In March 2025, Virginia’s legislature passed a groundbreaking update to the Information Technology Access Act (ITAA), reshaping accessibility requirements for digital communication across public institutions. The law (HB2541) applies to Virginia state agencies, local governments, special districts, public school systems, and institutions of higher learning.

Previously, the ITAA primarily addressed barriers for individuals with blindness or visual impairments. With this update, the scope expands to cover all disabilities, ensuring broader and more inclusive digital access.

Expanded Scope and Vendor Accountability

This Act’s definition of “information and communications technology” has widened significantly. While the previous focus was primarily on websites, the updated law explicitly includes websites, applications, and other digital services.

One key distinction between Virginia’s new law and other recent measures—such as Colorado HB21-1110 or the federal Department of Justice (DOJ) announcements is its emphasis on vendor responsibility. The law requires vendors to provide software to submit an Accessibility Conformance Report (ACR), such as a Voluntary Product Accessibility Template (VPAT), detailing their product’s accessibility status. If a product does not fully comply with WCAG 2.1 standards, vendors must provide an Accessibility Road Map outlining areas of non-compliance and a timeline for resolving accessibility gaps.

This represents a major shift in approach: instead of placing full responsibility on public entities, vendors must now actively contribute to digital accessibility efforts.

Compliance Timeline

The law’s implementation rhymes with last year’s DOJ Title II accessibility announcement, setting clear deadlines for compliance:

• April 24, 2026: Accessibility requirements apply to state agencies, institutions of higher education, and covered entities serving populations of 50,000 or more.
• April 26, 2027: Accessibility compliance expands to special districts and entities serving populations under 50,000.

What Should You Do?

With limited time to prepare, now is the moment to act. Here is how you can get started:

1. Audit Your Digital Presence: Inventory all websites, applications, and electronic communications under your control.
2. Evaluate Accessibility: Assess how accessible your technology currently is for people with disabilities.
3. Engage with Vendors: Work closely with software providers to secure ACR or VPAT documentation.
4. Develop an Accessibility Plan: Establish a timeline to ensure full compliance.
5. Seek External Expertise: When needed, collaborate with third-party accessibility specialists.

Final Thoughts

Virginia’s HB2541 represents a fundamental shift in how digital accessibility is approached. By embedding vendor accountability and expanding the law’s scope, the state is taking significant strides toward equitable technological access. While the timeline is tight, proactive collaboration and prioritizing accessibility can help public institutions navigate these changes effectively starting today.