Posted: · Updated: · Author: Adam Welch
Washington agencies face related but distinct accessibility responsibilities: Executive Order 24-05 addresses disability inclusion across state employment, while the federal ADA Title II web rule establishes WCAG 2.1 AA requirements for state and local government websites and mobile apps.
Quick answer: Washington Executive Order 24-05, signed in December 2024, directs executive agencies to improve disability employment, accommodations, accessible documents, training, and digital work environments. Separately, the US Department of Justice's ADA Title II web rule requires most state and local government web content and mobile apps to meet WCAG 2.1 Level AA by April 26, 2027, or April 26, 2028, depending on population.
In this article
Key Facts and Deadlines
- December 2024: Governor Jay Inslee signed Washington Executive Order 24-05, Improving Employment Outcomes for People with Disabilities in State Employment.
- December 31, 2026: Executive agencies are directed to strive for a workforce in which at least 5 percent of employees are people with disabilities.
- July 1, 2026: Washington's USER-01-01-S technical baseline advanced from WCAG 2.1 AA to WCAG 2.2 AA for covered state technology.
- April 26, 2027: State and local governments serving populations of 50,000 or more must comply with the federal ADA Title II web and mobile-app rule.
- April 26, 2028: Governments serving fewer than 50,000 people and special district governments must comply with the federal rule.
- July 1, 2029: Under Washington's USER-01 policy, content and tools necessary for essential job duties, public information, or participation in programs must be accessible, subject to the policy's terms and exceptions.
These dates describe different requirements. Meeting one deadline does not automatically satisfy the others.
What Washington Executive Order 24-05 Requires
EO 24-05 is principally an employment and workplace-inclusion order. It seeks to remove barriers throughout recruitment, hiring, retention, professional development, accommodation, and promotion. It also contains important digital-accessibility directives because employment now depends on online systems, documents, communications, and training.
Among other actions, the order directs executive agencies to:
- develop measurable hiring and workforce plans addressing disability representation and disparities;
- strive to achieve a workforce with at least 5 percent representation by people with disabilities by the end of 2026;
- ensure agency-created materials and employee training meet accessibility requirements;
- review recruitment systems, job descriptions, and employment practices for unnecessary barriers;
- provide and fund reasonable accommodations without penalizing individual agency hiring decisions;
- support participation in the Disability Inclusion Network and Supported Employment in State Government program; and
- strengthen the accessibility of hiring systems, internal websites, applications, portals, training materials, data systems, and documents.
The state's current implementation work is coordinated across organizations including the Office of Financial Management, Office of Equity, Department of Enterprise Services, and Washington Technology Solutions. Agencies should consult the current state implementation resources rather than treating the original order as the only operational guidance.
What the ADA Title II Web Rule Requires
The federal rule is broader than employment. It applies to web content and mobile apps that state and local governments provide or make available, including content delivered through contractors in many circumstances. The technical standard is WCAG 2.1 Level AA.
Covered content can include public websites, online forms, payment and reservation systems, meeting information, mobile apps, course materials, documents, and third-party platforms used to deliver government programs. The rule contains limited exceptions, including certain archived content, preexisting conventional electronic documents, individualized password-protected documents, qualifying third-party content, and preexisting social-media posts. An exception does not eliminate a government's continuing duties to provide effective communication, reasonable modifications, and equal access.
The compliance date is based primarily on population: April 26, 2027, for governments serving 50,000 or more people, and April 26, 2028, for smaller governments and special district governments. School districts use the population method specified by the Department of Justice.
EO 24-05 and the ADA Title II Rule Compared
| Requirement | Primary scope | Who it affects | Digital relevance |
|---|---|---|---|
| Washington EO 24-05 | Disability employment, workplace inclusion, accommodation, and agency practices | Washington executive and small-cabinet agencies, with responsibilities assigned to statewide partners | Accessible hiring systems, internal platforms, documents, communications, and training |
| ADA Title II web rule | Access to state and local government web content and mobile apps | State and local governments and, in many cases, contractors providing their public services | WCAG 2.1 AA for covered websites, apps, documents, forms, and digital services |
| WaTech USER-01 and USER-01-01-S | Washington technology accessibility policy and technical standard | Covered Washington state technology | Accessibility plans, coordinators, training, covered technology, and WCAG 2.2 AA as the minimum standard effective July 1, 2026 |
What Agencies Should Inventory
A reliable accessibility program starts with an inventory tied to owners and public impact. A simple website-page list is not enough.
| Asset | What to assess | Common failure | Likely owner |
|---|---|---|---|
| Website templates | Keyboard operation, headings, landmarks, contrast, navigation, and responsive behavior | Fixing individual pages while leaving the shared template defective | Web or communications team |
| Online forms | Labels, instructions, errors, focus management, time limits, and confirmation messages | Errors communicated only by color or after focus has moved elsewhere | Program owner and web team |
| PDFs and office documents | Tags, title, language, headings, reading order, tables, links, and text alternatives | Uploading a visually polished but untagged document or scanned image | Communications and document author |
| Vendor platforms | Keyboard and screen-reader testing, accessibility documentation, support, and remediation commitments | Accepting a VPAT or sales claim without product testing | Procurement, IT, and program owner |
| Training and media | Captions, transcripts, audio description where needed, player controls, and accessible course operation | An accessible website linking to an inaccessible learning platform or presentation | HR, training, and content teams |
| Mobile apps | Platform accessibility APIs, labels, gestures, orientation, reflow, and error recovery | Testing only the corresponding website | Product owner and development team |
A Practical 90-Day Accessibility Plan
Days 1–30: Establish Ownership and Risk
- Name an executive sponsor, accessibility coordinator, and accountable owners for each platform.
- Inventory public and employee-facing websites, apps, documents, forms, training systems, and vendor tools.
- Identify high-impact journeys such as applying for benefits, employment, permits, payments, meetings, and emergency information.
- Publish an accessible way for users to report barriers and request assistance.
Days 31–60: Test and Prioritize
- Combine automated scans with keyboard, screen-reader, zoom, reflow, and document testing.
- Prioritize barriers by user impact, frequency, legal deadline, and whether a shared template can fix many pages at once.
- Review active procurements and renewals before inaccessible products become longer-term dependencies.
- Create a remediation backlog with owners, target dates, and acceptance tests.
Days 61–90: Remediate and Operationalize
- Fix shared templates and critical user journeys first.
- Train content authors to create accessible headings, links, images, tables, forms, and documents.
- Add accessibility requirements and testing rights to procurement language.
- Retest completed work with people and assistive technologies, then record evidence.
- Establish a recurring audit, reporting, and governance schedule so accessibility does not decay after launch.
Accessible Procurement Questions
Accessibility should be evaluated before a contract is signed, not added as a remediation request after launch. Agencies should ask vendors:
- Which product version and workflows were evaluated, against which WCAG version and conformance level?
- Was the assessment performed by the vendor, an independent specialist, or both?
- What manual keyboard and assistive-technology testing was completed?
- Can the agency test a production-equivalent environment before acceptance?
- Which known accessibility defects remain, and what are their remediation dates?
- How are accessibility regressions tested before releases?
- Will the contract require timely remediation, accessible support, and updated conformance documentation?
- Can users complete every critical task without relying on an inaccessible alternate process?
Why Automated Testing Is Not Enough
Automated tools are useful for finding repeatable failures such as missing labels, invalid relationships, and some contrast problems. They cannot reliably determine whether alternative text communicates the right meaning, whether heading structure reflects the content, whether focus order makes sense, whether instructions are understandable, or whether a complete task works well with assistive technology.
A defensible testing program combines automated checks with manual keyboard review, screen-reader testing, zoom and reflow inspection, document review, and testing of complete user journeys. Involving people with disabilities provides insight that conformance checklists alone cannot supply.
How Hemisphere Can Help
Hemisphere combines website development, user-interface design, content structure, document design, and search optimization. That cross-disciplinary perspective is useful because accessibility failures rarely belong to only one team. We can help organizations inventory digital assets, identify template-level issues, prioritize remediation, improve accessible content workflows, and build accessibility requirements into redesigns and ongoing maintenance.
If your organization needs an accessibility-focused website review or a practical remediation plan, contact Hemisphere Design + Marketing.
Primary Sources
- Washington Executive Order 24-05: Disabilities in State Employment
- Washington OFM: People with Disabilities in State Government
- US Department of Justice: Title II Web and Mobile Application Accessibility Rule
- WaTech USER-01 Digital Accessibility Policy
- WaTech USER-01-01-S Digital Accessibility Standard
- W3C Web Content Accessibility Guidelines 2.1
Reviewed for accuracy: August 13, 2026. This article distinguishes Washington employment directives from the federal web-accessibility rule and uses primary government sources. Requirements and implementation guidance can change; agencies should confirm current obligations with their legal and accessibility teams. This article provides general information and is not legal advice.
About the author: Adam Welch is Hemisphere's Creative Director. He has more than 30 years of design experience and provides project oversight spanning visual design, digital production, and website work.
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