Washington: WCAG 2.2 AA for state agencies, and vendors held to their reports

The policy and standard bind Washington state agencies. They were adopted by the state chief information officer and approved by the Technology Services Board on 10 December 2024, under the agency's statutory power to set statewide technology standards and policies. Local governments and private businesses are not covered by them.

Covered technology, including free tools and anything substantially modified, must be accessible to people with disabilities directly or through assistive technology. The minimum was WCAG 2.1 Level AA; since 1 July 2026 it is WCAG 2.2 Level AA. From 1 July 2029 the reach widens to every tool an employee or member of the public needs.

Each agency must have its own accessibility policy and coordinator, require annual awareness training for all staff, and keep an IT Accessibility Plan updated at least every year, built with input from people with lived experience of disability.

This is the most demanding procurement text on this list. Agencies must validate accessibility through human user testing, together with a third-party validation report, a VPAT, or documentation of a compliance review against the applicable WCAG level. They must require a remediation plan from the vendor, evaluate its timeline and write contract clauses to enforce it.

The standard reserves the agency's right to reduce or terminate a contract where a vendor fails to respond, remediate or improve accessibility in new releases, or misrepresents the current accessibility of its product. A VPAT that overstates conformance is a contract risk in Washington, not just a sales document.

State law here adds to federal law; it does not replace it. Every city, county, school district and special district in Washington is bound by the federal Title II web rule, 28 CFR 35.200, which requires WCAG 2.1 Level AA on web content and mobile apps: from April 26, 2027 for public entities of 50,000 people or more, and from April 26, 2028 for smaller entities and special districts. State agencies are bound by the same rule at the earlier date.

Private businesses open to the public answer to ADA Title III. A private plaintiff can sue for an injunction and ask for attorney's fees; the Department of Justice can sue for damages and civil penalties. No federal regulation names a web standard for businesses, so audits use WCAG 2.1 or 2.2 Level AA as the working benchmark.

Vendors selling to Washington agencies should test against WCAG 2.2 AA now, publish a remediation plan they can meet, and make sure the VPAT matches what a human tester will find.