Tennessee Digital Accessibility Law

WCAG 2.1 AA + Section 508 Federal ADA Title II baseline

Tennessee has no state-specific digital/ICT accessibility law and no binding statewide WCAG mandate for government procurement. It is absent from the federal Section508.gov state list, and the official TN.gov accessibility statement relies on federal Section 508 and ADA Title II (with DOJ-issued standards) rather than any Tennessee statute. The Department of Finance & Administration's Strategic Technology Solutions (STS) is the central IT authority and staffs the Information Systems Council, but no ISC/STS statewide accessibility policy is published; the Department of Disability and Aging is the listed accessibility-complaint contact. Tennessee's accessibility statutes cover physical buildings only (Tenn. Code 68-120-204), and the Tennessee Disability Act (Tenn. Code 8-50-103) is a general employment-discrimination law enforced through the Human Rights Commission, not a web/WCAG cause of action. There is therefore no Tennessee private right of action or statutory damages for digital accessibility; enforcement is federal under ADA Title II (injunctive relief, attorney's fees, and damages only on intentional discrimination). Under the DOJ 2024 Title II web rule, as extended in 2026, public entities must meet WCAG 2.1 Level AA by April 26, 2027 (population 50,000+) or April 26, 2028 (under 50,000 and special districts). Some entities, notably the Tennessee Board of Regents, voluntarily follow WCAG Level A and AA, but no statewide statutory standard exists.

What the law requires

  • Responsible agency No state agency administers a digital/ICT accessibility law, because none exists. For executive-branch IT, the Department of Finance & Administration's Strategic Technology Solutions (STS) is the state's central information technology service bureau and acts as staff to the Information Systems Council (ISC), the body that sets binding statewide IT policies (corroborated by tn.gov/finance/sts.html). The official TN.gov accessibility statement lists the Tennessee Department of Disability and Aging (Accessibility@tn.gov) as the contact for accessibility complaints (corroborated by tn.gov/web-policies/accessibility.html). Higher-education systems set their own standards (e.g., the Tennessee Board of Regents). (tn.gov/finance/sts.html) (opens in new tab)
  • Adopted standard No statutorily adopted statewide digital-accessibility standard (CORROBORATED: none found in TN Code, ISC/STS policies, or TN.gov statement). The TN.gov accessibility statement cites Section 508 and DOJ/ADA Title II standards but names no specific WCAG version/level. The operative federal standard for Tennessee state and local government web content and mobile apps is WCAG 2.1 Level AA, per the DOJ 2024 ADA Title II web rule (corroborated by ada.gov). The Tennessee Board of Regents voluntarily follows WCAG Level A and AA plus Section 508 (entity-level, not statewide mandate).
  • Who it covers No state-law scope exists (CORROBORATED: no Tennessee digital-accessibility statute). Under the federal baseline: ADA Title II covers all Tennessee state and local government entities and public higher education; Section 504/508 reach recipients of federal funds and federally aligned ICT procurement. Vendor and contractor obligations flow contractually from these public entities, not from any Tennessee accessibility statute.
  • Private right of action No Tennessee digital-accessibility private right of action exists (CORROBORATED: no such statute). DISTINCTION: Tennessee's general disability-discrimination statute, the Tennessee Disability Act (Tenn. Code 8-50-103), is an EMPLOYMENT-discrimination law; it makes disability discrimination in employment a Class C misdemeanor and routes aggrieved persons to the Tennessee Human Rights Commission under Tenn. Code 4-21-302 to 4-21-311 (reinstatement, back pay, compensatory damages; no punitive damages). It does NOT create a web/ICT/WCAG cause of action. For digital accessibility, enforcement is federal: ADA Title II permits private suits and DOJ enforcement against public entities (sovereign immunity abrogated for Title II court-access claims in Tennessee v. Lane, 541 U.S. 509 (2004)).
  • Statutory damages / penalties None - no Tennessee statute sets per-violation digital-accessibility damages (CORROBORATED: no such statute). The Tennessee Disability Act (general employment law) provides reinstatement, back pay, and compensatory damages via the Human Rights Commission, with no punitive damages, and is not a digital-accessibility provision. For digital accessibility, remedies arise under federal ADA Title II (injunctive relief, compensatory damages on a showing of intentional discrimination, and attorney's fees). The commonly cited $75,000 / $150,000 figures are federal ADA civil penalties, not Tennessee statutory damages.
  • Exemptions No state-law exemptions exist (no Tennessee digital-accessibility statute). Under the federal baseline, ADA Title II provides fundamental-alteration and undue-burden defenses; the DOJ 2024 Title II web rule adds limited exceptions (e.g., archived web content, certain preexisting electronic documents, individualized password-protected content, and third-party content not posted by or for the public entity).
  • Governing authority No Tennessee statute or binding statewide rule mandates digital/ICT/web accessibility (WCAG) for state or local government procurement. CORROBORATED: Tennessee is absent from the Section508.gov state IT-accessibility list, and the official TN.gov accessibility statement relies on Section 508 of the Rehabilitation Act and Title II of the ADA (with DOJ-issued standards), citing no Tennessee statute or statewide policy. Tennessee's accessibility STATUTES address physical buildings only (Tenn. Code 68-120-204 / Tennessee Public Buildings Accessibility Act, adopting the 2010 ADA Standards for Accessible Design), not digital content. The 'Data Accessibility, Transparency and Accountability Act' (Tenn. Code Title 49, Ch. 1, Part 7) is an education-data-transparency law, NOT disability accessibility. The operative baseline for Tennessee public entities is federal ADA Title II and Section 504/508. (This is GENERAL federal disability/civil-rights law plus the 2024 DOJ Title II web rule, not a Tennessee digital-accessibility provision.)
  • Compliance deadline No Tennessee statutory deadline. Federal ADA Title II web-rule dates apply, as extended one year by the DOJ Interim Final Rule published April 20, 2026 (corroborated by ada.gov): WCAG 2.1 Level AA by April 26, 2027 for public entities with total population 50,000 or more, and by April 26, 2028 for public entities under 50,000 and special district governments.

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Official sources:
section508.gov/manage/laws-and-policies/state/ (opens in new tab)
tn.gov/web-policies/accessibility.html (opens in new tab)
tn.gov/finance/sts.html (opens in new tab)
tn.gov/finance/strategic-technology-solutions/strategic-technology-solutions/sts-security-policies.html (opens in new tab)
ada.gov/resources/2024-03-08-web-rule/ (opens in new tab)
law.justia.com/codes/tennessee/title-8/chapter-50/part-1/section-8-50-103/ (opens in new tab)
law.justia.com/codes/tennessee/title-49/chapter-1/part-7/ (opens in new tab)
tbr.edu/marketing/web-accessibility (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.