Missouri: comparable access in state IT, now measured against WCAG 2.2

RSMo 161.935 binds state departments and agencies. It applies when they develop, buy, maintain or use information technology, and also when they administer contracts or grants that pay for IT. Local governments and private businesses are not covered by it.

Unless an undue burden would result, agencies must make sure their IT lets employees, program participants and members of the public reach information and data comparable to people without disabilities. The council works with the state's IT services division to adopt standards for procurement, custom systems, websites and emerging technology, review custom systems before state money is spent, train staff, involve people with disabilities, and set complaint procedures.

The standard in force is Missouri State ICT Standard 3.0, which requires WCAG 2.2 Level A and AA for public sites, applications, intranets and internal communications. The WCAG 2.2 version took effect on 5 October 2025 with a compliance deadline of 6 April 2026.

State law here adds to federal law; it does not replace it. Every city, county, school district and special district in Missouri is bound by the federal Title II web rule, 28 CFR 35.200, which requires WCAG 2.1 Level AA on web content and mobile apps: from April 26, 2027 for public entities of 50,000 people or more, and from April 26, 2028 for smaller entities and special districts. State agencies are bound by the same rule at the earlier date.

Private businesses open to the public answer to ADA Title III. A private plaintiff can sue for an injunction and ask for attorney's fees; the Department of Justice can sue for damages and civil penalties. No federal regulation names a web standard for businesses, so audits use WCAG 2.1 or 2.2 Level AA as the working benchmark.

Missouri's state standard is WCAG 2.2, one version ahead of the federal Title II rule, which names WCAG 2.1. WCAG 2.2 adds A and AA success criteria including 2.4.11 Focus Not Obscured (Minimum), 2.5.7 Dragging Movements, 2.5.8 Target Size (Minimum), 3.2.6 Consistent Help, 3.3.7 Redundant Entry and 3.3.8 Accessible Authentication (Minimum), and it removes 4.1.1 Parsing as obsolete. For a state agency in Missouri, meeting the state standard also meets the federal one; the reverse is not true.

A vendor selling to a Missouri agency should test against WCAG 2.2 AA, not 2.1, because the state standard has moved ahead of the federal Title II rule. A Missouri city or county is bound by the federal rule at WCAG 2.1 AA, not by this statute.