Wisconsin Digital Accessibility Law

WCAG 2.1 AA + Section 508 Federal ADA Title II baseline

Wisconsin has no state-specific digital/ICT accessibility statute and no binding statewide accessibility standard: the controlling IT statute (Wis. Stat. 16.971, DOA/DET) and the DET Acceptable Technology Use, Access, and Security Policy contain no accessibility/WCAG/Section 508 requirement, and Wisconsin is absent from the Section508.gov state-law compilation. The operative requirement for state and local government is therefore the federal ADA Title II baseline (WCAG 2.1 AA). Public higher education is bound by UW System Administrative Policy SYS 655, which adopts WCAG 2.1 Level AA with an April 24, 2026 remediation deadline for existing digital resources. There is no digital-accessibility-specific private right of action or statutory-damages scheme in Wisconsin; however, the general public-accommodations statute (Wis. Stat. 106.52) provides a private civil action for disability discrimination with injunctive relief, damages including punitive damages, and attorney fees, though that statute does not reference websites or digital services and is general civil-rights law rather than a digital mandate.

What the law requires

  • Responsible agency No single statewide digital-accessibility authority confirmed from primary sources. State executive-branch IT is administered by the Department of Administration (DOA) Division of Enterprise Technology (DET) under Wis. Stat. 16.971, but that statute contains no accessibility/WCAG/Section 508 mandate. Public higher education is governed by the Universities of Wisconsin (UW System), whose UW System Administrative Policy SYS 655 adopts WCAG 2.1 Level AA. General disability discrimination in public accommodations is administered by the Department of Workforce Development, Equal Rights Division, under Wis. Stat. 106.52. (doa.wi.gov/Pages/AboutDOA/DET.aspx) (opens in new tab)
  • Adopted standard No statewide Wisconsin statutory or administrative-rule digital-accessibility standard was corroborable from primary sources. Public higher ed (UW System Policy SYS 655) adopts WCAG 2.1 Level AA (verified from policy text). The federal ADA Title II baseline (WCAG 2.1 Level AA per 28 CFR Part 35, 2024 DOJ rule) is the operative requirement for Wisconsin state and local government. Individual Wisconsin executive-branch agencies' public accessibility statements reference WCAG 2.1 Level AA and/or Section 508, but no binding statewide WCAG/508 statute, rule, or DET policy was confirmed.
  • Who it covers No confirmed statewide statutory digital-accessibility scope. UW System Policy SYS 655 binds all Universities of Wisconsin institutions and applies to 'all web content and mobile apps, including third party content, provided or made available for use in all Universities of Wisconsin programs, services, and activities' (verified from policy text). Wis. Stat. 106.52(3) prohibits disability discrimination in 'public place[s] of accommodation or amusement,' defined broadly to include 'any place where accommodations, amusement, goods, or services are available' (verified from statute text), but the statute does not reference websites or digital services. Under the federal ADA Title II baseline, scope covers all Wisconsin state agencies, local governments, and public entities.
  • Private right of action DIGITAL-ACCESSIBILITY-SPECIFIC: No - Wisconsin has no digital/web-accessibility-specific private right of action; no such statute was found. GENERAL DISABILITY/CIVIL-RIGHTS LAW: Yes - Wis. Stat. 106.52(4)(e)1 provides a private right of action for disability discrimination in public places of accommodation: 'A person, including the state, alleging a violation of sub. (3) may bring a civil action for appropriate injunctive relief, for damages including punitive damages and, in the case of a prevailing plaintiff, for court costs and reasonable attorney fees' (verified from statute text). This general public-accommodations statute does not mention websites or digital services, so its application to digital accessibility is not established by its text. Federal ADA Title II/III private enforcement also applies through federal court.
  • Statutory damages / penalties DIGITAL-ACCESSIBILITY-SPECIFIC: None - no Wisconsin statute sets per-violation fines or statutory damages for digital accessibility. GENERAL DISABILITY/CIVIL-RIGHTS LAW: Wis. Stat. 106.52(4)(e)1 authorizes, for a public-accommodations disability-discrimination violation, 'damages including punitive damages' plus court costs and reasonable attorney fees for a prevailing plaintiff (verified from statute text); no fixed statutory per-violation dollar amount is specified. This is general civil-rights remedy, not a digital-accessibility statutory-damages scheme.
  • Exemptions Wisconsin has no statewide digital-accessibility statute, so no statewide statutory exemptions exist. UW System Policy SYS 655 excuses conformance where it would cause a fundamental alteration or significant difficulty or expense, and exempts archived web content, preexisting conventional electronic documents, certain third-party content posted without contractual arrangement, individualized password-protected documents, and preexisting social media posts (verified from policy text). Under the federal ADA Title II baseline, undue burden and fundamental alteration apply.
  • Governing authority No Wisconsin state-specific digital/ICT accessibility statute or binding statewide administrative rule was found in primary sources. Wis. Stat. 16.971 (DOA/DET IT authority) contains no accessibility, WCAG, or Section 508 requirement (verified from statute text). The DET 'Acceptable Technology Use, Access, and Security Policy' (eff. 3/10/2025) contains no accessibility/WCAG/Section 508 provisions (verified from the PDF text). Individual Wisconsin agencies publish their own WCAG 2.1 AA accessibility statements, but no binding statewide DET accessibility standard was corroborable. For public higher ed, UW System Administrative Policy SYS 655 (Accessibility of Web Content and Mobile Applications) is binding on Universities of Wisconsin institutions and adopts WCAG 2.1 Level AA (verified from policy text). Wisconsin's general public-accommodations disability law (Wis. Stat. 106.52) prohibits disability discrimination in places of public accommodation but is general civil-rights law and does not mention websites or digital services (verified from statute text). The operative baseline for state and local government digital accessibility is therefore Federal ADA Title II (28 CFR Part 35).
  • Compliance deadline No statewide statutory deadline (no statewide accessibility statute). UW System Policy SYS 655: 'existing digital resources that are not accessible shall be remediated to comply with WCAG 2.1 level AA by April 24, 2026' (verified from policy text; public higher-ed policy, not a statute). Under the federal ADA Title II baseline for state/local government: WCAG 2.1 AA by April 26, 2026 (population 50,000+) / April 26, 2027 (under 50,000 and special district governments) per 28 CFR Part 35.

Evaluating a vendor for Wisconsin?

Score any VPAT or ACR against WCAG 2.1 AA + Section 508 in under a minute, with a procurement risk rating. Free to start.

Evaluate a VPAT Free

Official sources:
section508.gov/manage/laws-and-policies/state/ (opens in new tab)
docs.legis.wisconsin.gov/statutes/statutes/16/VII/971 (opens in new tab)
det.wi.gov/Documents/AUP%20-%20Effective%20Date%203.10.2025.pdf (opens in new tab)
wisconsin.edu/uw-policies/uw-system-administrative-policies/accessibility-of-web-content-and-mobile-applications/ (opens in new tab)
docs.legis.wisconsin.gov/statutes/statutes/106/III/52/4 (opens in new tab)
docs.legis.wisconsin.gov/statutes/statutes/106/III/52/2 (opens in new tab)
doa.wi.gov/Pages/AboutDOA/DET.aspx (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.