Texas accessibility requirements for government vendors
The new law never says “vendor.” The old rules it points at have expected a VPAT from you since 2020.
Tex. Gov’t Code ch. 2054, Subchapter S (added by HB 5195, 2025) over Subchapter M and 1 TAC ch. 206 and 213
01 — Standard
What the instrument actually requires
The operative Texas conformance target comes from Subchapter M by way of 1 TAC ch. 213, which since April 18, 2020 has required new or changed state-agency web pages and software to meet the standard referenced in the Revised Section 508 rule — WCAG 2.0 Level AA. HB 5195 sets no new technical standard of its own.
Source: Texas DIR — EIR accessibility program ↗
02 — Coverage
Who it covers, and who it does not
HB 5195 adds Subchapter S, “Modernization of State Agency Internet Websites and Digital Services,” obliging each state agency — expressly including institutions of higher education — to assess its websites and digital service portals, with compliance with Subchapter M accessibility standards named as one assessment item.
Source: Tex. HB 5195 (enrolled) ↗
What this means for a SLED contractor
Subchapter S and the 1 TAC rules are aimed at state agencies and public universities. A Texas city, county or ISD is not covered by them, and a contractor who cites HB 5195 to a municipal buyer is citing the wrong instrument.
03 — Dates
The dates a bid calendar has to respect
HB 5195 took effect September 1, 2025. DIR must report to the Legislature not later than November 15, 2026 on the status of agencies’ digital-modernization planning; that reporting section (§ 2054.653) expires January 1, 2027, while the biennial-review provision (§ 2054.654) sunsets September 1, 2031.
Source: Tex. HB 5195 (enrolled) ↗
04 — The ask
What it asks a vendor to hand over
HB 5195 itself never uses the words contractor, vendor or supplier — its duties run to agencies and to DIR. The vendor-facing expectation is Subchapter M’s: agencies and universities must procure technology meeting the standard, and vendors are expected to provide accessibility information for their products, which in practice means a completed VPAT.
Source: Texas DIR — EIR accessibility program ↗
05 — Fit
Where a dated structural scan fits here
The mechanism worth planning around is indirect: an agency cannot report on the accessibility of its permit portal without pulling the record on the permit portal, and the permit portal is your deliverable. Between now and the November report the predictable event is a Texas client asking for a current scan, a VPAT or a “confirm this still meets Subchapter M” note. Having a dated record already on the shelf turns that into an afternoon instead of an unplanned remediation sprint on someone else’s deadline.
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 Texas 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.