Virginia Digital Accessibility Law

WCAG 2.1 AA + Section 508 State-specific law

Virginia has a state-specific digital accessibility law, the Information Technology Access Act (Code of Virginia 2.2-3500 to 2.2-3504), administered by the Virginia Information Technologies Agency (VITA) through ITRM Standard GOV103-00 and substantially modernized by HB2541 in 2025. The law incorporates federal Section 508 standards, Section 255 guidelines, and the ADA Title II rule (28 C.F.R. 35.200), so the operative web benchmark is WCAG 2.1 Level AA, and it covers state agencies, public higher education, school divisions, and political subdivisions, with vendors required to supply VPAT-style Accessibility Conformance Reports and remediation roadmaps. The ITAA creates no private right of action and no statutory damages; enforcement is procurement-driven (bid screening, contract remedies, and vendor exclusion), though covered public entities still face independent federal ADA Title II / Section 504 exposure. HB2541 procurement requirements took effect July 1, 2025, with phased compliance for covered entities beginning April 24, 2026 and April 26, 2027.

What the law requires

  • Responsible agency Virginia Information Technologies Agency (VITA) (vita.virginia.gov)
  • Adopted standard ITAA does not name WCAG directly; it incorporates federal Section 508 Standards (29 U.S.C. 794d / 36 C.F.R. Part 1194) and Section 255 Guidelines (47 U.S.C. 255), and conformance with 28 C.F.R. 35.200 (DOJ ADA Title II rule). The operative web standard via those references is WCAG 2.1 Level AA. Accessibility Conformance Reports (VPATs) are required from vendors who cannot self-certify conformance.
  • Who it covers Covered entities defined in Code of Virginia 2.2-3501: state agencies, public institutions of higher education, public school divisions, and political subdivisions of the Commonwealth. Applies to ICT procured, developed in-house, or acquired by contract. HB2541 procurement provisions phase in by population: entities of 50,000+ and higher education first, then smaller/special-district entities. Vendors/contractors are reached indirectly through procurement requirements (ACRs and Vendor Accessibility Roadmaps).
  • Private right of action No. The ITAA does not create a private right of action or statutory damages. Enforcement is procurement-driven (solicitation screening, contract remedies, and exclusion of non-conforming vendors). Note: covered public entities remain independently subject to federal ADA Title II and Section 504, which do permit private litigation against the entity, but that is federal law, not the Virginia ITAA.
  • Statutory damages / penalties None under the ITAA - no per-violation fines or statutory damages. Enforcement is contractual/procurement-based: covered entities may require ACRs and remediation roadmaps, and reportedly may seek contract credits or cancel contracts if vendors fail to remediate within a defined period (the $10,000 contract-credit cap is reported by secondary sources interpreting HB2541's procurement remedies and was not directly confirmed in the official statute text reviewed).
  • Exemptions Section 2.2-3504 (Exclusions to digital accessibility) ties exceptions to federal regulations rather than restating them: the exceptions found in 28 C.F.R. 35.201 (ADA Title II, including undue burden and fundamental alteration) and 36 C.F.R. Part 1194, Appendix A, Section E202 (Section 508 general exceptions). Federal undue burden and fundamental alteration defenses therefore apply.
  • Governing authority Information Technology Access Act (ITAA), Code of Virginia Title 2.2, Chapter 35, Sections 2.2-3500 through 2.2-3504 (originally enacted 2004; substantially amended by HB2541, 2025 Acts of Assembly, eff. July 1, 2025). VITA implements the Virginia Information Technology Accessibility Standard, ITRM Standard GOV103-00.
  • Compliance deadline Phased under HB2541: procurement requirements apply to newly negotiated contracts beginning July 1, 2025; covered entities with population 50,000+, institutions of higher education, and state public bodies beginning April 24, 2026; special district governments and covered entities under 50,000 population beginning April 26, 2027. Federal ADA Title II web deadlines (Apr 26 2027 / Apr 26 2028) also apply to these public entities.

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Official sources:
section508.gov/manage/laws-and-policies/state/
law.lis.virginia.gov/vacodepopularnames/information-technology-access-act/
law.lis.virginia.gov/vacode/title2.2/chapter35/section2.2-3501/
law.lis.virginia.gov/vacode/title2.2/chapter35/section2.2-3502/
law.lis.virginia.gov/vacode/title2.2/chapter35/section2.2-3504/
lis.virginia.gov/bill-details/20251/HB2541
vita.virginia.gov

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.