WCAG Rules for City Website Contracts - New York City
When contracting to build or maintain city websites in New York City, New York, agencies require compliance with recognized accessibility standards. This checklist explains how procurement teams and vendors must reference WCAG, perform accessibility testing, document conformance, and manage remediation during the contract lifecycle. Follow agency requirements, include clear contract language, collect conformance evidence, and use official complaint and inspection channels so city websites remain usable for all New Yorkers.
What the city requires
New York City agencies generally require web and digital content to meet WCAG standards as part of procurement and contract administration. Include an explicit accessibility clause in solicitations, require an Accessibility Conformance Report (for example, a VPAT) from vendors, and specify automated and manual testing before acceptance. Procurement oversight and technical policy are handled at the agency level; contract review and enforcement involve procurement offices and the Department of Information Technology and Telecommunications (DoITT). [1]
Penalties & Enforcement
Enforcement and remedies for noncompliance vary by agency and contract. Official city policy pages describe standards and procurement responsibilities, but specific fines and statutory penalty figures are generally not listed on those policy pages. Where monetary penalties or specific administrative fines apply, they are set in contract terms, agency rules, or procurement board regulations rather than on high-level accessibility guidance pages. [1] For procurement enforcement and contract compliance procedures, contracting officers and the Department of Citywide Administrative Services (DCAS) handle oversight. [2]
- Escalation: first notice, required remediation period, and possible contract withholding or termination; exact timeframes are usually set in the contract (not specified on the cited page).
- Fines: monetary penalties or liquidated damages are set by contract or agency rule (not specified on the cited page).
- Non-monetary sanctions: remediation orders, corrective action plans, withholding of payments, suspension or termination of contract, and referral to agency legal counsel/city law for enforcement.
- Complaint and inspection pathways: agency procurement office, DoITT accessibility contacts, and city complaint portals; see Help and Support / Resources below for official contact pages.
- Appeals and review: protest and appeal rights follow procurement rules and contract dispute processes; specific time limits are defined in solicitation documents or procurement rules (not specified on the cited page).
Applications & Forms
There is no single universal form for accessibility compliance published on the high-level policy pages; agencies typically ask for an Accessibility Conformance Report (ACR) or VPAT, test reports, and evidence of manual testing during proposal or post-award review. If a formal form is required, the solicitation will list the name and submission method. [1]
Practical contract checklist
- Include an explicit accessibility clause requiring WCAG 2.1 AA (or the version specified by the agency) and reference required conformance documentation.
- Require a vendor-supplied VPAT/ACR and source test reports from automated and manual testing.
- Set milestones for accessibility testing, remediation windows, and acceptance criteria.
- Include warranty and maintenance obligations for ongoing accessibility fixes after deployment.
- Define dispute, inspection, and enforcement paths consistent with procurement rules and agency contacts.
Action steps for vendors and contracting officers
- Before proposal: prepare a VPAT/ACR and sample remediation plan.
- During delivery: run automated scans and manual testing, log issues, and provide remediation timelines.
- On noncompliance: follow contract cure periods, negotiate remediation, and engage procurement counsel if disputes arise.
FAQ
- Do New York City agencies require WCAG conformance for websites?
- Yes; city policy requires agencies to follow recognized accessibility standards and to include accessibility requirements in contracts and solicitations. [1]
- What proof of conformance should vendors provide?
- Vendors should provide an Accessibility Conformance Report (VPAT), automated scan reports, manual test results, and a remediation plan for any failures.
- Who enforces accessibility in city contracts?
- Contracting agencies and procurement oversight offices enforce accessibility obligations; DoITT provides technical policy and DCAS or agency procurement offices manage contract compliance. [2]
How-To
- Review the agency solicitation and note the required WCAG level and acceptance tests.
- Prepare a VPAT/ACR and include evidence of automated and manual testing.
- Submit conformance documentation with your proposal or as required post-award.
- If issues are found, implement the remediation plan within the contract cure period and document completion.
- Use agency complaint and procurement protest procedures if there is a dispute about compliance or acceptance.
Key Takeaways
- Include explicit WCAG clauses and evidence requirements in every solicitation.
- Require VPAT/ACR, automated scans, and manual testing before acceptance.
- Enforcement and remedies are handled through agency procurement processes and contract terms.
Help and Support / Resources
- DoITT - Department of Information Technology & Telecommunications
- DCAS - Department of Citywide Administrative Services
- MOPD - Mayor's Office for People with Disabilities
- Mayor's Office of Operations