focuses on state-level compliance, the DOJ's ADA Title II rule applies equally to all state and local government entities. Cities, counties, school districts, public universities, transit authorities, and any other government-funded organization face the same WCAG 2.1 AA requirements.

If state governments — with their dedicated IT departments, accessibility coordinators, and enterprise resources — are struggling this badly, imagine the situation for a city of 60,000 with a two-person IT department. The April 2026 deadline applies to these entities too, and they have even fewer resources to work with.

Smaller local governments (under 50,000 population) have until April 2027, but that extra year will evaporate quickly. The time to start is now, regardless of which deadline applies to your entity. For a complete breakdown of ADA Title II requirements and deadlines, see our comprehensive guide.

Accessibility as Infrastructure: The Cybersecurity Parallel

Multiple leaders quoted in the NASCIO research drew explicit parallels between digital accessibility and cybersecurity — and the comparison is instructive.

A decade ago, many state governments treated cybersecurity as an afterthought. Today, it's the #1 priority in NASCIO's annual CIO survey, with dedicated budgets, staff, and governance structures in every state. Accessibility is following the same trajectory, having just climbed to #6 on NASCIO's priority list.

Pennsylvania's Adams captured it perfectly: "It's just as important as security. It needs to be embedded in the software development life cycle." And Cohan expressed hope that accessibility will become "a foundational pillar for technology" alongside security and privacy.

The implication: states that treat accessibility as a one-time project to check off by April 2026 will find themselves in the same position as states that treated cybersecurity as a one-time audit. True compliance requires continuous investment — automated monitoring, regular testing, ongoing training, and embedded processes throughout the technology lifecycle.

Your State's Deadline Is 58 Days Away

The NASCIO report makes one thing clear: most states aren't ready. But you don't need a six-figure enterprise contract to start. RatedWithAI provides continuous WCAG 2.1 AA monitoring at a fraction of the cost of traditional government accessibility tools.

$29

per month

vs. $50K+/yr enterprise tools

5 min

to first scan

vs. months of procurement

24/7

continuous monitoring

vs. annual point-in-time audits

Free Accessibility Check →Government Solutions

Sources and Further Reading

• NASCIO IT Accessibility Working Group in Review: A Guide to DOJ Final Rule Compliance (February 2026)
• "Are States Ready for the Approaching Accessibility Deadline?" — GovTech (February 25, 2026)
• "Digital accessibility working group encourages states to 'keep it simple' on policy" — StateScoop (February 4, 2026)
• NASCIO Guide to DOJ Final Rule Compliance (PDF)
• CDC Disability and Health Data System

Related Guides

Compliance Guide