Washington Policy 188 is the state’s accessibility policy governing information technology used by executive branch agencies. It requires that IT procured, developed, maintained, or used by state agencies be accessible to people with disabilities, with WCAG 2.0 Level AA cited as the technical standard for web content. Policy 188 applies to websites, web applications, mobile apps, electronic documents, software, and digital content produced or purchased by covered agencies. The Washington web accessibility law framework also intersects with federal obligations under the ADA and Section 508, which means agencies must align with multiple standards at once.
| Element | Details |
|---|---|
| Issuing Authority | Washington Technology Services (WaTech) Office of the Chief Information Officer (OCIO) |
| Who Must Comply | Executive branch state agencies, boards, commissions, and certain institutions of higher education |
| Technical Standard | WCAG 2.0 Level AA for web content; Section 508 referenced for software and hardware |
| Scope | Websites, web apps, mobile apps, documents, software, procurement, and internal IT |
| Related Requirements | ADA Title II, Section 508, and the 2024 DOJ rule mandating WCAG 2.1 AA for state and local government |
What Is Policy 188?
Policy 188 is Washington State’s accessibility policy, issued by the Office of the Chief Information Officer under WaTech. It directs covered agencies to make their IT accessible to employees, contractors, and members of the public with disabilities.
The policy frames accessibility as a procurement, development, and operations requirement, not a one-time project. Agencies are expected to build accessibility into vendor contracts, design phases, content publishing workflows, and ongoing maintenance.
Who Does Washington Web Accessibility Law Apply To?
Policy 188 covers Washington executive branch agencies, along with boards and commissions that fall under WaTech’s authority. Many higher education institutions in Washington also align with the policy or follow parallel standards.
Local governments in Washington, including cities, counties, and school districts, are not directly bound by Policy 188. However, they are bound by ADA Title II, which now requires WCAG 2.1 Level AA conformance for web content and mobile apps under the 2024 Department of Justice rule.
What Standards Does Policy 188 Reference?
Policy 188 points to WCAG 2.0 Level AA as the baseline technical standard for web content. For software and hardware, it references Section 508 of the Rehabilitation Act, which was updated in 2018 to incorporate WCAG 2.0 AA criteria.
While Policy 188 itself still cites 2.0 AA, most agencies are moving toward WCAG 2.1 AA or WCAG 2.2 AA to align with the federal ADA Title II rule and modern procurement expectations. Auditing against 2.1 AA is the practical baseline for any covered entity today.
What Does Policy 188 Require Agencies to Do?
The policy sets expectations across several areas. Agencies must designate an accessibility coordinator, publish an accessibility plan, and document conformance for digital assets.
Core obligations include procuring IT products and services that meet accessibility standards, often documented through an ACR. Agencies must also design and develop new web content and applications to WCAG conformance levels, train staff who create digital content (including authors of documents and web pages), remediate issues identified in audits or user reports, and post an accessibility statement with contact information for accommodation requests.
How Does Policy 188 Interact With Federal Law?
Washington agencies sit at the intersection of state and federal accessibility requirements. Policy 188 is the state-level directive, but ADA Title II governs all state and local government services, programs, and activities, including digital ones.
The 2024 DOJ final rule under Title II set firm deadlines for WCAG 2.1 Level AA conformance. Large public entities had until April 2026, and smaller entities had until April 2027. For Washington agencies, this means Policy 188’s 2.0 AA baseline is no longer sufficient on its own, and 2.1 AA work is required regardless of internal policy timing.
How Do Agencies Verify Conformance?
Conformance is verified through an accessibility audit. A manual accessibility audit evaluates each in-scope page or screen against the applicable WCAG success criteria and identifies issues with severity ratings and recommended fixes.
Automated scans only flag approximately 25% of issues, which is why they cannot stand in for an audit when documenting conformance. Agencies frequently pair an audit with ongoing scanning to monitor regressions between full evaluations.
For software and SaaS products purchased by agencies, vendors are typically asked to provide an Accessibility Conformance Report. Learning how an ACR is produced helps procurement teams evaluate vendor documentation rather than accepting it at face value.
What Happens After an Audit?
After an audit identifies issues, agencies move into accessibility remediation. Development and content teams work through the report, applying fixes in priority order based on user impact and risk.
Once fixes are in place, validation confirms each issue has been resolved correctly. Agencies that procure third-party software should also confirm vendor remediation timelines and request updated ACRs after fixes ship.
FAQ
Does Policy 188 require WCAG 2.1 AA or 2.0 AA?
Policy 188 cites WCAG 2.0 Level AA as its baseline. However, Washington agencies covered by ADA Title II must also meet WCAG 2.1 Level AA under the 2024 DOJ rule, so 2.1 AA is the practical standard.
Do Washington cities and school districts have to follow Policy 188?
No. Policy 188 applies to executive branch state agencies. Cities, counties, and school districts are covered by ADA Title II, which has its own WCAG 2.1 AA requirement and compliance deadlines.
What documents prove accessibility conformance under Policy 188?
An accessibility audit report documents the evaluation of a specific digital asset against WCAG. For procured software, an ACR documents vendor conformance. Agencies often maintain both as part of their accessibility documentation.
Can an automated scan satisfy Policy 188 evaluation needs?
No. Scans detect a limited share of accessibility issues and cannot determine WCAG conformance. A manual audit conducted by qualified auditors is required to evaluate conformance and produce a report agencies can rely on.
How often should a Washington agency audit its website?
A full audit once per year is a reasonable cadence, with additional audits after major redesigns or platform changes. Between audits, scanning and content review help catch new issues before they accumulate.
Policy 188 sets the floor for Washington agencies, but the federal Title II rule sets the ceiling agencies actually need to hit. Treating the two together, rather than separately, is the cleanest way to plan an accessibility program.
Contact Accessible.org to discuss an audit, ACR, or remediation support for your agency or vendor product: Contact Accessible.org.
