New York accessibility requirements for government vendors
A rolling WCAG reference and a January 1, 2027 date — with a public progress report as the fallback.
N.Y. State Technology Law § 103-d
01 — Standard
What the instrument actually requires
The section requires “the most current version of the Web Content Accessibility Guidelines, specifically level AA.” It does not pin a version number, so the bar moves as the W3C publishes — it is not frozen at 2.1.
Source: N.Y. State Tech. Law § 103-d ↗
02 — Coverage
Who it covers, and who it does not
“Each state agency shall, to the extent practicable, conform any of their websites, created or modified with changes to form or function after the effective date of this section” — the duty is scoped to state agencies and to sites created or materially changed after the section took effect.
Source: N.Y. State Tech. Law § 103-d ↗
What this means for a SLED contractor
New York City, county and school-district work is outside § 103-d. That does not make it unregulated — Title II still applies, and large New York buyers write their own accessibility clauses — but do not cite § 103-d at a municipal buyer as the source of its obligation.
03 — Dates
The dates a bid calendar has to respect
The compliance date is January 1, 2027. An agency that cannot conform by then must instead post a public progress report by that date, updated annually from the date of the original posting.
Source: N.Y. State Tech. Law § 103-d ↗
04 — The ask
What it asks a vendor to hand over
§ 103-d imposes no document requirement on vendors directly — it is written as a duty on the agency. The vendor-facing ask in New York arrives through the agency’s own procurement and contract language rather than from this section.
Source: N.Y. State Tech. Law § 103-d ↗
05 — Fit
Where a dated structural scan fits here
The progress-report fallback is the interesting part for a vendor. An agency that has to publish, and then annually update, a public account of where it is not yet conforming needs dated evidence from every surface it did not build itself — including yours. Being the vendor who can hand over a current, dated structural-scan record with untested criteria labeled is a good position the first January that report comes due.
BidShield ADA produces a dated WCAG 2.1 AA structural-scan record and an audit-defense log. Automated testing detects only a portion of accessibility barriers and cannot replace manual review, so nothing it produces is a WCAG conformance claim, an ADA or Section 508 compliance certification, an Accessibility Conformance Report, or a legal opinion.
06 — Depth
Go deeper
Have the record before New York asks for it
BidShield ADA's Contractor's Defense Bundle gives you a dated, exportable WCAG 2.1 AA structural-scan and audit-defense log for $299. Not a compliance certification — a defensible record.
Get StartedEvery claim on this page was read from the linked primary source on 2026-07-28. Statutes, rules and agency standards change; check the source before relying on any of it. This page is for informational purposes only and does not constitute legal advice. Consult qualified legal counsel for guidance specific to your situation.