Virginia’s HB 2541: A New Era of Digital Accessibility and Public-Sector Procurement

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Virginia has taken a major step forward in digital inclusion. HB 2541, the update to the Commonwealth’s Virginia Information Technology Access Act, introduces a modern and accountability-driven model that places digital accessibility at the heart of public-sector procurement.

Under HB 2541, accessibility is no longer a “best practice” or an optional consideration. It becomes a core requirement that must be embedded into how public bodies purchase websites, software, applications, digital platforms, and cloud-based ICT solutions.

If you are a Virginia public-sector organization – or a vendor selling into the Commonwealth – this legislation directly affects how you operate, procure, and deliver digital services.

Below, we break down what HB 2541 changes, who it covers, and what you should do now to prepare.

What HB 2541 Achieves

HB 2541 modernizes Virginia’s accessibility requirements in four major ways:

1. Expands Who Must Be Served

Historically, the Act focused primarily on individuals who were blind or visually impaired. HB 2541 recognizes today’s broader definition of disability and the need for inclusive digital access for all Virginians, including people with:

  • Cognitive or learning disabilities
  • Mobility and dexterity impairments
  • Low vision
  • Neurodiverse needs
  • Language and literacy barriers

This sets a more inclusive and equitable standard across the Commonwealth.

2. Broadens What Qualifies as ICT

The updated law now explicitly covers websites, digital platforms, software, mobile apps, cloud tools, online services, and communications technologies.

This sets a more inclusive and equitable standard across the Commonwealth.

3. Introduces a Procurement-Based Accountability Model

This is the most transformational part of HB 2541. Public bodies must now require vendors to provide:

  • A current Accessibility Conformance Report (ACR) using the VPAT format
  • Transparent disclosure of accessibility gaps
  • A time-bound remediation plan outlining how and when those gaps will be closed

This shifts responsibility upstream, making vendors accountable for accessibility from day one, rather than placing the burden on public bodies after procurement.

4. Phases Compliance Based on Entity Size

To ensure a realistic transition, the law introduces a staggered timeline:

  • Large entities move first
  • Smaller organizations follow

This provides time for training, contract updates, vendor engagement, and digital modernization.

Who Is Covered by HB 2541?

The legislation applies broadly across the Commonwealth. Covered entities include:

  • State agencies and state public bodies
  • Public institutions of higher education
  • Public school divisions
  • Local governments, counties, cities, and special districts

If you are anywhere within the Virginia public-sector ecosystem or if you are a vendor providing ICT into that ecosystem, HB 2541 applies to you.

Key Requirements for Compliance

The expectations under HB 2541 are clear and transparent.

1. All New or Renewed ICT Contracts Must Include Accessibility Requirements

Accessibility must be integrated into:

  • RFPs 
  • Vendor agreements
  • Renewals
  • Procurement templates and approval processes

2. Vendors Must Provide Current VPAT/ACR Documentation 

Documentation must be:

  • Up to date
  • Honest about gaps
  • Accompanied by a credible remediation roadmap
  • Mapped to WCAG 2.1 or 2.2 AA, the referenced standards

3. Entities Should Appoint a Digital Accessibility Coordinator 

This ensures internal accountability and creates a central point of governance, training, and remediation oversight.

4. Exceptions Exist, But Are Narrow  

Limited exemptions apply only if:

  • The accessible equivalent increases cost by more than 5%, or
  • The ICT is strictly used by individuals without disabilities

These limitations reinforce that accessibility must be the default, not an afterthought.

Deadlines and Phasing

HB 2541 includes a phased rollout aligned with entity size:

April 24, 2026

Applies to:

  • Entities serving 50,000+ residents
  • All state public bodies
  • All public institutions of higher education

April 26, 2027

Applies to:

  • Smaller localities (serving under 50,000 residents)
  • Special districts

This ensures all public bodies reach the same standard, with time to adjust internal processes and contracts.

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Why HB 2541 Matters

This legislation solves a longstanding issue: public entities often purchase inaccessible software or websites, only to discover the problems later – leading to costly remediation, barriers for residents, or exposure to legal risk.

HB 2541 delivers:

  • Reduced legal exposure
  • Stronger procurement governance
  • More predictable vendor accountability
  • Modernized, inclusive digital experiences for every Virginian
  • A competitive advantage for vendors who take accessibility seriously

It creates a more transparent, equitable, and user-centered digital landscape across the Commonwealth.

How Recite Me Supports HB 2541 Compliance

Recite Me helps public-sector organizations and vendors meet both the spirit and letter of HB 2541.

1. Compliance Readiness: WCAG 2.2 AA Auditing  

Our Accessibility Checker provides: 

  • Automated scanning
  • Manual expert review
  • Issue prioritization
  • Remediation guidance
  • Exportable reports for procurement teams

This directly supports VPAT/ACR preparation and ongoing compliance.

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2. Usability & Inclusion: Assistive Toolbar  

Beyond compliance, the Assistive Toolbar helps residents access and use content by providing: 

  • Screen reading
  • Translation into 100+ languages
  • Adjustable text size, fonts, spacing, and contrast
  • Reading guides, focus tools, and content simplification

This supports users with disabilities, aging populations, multilingual communities, and individuals with literacy challenges.

3. Governance, Communication & Transparency   

Recite Me helps organizations: 

  • Publish accessibility statements
  • Build remediation roadmaps
  • Communicate progress
  • Prepare vendor documentation for procurement

This aligns directly with HB 2541’s vendor accountability model. 

A Turning Point for Digital Inclusion in Virginia

HB 2541 marks a cultural and operational shift. Accessibility is now a fundamental requirement of responsible public service, not a checkbox or afterthought.

For organizations in Virginia, the time to modernize is now. And Recite Me is here to support every step from assessment and compliance to inclusive user experience and procurement-ready documentation.

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