Virginia accessibility requirements for government vendors

01 — Standard

What the instrument actually requires

• Covered entities must ensure their information and communications technology gives people with disabilities access “equivalent to that provided to individuals who do not have a disability” and “conforms with the accessibility requirements as provided in 28 C.F.R. § 35.200” — that is, Virginia points at the federal Title II technical standard rather than naming a WCAG version itself.

  Source: Va. Code § 2.2-3502 ↗

02 — Coverage

Who it covers, and who it does not

• The Act runs to “covered entities” — localities of 50,000 or more, institutions of higher education, and state public bodies from April 24, 2026, with special district governments and smaller public bodies following on April 26, 2027.

  Source: VITA — HB 2541 implementation notice ↗

03 — Dates

The dates a bid calendar has to respect

• VITA incorporated the revised accessibility requirements into its Mandatory Core Contractual Terms and applies them to solicitations and contracts negotiated or renegotiated on or after April 24, 2026.

  Source: VITA — HB 2541 implementation notice ↗

• Virginia’s own dates sit in state law and were not moved by the April 2026 federal Interim Final Rule, so the state date for a covered locality currently runs ahead of the federal one.

  Source: Va. Code Title 2.2, Ch. 35 (full chapter) ↗

04 — The ask

What it asks a vendor to hand over

• A vendor either certifies that the product it is supplying conforms, or — if it cannot — the covered entity may require “a current vendor-paid and completed Accessibility Conformance Report indicating the level of conformance” for the technology being procured.

  Source: Va. Code § 2.2-3503 ↗

• The report cannot be self-attested: “The Accessibility Conformance Report shall be completed by a digital accessibility subject matter expert with significant experience with product evaluation or by a qualified neutral third party.”

  Source: Va. Code Title 2.2, Ch. 35 (full chapter) ↗

• “Any areas of nonconformance shall be documented with a vendor-paid and completed Vendor Accessibility Roadmap highlighting areas requiring improved accessibility, including a timeline for each nonconforming area’s completion.”

  Source: Va. Code § 2.2-3503 ↗

05 — Fit

Where a dated structural scan fits here

Virginia is the clearest case for being precise about what this product is. BidShield does not produce an Accessibility Conformance Report, and it cannot satisfy § 2.2-3503’s requirement that a subject matter expert or qualified neutral third party complete one — that is a human evaluation and it has to stay one. What a dated structural scan gives you is the record underneath: which WCAG 2.1 AA success criteria an automated engine could check on your deliverable, on what date, with the untested criteria labeled as untested. That is the input an evaluator works from, and it is the evidence that your Vendor Accessibility Roadmap timeline was written against something real.

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

• VPATs and ACRs: What Procurement Officers Read, and What Bashin Means for Yours
• The Vendor Accessibility Roadmap: The Second Deliverable Most Contractors Don't Know They Owe
• Reading a Vendor's ACR: Ten Questions Before You Inherit the Liability
• The state laws that didn't move — the cross-state overview