Michigan Digital Accessibility Law

WCAG 2.1 AA + Section 508 State-specific law

Michigan has a binding statewide executive-branch digital accessibility standard, DTMB IT Technical Standard 1360.00.11 (SOM Digital Standards for Websites and Applications, effective May 27, 2025), which adopts WCAG 2.1 Level AA and sets an internal target of April 24, 2026 to bring non-conforming state content into conformance. That IT standard is administered by the Department of Technology, Management and Budget and carries no monetary penalty. Separately, the Persons with Disabilities Civil Rights Act (Act 220 of 1976, MCL 37.1101 et seq.) provides a private right of action (MCL 37.1606) against public accommodations and public services, including state and local government and educational institutions, with remedies of injunctive relief plus actual damages and reasonable attorneys' fees, but no fixed statutory-damage amount. Local governments and public universities are reached through the PWDCRA and federal ADA Title II rather than the state IT standard.

What the law requires

  • Responsible agency Michigan Department of Technology, Management and Budget (DTMB) for the statewide IT digital accessibility standard; Michigan Department of Civil Rights (MDCR) administers the Persons with Disabilities Civil Rights Act (michigan.gov/som/digitalstandards) (opens in new tab)
  • Adopted standard WCAG 2.1 Level AA (adopted as the minimum conformance standard for State of Michigan digital content under IT Technical Standard 1360.00.11). The standard tracks the federal ADA Title II web rule; explicit Section 508 alignment language was not confirmed from the official standard text.
  • Who it covers The DTMB IT standard 1360.00.11 applies to State of Michigan (SOM) executive-branch agencies and the websites, applications, software, electronic documents, mobile apps, and media they create or make available. It does not by its own terms govern local governments or public universities. Local/county/municipal government and public higher education are instead covered by the PWDCRA 'public service' provisions (MCL 37.1301 defines public service to include facilities, departments, agencies, boards, or commissions owned/operated/managed by the state or a subdivision, county, city, village, township, or district, and educational institutions as public accommodations) and by federal ADA Title II.
  • Private right of action Yes (under state statute). The Persons with Disabilities Civil Rights Act, MCL 37.1606, provides that a person alleging a violation may bring a civil action in circuit court for appropriate injunctive relief or damages, or both. The DTMB IT standard itself is an internal executive-branch policy with no private enforcement mechanism. Federal ADA Title II is enforced via DOJ and private civil action (injunctive relief; no Title II compensatory-damages floor without intentional discrimination).
  • Statutory damages / penalties None - no fixed statutory damages or per-violation penalty amount. Under MCL 37.1606 a prevailing plaintiff may recover actual damages for injury or loss caused by each violation plus reasonable attorneys' fees (and injunctive relief); damages are determined case-by-case rather than as a set statutory sum. The DTMB IT standard carries no monetary penalty.
  • Exemptions The DTMB standard recognizes an archived-content exception (web content created before the compliance date, kept only for reference/recordkeeping in a designated archive area and unchanged since archiving, need not meet WCAG 2.1 AA), and directs agencies that cannot meet the standard by the enforcement date to work with their DTMB Agency Services team on alternatives. Federal ADA Title II undue-burden and fundamental-alteration defenses, and the Title II archived-content, preexisting-electronic-documents, third-party, and password-protected-course exceptions, also apply. Under PWDCRA, accommodation is excused where it is unrelated to the individual's ability to benefit or where accommodation requirements/limits in the act apply.
  • Governing authority DTMB IT Technical Standard 1360.00.11, SOM Digital Standards for Websites and Applications (effective May 27, 2025), set in policy by DTMB via the Administrative Guide to State Government; Persons with Disabilities Civil Rights Act, Act 220 of 1976 (MCL 37.1101 et seq.), including public accommodation/public service provisions (MCL 37.1301, 37.1302) and the civil-action/remedy provision (MCL 37.1606). Federal ADA Title II (28 CFR Part 35) also applies as a baseline.
  • Compliance deadline The SOM IT standard targets WCAG 2.1 AA conformance for non-conforming digital content before April 24, 2026 (an internal SOM target tied to the federal Title II framework). Federal ADA Title II compliance dates also apply: April 24, 2026 / April 26, 2027 for public entities of 50,000+ population and April 26, 2028 for smaller public entities and special district governments.

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Official sources:
michigan.gov/som/digitalstandards (opens in new tab)
michigan.gov/dtmb/-/media/Project/Websites/dtmb/Law-and-Policies/IT-Policy/13600011-SOM-Digital-Standards-for-Websites-and-Applications.pdf (opens in new tab)
michigan.gov/dtmb/policies/it-policies (opens in new tab)
legislature.mi.gov/Home/RenderDoc?objectName=mcl-Act-220-of-1976 (opens in new tab)
legislature.mi.gov/Laws/MCL?objectName=MCL-37-1302 (opens in new tab)
michigan.gov/-/media/Project/Websites/mdcr/legal/pwdcra.pdf (opens in new tab)
section508.gov/manage/laws-and-policies/state/ (opens in new tab)

Not legal advice. Informational summary compiled from the official sources cited above, last verified 2026-06-08. Requirements change; confirm against the primary source before relying on it. Federal ADA Title II applies regardless of state law (WCAG 2.1 Level AA; compliance April 26, 2027 for entities of 50,000+ population, April 26, 2028 for smaller entities and special districts). See all states.