New York has state-specific digital accessibility law beyond the federal ADA Title II baseline: State Technology Law Section 103-d and Executive Law Section 170-f require state-agency websites and the websites of state contractors/vendors to conform to the most current WCAG (currently 2.2) Level AA by January 1, 2027, implemented through NYS Office of Information Technology Services (ITS) policy NYS-P08-005, which also enforces the federal DOJ ADA Title II WCAG 2.1 AA requirement and calls for vendor VPATs during software procurement. Crucially, these procurement statutes create no private right of action and impose no statutory damages or per-violation fines; the only stated consequence of non-compliance is a publicly posted annual progress report, so enforcement is administrative and contractual via ITS oversight and procurement clauses. Broader digital-accessibility lawsuits in New York instead proceed under the federal ADA and the State/NYC Human Rights Laws, which are separate public-accommodation statutes rather than these ICT-procurement provisions.

What the law requires

• Responsible agency New York State Office of Information Technology Services (ITS), Office of Digital Transformation / Digital Experience Bureau (its.ny.gov/accessibility-information-communication-technology) (opens in new tab)
• Adopted standard WCAG 2.2 Level AA for state-agency websites and third-party/contractor websites under STL 103-d and Exec Law 170-f (deadline Jan 1, 2027). Separately, WCAG 2.1 Level AA for all web content and mobile apps under the federal DOJ ADA Title II rule (28 CFR Part 35), per NYS-P08-005, by Apr 24, 2026. Policy also references Section 508 / VPAT: vendors should supply a VPAT during procurement of pre-built software with a user interface; statute auto-adopts 'the most current version of WCAG ... or any successor.'
• Who it covers State Entities / State Agencies as defined in Executive Order 117 and STL Section 101, including their employees and ITS. Extends to all third parties (local governments, consultants, vendors, and contractors) that use or access an IT Resource for which the State Entity or ITS has administrative responsibility, including third-party-hosted systems. Executive Law 170-f independently binds any contractor, subcontractor, vendor, consultant, or other person providing services under a state contract as to websites they provide for those services. Note: STL 103-d applies to state-agency websites; it does not by its terms mandate accessibility for independent municipal/county or public-university websites unless they fall within the State Entity / state-contract definitions, though the federal ADA Title II rule independently covers all state and local government entities (including public higher education).
• Private right of action No - neither STL Section 103-d nor Executive Law 170-f creates a private right of action or names a damages remedy; STL 103-d's only stated consequence for non-compliance is a public written progress report. Enforcement is effectively administrative/contractual via ITS policy and state procurement clauses. (Separately, individuals may pursue digital-accessibility claims against public accommodations under the federal ADA and the NY State Human Rights Law / NYC Human Rights Law, but those are general disability-discrimination statutes, not these ICT-procurement provisions.)
• Statutory damages / penalties None in the ICT-procurement statutes - STL 103-d and Exec Law 170-f specify no per-violation fines or statutory damages; enforcement is policy/contract-driven (progress reports, procurement contract clauses) under ITS oversight.
• Exemptions Under NYS-P08-005 the federal DOJ Rule exceptions apply to the WCAG 2.1 obligation: archived web content; preexisting conventional electronic documents (unless used to apply for/access/participate in services); content posted by a third party; individualized, password-protected or otherwise secured conventional electronic documents; and preexisting social media posts. STL 103-d obligations apply 'to the extent practicable,' and an agency unable to comply by Jan 1, 2027 must instead post (and annually update) a public written progress report. General ADA Title II undue-burden and fundamental-alteration defenses also apply under the federal baseline.
• Governing authority State Technology Law (STL) Section 103-d 'Website accessibility; state agencies' (NYSenate.gov: https://www.nysenate.gov/legislation/laws/STT/103-D); Executive Law Section 170-f 'Website accessibility; contractors and vendors' (added by A8453, signed Dec 2 2022; https://www.nysenate.gov/legislation/laws/EXC/170-F); STL Section 103(10), 103(20) and 103(21) authorizing ITS to issue guidance; implemented by NYS Enterprise IT Policy NYS-P08-005 'Accessibility of Information Communication Technology' (updated 08/19/2024). These are state-specific requirements layered on top of the federal ADA Title II baseline (28 CFR Part 35).
• Compliance deadline State-specific: WCAG 2.2 AA for state-agency and contractor/vendor websites by January 1, 2027 (STL 103-d / Exec Law 170-f), with annual public progress report if not met. Plus federal DOJ ADA Title II WCAG 2.1 AA deadline of April 24, 2026 as stated in NYS-P08-005 (federal rule dates are Apr 26 2026 for large entities / Apr 26 2027 for entities under 50,000 population and special district governments).

Official sources:
its.ny.gov/accessibility-information-communication-technology (opens in new tab)
its.ny.gov/system/files/documents/2025/12/nys-p08-005-accessibility-of-information-communication-technology.pdf (opens in new tab)
nysenate.gov/legislation/laws/STT/103-D (opens in new tab)
nysenate.gov/legislation/laws/EXC/170-F (opens in new tab)
its.ny.gov/nys-technology-law (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.