Digital Accessibility Progress Reports

• Q2 2024 Progress Report
• Q3 2024 Progress Report
• Q4 2024 Progress Report
• Q1 2025 Progress Report
• Q2 2025 Progress Report

Note

Because this is the city’s first progress report, this report recounts many prior efforts and city progress preceding this report. Future reports will recount only updates from the prior report.

Definitions

• “Digital Accessibility Law” refers to those statutory provisions adopted by HB 21-1110.
• “ICT” refers to information and communications technology, as defined in the Rules.
• “OIT” refers to the Governor’s Office of Information Technology, State of Colorado.
• “The Rules” refers to the Rules Establishing Technology Accessibility Standards, found in the Colorado Code of Regulations at 8 CCR 1501-11.
• “WCAG” refers to the most recent version of the Web Content Accessibility Guidelines, success criteria Levels A and AA.

Overview

The City believes its external-facing webpages are substantially compliant. Throughout 2023, the City engaged in a thoughtful process for evaluating its webpages and remedying accessibility issues. These efforts included retaining and utilizing third-party software designed to evaluate the City’s web pages and portals.

Furthermore, as of the date of this report, the City has provided various means for alternative and additional accommodation if persons have difficulty accessing, reading, or utilizing the City’s web pages. These include, among other things, eliminating barriers by adding digital accessibility content to the City’s ADA webpage and providing contact information on various pages for assistance.

While the Digital Accessibility Law provided funding to OIT, it did not provide funding to local governments. Accordingly, the City is working toward full compliance without an increase in resources. Financial constraints prevent an "all at once” conversion to full compliance of all the City’s ICT, but the City is reallocating staff time and planning future allocations to address the issues.

Compliance Progress

Since the passage of HB 21-1110, the City has undertaken substantial efforts to ensure its ICT is accessible. These efforts include, but are not limited to:

Accessibility Program Steering Committee (Leadership)

Beginning in 2023, City leadership has regularly met to discuss digital accessibility compliance. These meetings provide technical staff with support from senior leadership, including:

• Executive Sponsors: City Manager Nuria Rivera-Vandermyde, Director of Innovation & Technology Jennifer Douglas.
• Steering Committee: High-level individuals from departments including Finance, City Attorney’s Office, Communications, Innovation and Technology, City Manager’s Office, and Human Resources.

Identified Workstreams and Workstream Teams

The City formed 16 different workstreams to address specific digital accessibility issues. These workstreams include areas such as vendor compliance, website accessibility, high-impact platforms, and training.

Digital Software and Applications Accessibility Assessment Team

Since January 2024, the City has had a team that evaluates the software and applications provided by third-party vendors for compliance with digital accessibility requirements. The team meets weekly and includes members from the Department of Finance, Innovation & Technology, ADA Coordinator, Risk Manager, and City Attorney’s Office.

Digital Portfolio

Existing application inventories have been updated, with over 300 applications being tracked. Ongoing conversations with vendors are helping address compliance deficiencies.

Investment in Tools

The City has procured tools like Popetech and Siteimprove to assess compliance, and enhanced licenses for Microsoft Office and Adobe Acrobat Pro to help staff produce accessible documents.

Educational & Community Participation

Program staff have attended training sessions by OIT, Colorado Government Association of Information Technology, and others. These sessions occur regularly, with staff reporting back on best practices.

Citywide Communications/Meetings

Digital accessibility has been frequently discussed in all-employee townhall meetings. In November 2023, a meeting was dedicated entirely to digital accessibility, with senior leadership speaking on its importance.

Digital Accessibility Champions

The City initiated an "Accessibility Champions" program where major departments designate a champion trained on digital accessibility to promote compliance within their department.

City Training Courses

The City created internal training courses on digital accessibility. These include:

• General Awareness Training: Self-paced training on digital accessibility basics, completed by over 1,600 staff.
• Email and Document Training: Courses on Microsoft Office and PDF accessibility, with 239 employees completing the pilot program.
• Specialized Training: Role-specific training for web content and Geographic Information System (GIS) tools.

Contract Template Revisions

The City revised its IT contracts to include digital accessibility terms, ensuring vendors understand and comply with these requirements. Accessibility is also included in purchasing criteria.

Conclusion

The City is committed to fostering inclusion and will continue to improve its accessibility efforts, addressing current and future barriers to ensure operations are accessible to everyone.

Q3 Digital Accessibility Update

The City continues to move its information technology towards full accessibility. All ongoing activities set forth in the City’s first report (for Q2, published July 1, 2024), continue to apply. In Q3, we made significant progress in improving the city’s digital accessibility efforts:

• Phase I Completion: We have successfully completed Phase I of our digital accessibility program and are now transitioning into the operational phase.
• Vendor Compliance: We are actively working with vendors to ensure they meet accessibility standards. For those not yet fully compliant, we are collaborating with them to develop a roadmap toward compliance as part of the renewal process.
• New Hire: We hired and onboarded a full-time Digital Accessibility Program Manager. This role reflects our ongoing commitment to accessibility and required careful budgeting to implement. The Digital Accessibility Program Manager will serve as a thought-leader throughout the City on matters relating to accessibility, and will provide needed expertise to appropriately assess the City’s many information technology products.
• Product Assessments: We assessed 36 products for compliance in this quarter. We also updated contract language to include accessibility requirements during renewals whenever possible. Many of these assessments resulted in needed additional contract language or promises for improvements from vendors. In cases where products were not yet fully compliant, we are working with the vendors to help them meet our standards, ensuring they have a plan in place to achieve compliance.
• Employee Training: We created and conducted both mandatory and optional digital accessibility training for new and current employees. To date, more than 2,100 employees have the training for awareness and understanding of HB21-1110. The City continues to prioritize digital accessibility training for those employees in the positions to make the greatest impact.
• Accessible Forms: We are continuing to convert paper and PDF forms into fully accessible digital formats using Formstack. Between July 1 and September 30, we have created 36 forms to replace PDFs that did not meet accessibility standards.

Q4 Digital Accessibility Update

• Vendor Engagement and Compliance: We continue to hold regular vendor review meetings to ensure progress toward compliance with Colorado's accessibility law, HB21-1110. This quarter, we reviewed 30 requests as part of our ongoing assessment process. Some vendors have responded positively to our requests for updated VPATs, demonstrating improvements from their initial conditional approvals.
• Accessibility Champions Group Reestablished: The City of Boulder’s Accessibility Champions group has been successfully restarted, with growing participation across departments. The Digital Accessibility Champions group is a cross-departmental team dedicated to promoting and supporting accessible digital practices citywide. Champions advocate for accessibility, assist in identifying and remediating digital content, provide departmental guidance, and participate in ongoing training to ensure compliance and sustainability.
• Statewide Peer Networking Group Launch: In collaboration with several other municipalities, the City of Boulder’s Digital Accessibility Program Manager has launched a peer networking group focused on enhancing compliance with HB21-1110. We are in the outreach phase and welcome additional municipalities from across Colorado to join. Interested parties can contact us at accessibility@bouldercolorado.gov.
• Conference Attendance: The City of Boulder ADA Coordinator attended the Accessing Higher Ground conference, a leading event in digital accessibility, to gain insights and share best practices for improving digital access across city services.

• Analysis of Potential Rule Changes. Review, evaluation, and preparation for the State of Colorado, Governor’s Office of Information Technology, proposed rule changes governing digital accessibility within the State HB21-1110 proposed rule changes. This analysis included examining the upcoming Department of Justice Rules governing digital accessibility, including the implications of both sets of rules upon city contracting and digital activities. This process is ongoing, but has been important for the city’s maintenance of expertise and knowledge surrounding developing legal requirements.
• Digital Accessibility Internal Messaging for 2025: The Digital Accessibility Program has developed key messaging for 2025, with planned outreach through multiple communication channels, including employee newsletters, Town Hall meetings, and the Accessibility Champions program. This initiative aims to increase awareness and engagement across City departments, which promotes both embracing the value of accessibility and legal compliance.
• Document Audit and Remediation Plan: We have developed a strategic document remediation plan to address the remaining documents on the City’s website. Using data to prioritize the most frequently used and downloaded documents, the remediation approach follows a structured order: converting documents to accessible HTML when possible, ensuring only accessible forms are used, and remediating necessary PDFs. In addition, detailed guidance and supporting documents have been developed to better assist content editors in meeting digital accessibility standards with a consistent organization-wide approach.
• Website Content Approval Process: The approval process for website edits and document uploads has been refined, ensuring accessibility compliance before publication. Additionally, we have temporarily paused all new document uploads to the website to prevent accessibility barriers and maintain a fully compliant digital environment moving forward.
• GIS Accessibility Task Force Established: The City has formed a GIS Accessibility Task Force, a cross-departmental group dedicated to providing guidance and support to GIS content creators. This group will work to ensure WCAG compliance to the greatest extent possible within GIS systems, enhancing accessibility across our mapping and spatial data tools.
• Expansion of Accessibility Tools: Plans are underway to roll out additional accessibility tools, including PAC 2024, to a broader audience within the City of Boulder. To support adoption, we have created guidance documents and tip sheets to help staff integrate these tools into their workflows effectively.
• Conference Attendance: The Digital Accessibility Program Manager and other City staff attended two accessibility-focused conferences, axe-con and MS Ability. These events provided valuable insights, best practices, and emerging trends in digital accessibility, which will inform future program enhancements. City staff also regularly attend presentations, trainings, and intergovernmental working groups to discuss accessibility issues.

The City of Boulder continues to advance its commitment to digital accessibility in alignment with HB21-1110. All initiatives outlined in prior updates remain in effect, and we have made additional progress this quarter in key areas of training, document accessibility, vendor reviews, and internal capacity-building.

Document Remediation Progress: This quarter, the City focused on improving the accessibility of high-impact content. We successfully remediated, transitioned to web pages, or archived PDFs from the top 100 pages of most-downloaded documents on the City’s website. An additional 150+ forms have been streamlined and digitized into an accessible format. In parallel, we removed 2200 outdated and archived documents that are no longer in active use. This work not only reduced the total volume of inaccessible content but also improved the accessibility of materials that are most used by the public. Remediation efforts are ongoing and will continue beyond the top 100 documents, following the City’s document prioritization strategy. To further support findability, we also improved the City’s search index by removing outdated or redundant entries, helping users more easily locate current and accessible content.

Additionally, the City renewed or purchased 19 licenses with Allyant CommonLook, a SIPA-approved vendor, to support the remediation of complex PDF documents.

Training and Staff Development: The City’s digital accessibility training efforts continue to grow. As of June 30, 94% of employees have completed the City’s mandatory digital accessibility awareness training. In addition, hundreds of staff have completed specialized training tailored to their roles, including website accessibility, accessible document creation, and procurement best practices.

To keep content current with evolving best practices, the City is refreshing its mandatory training module this quarter. Updated content reflects new legal developments, improved workflows, and employee feedback.

Citywide Guidance and Resources: To support staff in implementing accessibility best practices, the City has rolled out a Document Accessibility Plan with clear guidance for all departments. This plan outlines expectations for accessible content creation and prioritization strategies for remediation, providing a consistent framework across the organization.

In tandem with the plan’s release, the Accessibility Hub on the employee intranet was updated and reorganized. The Hub now includes refreshed guidance, up-to-date training materials, frequently asked questions, contact information, and links to internal and external resources.

Vendor Accessibility Reviews: This quarter, the City reviewed more than 50 software and digital tools for accessibility compliance. As part of the ongoing vendor review process, we continue to assess products at the time of procurement and renewal, with a focus on obtaining current accessibility documentation (e.g., VPATs) and confirming remediation roadmaps where needed.

Social Media Accessibility: This quarter, the City updated its Social Media Policy to formally include digital accessibility standards, ensuring all content shared through official channels aligns with WCAG guidance. In addition, platform-specific accessibility guidance was developed for each social media channel the City uses. This guidance includes best practices for captions, alt text, contrast, emojis, and more. The updated policy and supporting resources were rolled out to all staff who manage or create content for City social media accounts.

Professional Development and Knowledge Sharing: City staff continue to engage in professional development to maintain and grow expertise. In Q2, the Digital Accessibility Program Manager participated in two notable events:

• IAAF 2025 – Accessible by Design: Enhancing Efficiency in Federal ICT, the annual Interagency Accessibility Forum hosted by the U.S. General Services Administration’s Section508.gov. This event convenes accessibility professionals in government from across the country to share scalable strategies for integrating accessibility into digital systems and procurement processes.
• WebAIM Training Series, with sessions focused on accessible document creation and vendor evaluation.

In addition, the City’s ADA Coordinator attended the 2025 National ADA Symposium, a leading conference on disability rights and accessibility. Attendance at this event supports the City’s broader efforts to align both digital and physical accessibility initiatives with current federal guidance and best practices.

These events provided practical insights that are being incorporated into City workflows and shared with internal working groups.