Colorado HB 21-1110 Video Accessibility
Colorado's digital accessibility law has been enforceable for over a year. Here's what it requires for your video content, and what a practical compliance path looks like.
If your agency publishes council meetings, hearings, or any other video online, Colorado's digital accessibility law now covers those recordings. HB 21-1110 (opens in new tab) has been on the books since 2021, and the good-faith grace period offered by HB 24-1454 (opens in new tab) expired July 1, 2025. Every Colorado state and local government entity is now expected to meet the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA (opens in new tab) across digital content, video included. This page walks through what that means for your video and what the practical path to compliance looks like.
HB 21-1110 At a Glance
- Law
- HB 21-1110 (enacted 2021)
- Standard adopted
- WCAG 2.1 Level AA
- Applies to
- State agencies, counties, municipalities, school districts, special districts, and public higher education
- Grace period
- Expired July 1, 2025
- Enforcement
- Private right of action, statutory damages up to $3,500 per violation, per affected individual
- Federal parallel
- ADA Title II, April 26, 2027 / April 26, 2028 deadlines — does not extend Colorado’s obligation
Figures current as of July 14, 2026.
Does HB 21-1110 Apply to Your Video?
Most agencies working through HB 21-1110 compliance start with their websites and forms. That's the right instinct, but video is also in scope, and it comes with requirements that standard web accessibility tools do not address. If your agency publishes meeting recordings, streams council sessions, or hosts any video online, those assets have to meet WCAG 2.1 AA too. That's where the WCAG video requirements come in, and where most agencies find the biggest gap in their current setup.
What Is Colorado HB 21-1110?
HB 21-1110 was signed by Governor Polis on June 30, 2021, making Colorado the first state in the country to enact a standalone digital accessibility law. Two later bills shaped how it works today. SB 23-244 (opens in new tab), signed April 20, 2023, clarified the statute's language on accommodations and sanctions and gave the Office of Information Technology (OIT) its rulemaking authority. HB 24-1454, signed in May 2024, created a conditional grace period. It was not an automatic extension; it offered immunity from liability only to agencies that demonstrated good-faith effort, and it expired July 1, 2025 (see the At-a-Glance summary above).
The law applies to all Colorado state agencies and local government entities: counties, municipalities, school districts, special districts, and public higher education. It reaches public-facing content and internal-facing employee systems alike. It covers vendor-supplied platforms that an agency contracts with, not just the content the agency produces directly.
How Is HB 21-1110 Enforced?
A non-compliant streaming platform purchased from a vendor is the agency's exposure, not the vendor's.
OIT's Technology Accessibility Rules under 8 CCR 1501-11 (opens in new tab) adopt WCAG 2.1 Level AA as the technical standard. Video is explicitly in scope. Enforcement is through Colorado state court via a private right of action under Colorado Revised Statutes 24-34-802 (opens in new tab) (see the At-a-Glance summary above for the current penalty amount).
The federal Americans with Disabilities Act (ADA) Title II rule (opens in new tab) for state and local government digital content runs in parallel. The Department of Justice's Interim Final Rule (opens in new tab) set the current federal compliance deadlines (see the At-a-Glance summary above). Colorado's state law was not extended alongside the federal rule. A Colorado agency relying on the federal dates to delay action has misread its state exposure, because the state obligation is already in force.
What to Do If You're Not in Compliance Today
If your agency hasn't started remediating its video content, you're not alone, and being behind doesn't mean starting from zero. Video accessibility work has historically required specialized staff and production time that most communications and IT teams simply don't have, so a large, untouched archive is the norm right now, not the exception.
The realistic starting point is a prioritized plan, not a finished archive overnight. Most agencies begin with their highest-traffic and highest-stakes content, council meetings, public hearings, and any recording tied to a service residents depend on, then work backward through the rest of the archive. Colorado's law itself recognizes that agencies reach compliance in stages: a documented plan that shows real, ongoing progress is part of the path forward, not just a finished checklist.
That's the shift worth making: the goal isn't a perfect archive by tomorrow. It's a documented, moving plan today, one you can point to if a complaint or an audit comes in.
What Does WCAG 2.1 AA Require for Video?
HB 21-1110 adopted WCAG 2.1 AA, which means four video requirements apply to your government content. Here's what each one means, and the practical path for handling it.
WCAG 1.2.4
Captions (Live)
Live audio in synchronized media must have accurate, synchronized captions. WCAG 1.2.4 requires accuracy sufficient to support equivalent comprehension, which means auto-captions at typical error rates fall short. The captions exist, but they are not compliant captions.
Practical path: The practical path is real-time AI captioning delivered directly into the live stream, with custom vocabulary that handles local street names, agency-specific terms, and Colorado public-figure names. MediaScribe Live is built for the clerk running the meeting, not the broadcast engineer running a control room.
WCAG 1.2.2
Captions (Prerecorded)
All prerecorded video, including your meeting archive, must have accurate synchronized captions. This is the requirement most agencies underestimate, because the backlog is bigger than the going-forward content.
Practical path: The practical path is automated captioning with editing tools designed for non-specialists, so an agency can work through its archive without adding staff. Output formats include SRT (a standard caption file), WebVTT (a caption format built for web video), and plain-text transcripts, so the captions plug into whatever your streaming platform expects.
WCAG 1.2.5
Audio Descriptions
Audio description must be provided for prerecorded video when visual information is essential. HB 21-1110 captures this by reference, because it adopted WCAG 2.1 AA. This is the requirement most Colorado agencies have not yet addressed.
Practical path: Traditional audio description requires professional narrators and weeks of production time per video, which is why most agencies have not started. MediaScribe Narrate uses AI to analyze the video, identify meaningful visual elements (slides, presenter cuts, charts, on-screen graphics), and place descriptions in the natural gaps of spoken dialogue. Hours of archived meeting video get processed in hours, not weeks. Narrate is for pre-recorded and video-on-demand workflows; live meetings run through MediaScribe Live.
WCAG 2.1.1
Accessible Player
The video player itself must be keyboard accessible and support assistive technology.
Practical path: The practical path is an accessible player and standard output formats (SRT, WebVTT, plain text) that come with every deployment, so the player is designed to satisfy the requirement out of the box and integrates with the streaming and meeting platforms your agency already uses.
How AI Audio Descriptions Work
Audio descriptions exist because viewers who are blind or have low vision need a parallel audio track describing the visual information that the spoken dialogue does not cover. Traditional audio description requires professional narrators and weeks of production time per video, which is why most agencies have not started.
MediaScribe Narrate uses AI to analyze the video, identify meaningful visual elements, and generate descriptions placed in the natural gaps of spoken dialogue. The workflow includes AI analysis of visual content and smart dialogue-gap detection, so descriptions never overlap with speech.
What to Look for in an Accessibility Vendor
Not every accessibility vendor is built the same way, and the technical box a product checks on day one isn't the only thing that matters. Accessibility work is ongoing, not a one-time purchase, so a tool backed by a committed team and a clear plan for known gaps is often the safer choice over one that claims a perfect scorecard and offers little else.
A few questions are worth asking before signing anything. What is the support service level? For software solutions, does the vendor provide clear delivery timelines and live status updates? Is there a documented roadmap for known issues, or just a verbal promise? Is there a clear process for reporting a problem and hearing back, with a real response commitment attached? Agencies that ask these questions up front tend to have a much easier time a year in than agencies that stop at a feature list.
A Complete Compliance Solution for Colorado Agencies
MediaScribe addresses WCAG 2.1 AA video requirements that HB 21-1110 brings into scope, in one platform. Live captioning, prerecorded captioning, AI-generated audio descriptions, and an accessible player all sit on the same platform, with a documentation trail that logs accessibility actions automatically. That paper trail is there when OIT compliance checks ask for it, and it's the same record that backs up a good-faith showing if a complaint ever lands.
The platform is built to work with what your agency already runs. Staff work in tools designed for clerks and communications teams, not broadcast engineers.
Live & prerecorded captions
WCAG 1.2.4 and 1.2.2, from live meetings to your full archive.
AI audio descriptions
WCAG 1.2.5 for prerecorded video, processed in hours, not weeks.
Accessible player & outputs
WCAG 2.1.1, plus SRT, WebVTT, and plain-text transcripts out of the box.
Automatic documentation trail
A record that supports a good-faith showing if a complaint or audit arrives.
Key Takeaways
- HB 21-1110 is now enforceable; the good-faith grace period expired in July 2025.
- The law adopts WCAG 2.1 Level AA for video, including archived recordings and live streams, and recognizes a documented, ongoing plan as part of the path to compliance, not just a finished archive.
- Colorado enforces through a private right of action, with statutory damages of up to $3,500 per violation, per affected individual.
- Vendor-supplied platforms are the agency's exposure, not the vendor's, and federal ADA Title II deadlines run in parallel without extending the Colorado obligation.
- The four WCAG video requirements are captions (live), captions (prerecorded), audio descriptions, and an accessible player.
- A documented roadmap and a named technical contact matter as much as a vendor's feature list for long-term compliance support.
Get Colorado-Compliant Before Your Next Audit
HB 21-1110 has been enforceable since 2024, and the grace period closed in 2025. A compliance assessment shows you where your agency stands against the WCAG 2.1 AA video requirements and what it takes to close any open gaps. It's a short conversation, built around your agency, with a clear look at the implementation timeline.
This page is for informational purposes only and is not legal advice. Statutes, rules, deadlines, and penalty amounts may change — verify all information through Colorado OIT's official resources (opens in new tab) and consult qualified legal counsel regarding your accessibility compliance obligations. Figures current as of July 14, 2026.