Washington accessibility requirements for government vendors

01 — Standard

What the instrument actually requires

• The standard sets Level AA conformance with WCAG 2.1 as the minimum for covered technology, and then raises it: “Effective July 1, 2026, the minimum level of compliance for accessibility is Level AA compliance with WCAG 2.2.” That date has passed, so WCAG 2.2 AA is the operative Washington bar today.

  Source: WaTech USER-01-01-S Digital Accessibility Standard ↗

02 — Coverage

Who it covers, and who it does not

• The standard is issued under RCW 43.105.054, RCW 43.105.052 and the RCW 43.105.020(22) definition of “state agency,” and it replaces the old 188.10 Minimum Accessibility Standard of August 31, 2021. Covered technology is all public-facing digital content and tools — websites, applications, documents and media, blog posts, social media — plus named categories of internal content such as emergency notifications, benefit and eligibility notices, and adjudicative decisions.

  Source: WaTech USER-01-01-S Digital Accessibility Standard ↗

03 — Dates

The dates a bid calendar has to respect

• Adopted by the State CIO and approved by the Technology Services Board on December 10, 2024, with a sunset review date of December 10, 2027.

  Source: WaTech USER-01-01-S Digital Accessibility Standard ↗

• The WCAG 2.2 Level AA minimum took effect July 1, 2026.

  Source: WaTech USER-01-01-S Digital Accessibility Standard ↗

04 — The ask

What it asks a vendor to hand over

• Agency procurement and contracting must build in accessibility validation: human user testing by the agency or a third party, plus a third-party accessibility validation report, or a Vendor Product Accessibility Template, or compliance review documentation evaluating the solution against the applicable WCAG level.

  Source: WaTech USER-01-01-S Digital Accessibility Standard § 4 ↗

• Agencies must “require a remediation plan from the vendor for addressing accessibility issues,” evaluate that plan and its timeline, and determine contractual clauses to enforce it.

  Source: WaTech USER-01-01-S Digital Accessibility Standard § 4 ↗

• Agencies reserve the right to reduce the amount of or terminate contracts where a vendor shows “a lack of accountability to timely response and remediation” — and, in the same clause, where “a vendor misrepresents the current accessibility of their products.” Vendor track record, including contract violations, is weighed in renewals and new procurements.

  Source: WaTech USER-01-01-S Digital Accessibility Standard § 4 ↗

05 — Fit

Where a dated structural scan fits here

Washington put the overlay-industry problem into contract language: overstating your product’s accessibility is grounds to cut the contract. That makes the conservative artifact the commercially safe one. BidShield scans against WCAG 2.1 AA and labels what an automated engine did not test, which is a partial picture of a WCAG 2.2 AA obligation and should be described that way to a Washington agency — as dated evidence of structural testing feeding your remediation plan, not as a conformance statement.

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

• Why Accessibility Overlay Widgets Will Cost You the Contract
• The Vendor Accessibility Roadmap: The Second Deliverable Most Contractors Don't Know They Owe
• VPATs and ACRs: What Procurement Officers Read, and What Bashin Means for Yours
• The state laws that didn't move — the cross-state overview