Understanding New York Executive Law §170‑F

Website Accessibility for Contractors and Vendors

New York Executive Law §170‑F is a key piece of legislation that directly links accessibility requirements to state contracts and vendor obligations.

Unlike broader accessibility laws that define rights or expectations, §170‑F establishes a clear and enforceable requirement: if an organization is delivering services to the State of New York, its digital properties must meet recognized accessibility standards.

This law is particularly important because it extends accessibility responsibility beyond government agencies to include private-sector organizations working with the state.

Note: This content is provided for general information only and does not constitute legal advice. If you need a formal interpretation of requirements for your organization, consult qualified legal counsel and your compliance team.

New York Executive Law §170-F at a glance

New York Executive Law §170-F requires contractors, vendors, consultants, and service providers working under State contracts to ensure covered websites conform to the most current version of WCAG.

The law extends accessibility responsibilities beyond government agencies to include private-sector organizations delivering services on behalf of the State.

Accessibility becomes part of procurement and contract delivery, not simply a technical best practice.

Vendors may be required to demonstrate accessibility compliance before solutions are accepted or deployed.

The law works alongside State technology policies and accessibility requirements to create accountability for both agencies and vendors.

Purpose of the Law

The primary purpose of Executive Law §170‑F is to ensure that any digital service provided as part of a state-funded or state-supported initiative is accessible to individuals with disabilities.

The law requires that accessibility is not treated as an internal government responsibility alone. Instead, it ensures that:

Vendors delivering services on behalf of the state meet accessibility standards

Public-facing digital services are consistently accessible, regardless of who builds them

Accessibility is embedded into state procurement and contracting practices

Scope of Application

Executive Law §170‑F applies to a broad range of entities involved in delivering services to the state. These include:

Contractors

Subcontractors

Vendors

Consultants

Any entity providing services under a New York State contract

Crucially, the law applies specifically to websites provided as part of those services.

This means that if a vendor delivers a website, portal, or digital interface as part of a contract, that digital service falls within the scope of the law.

Core Requirement

The central requirement of §170‑F is clear and specific:

Any website provided under a state contract must conform to the most current version of the Web Content Accessibility Guidelines (WCAG).

This establishes WCAG as the mandatory technical benchmark for vendors working with New York State.

What This Means in Practice

Executive Law §170‑F fundamentally changes how accessibility is enforced by linking it directly to contract eligibility and delivery obligations.

In practice, this means:

Accessibility is not optional for vendors

Non-compliant solutions may be rejected at procurement stage

Accessibility must be demonstrated, not assumed

Vendors are accountable for the accessibility of their deliverables

This applies to:

Websites and portals built for state services

Digital platforms supporting public programs

Systems used by citizens to access services

Relationship to Other New York Requirements

Executive Law §170‑F does not operate in isolation. It works alongside other regulatory frameworks:

State Technology Law §103‑d
→ Applies accessibility requirements to state agencies

ITS Accessibility Policy (NYS‑P08‑005)
→ Provides implementation guidance and governance expectations

Importantly, the ITS policy explicitly states that §170‑F requirements must be followed by vendors delivering services under state contracts.

Together, these frameworks create a closed loop of accountability:

Agencies must procure accessible systems

Vendors must deliver accessible systems

WCAG is the shared standard

Why This Law Is Important

Executive Law §170‑F is significant because it operationalizes accessibility in a way that many jurisdictions do not.

It ensures that:

Accessibility is embedded in procurement, not just policy
Vendors cannot shift responsibility back to the state
Digital services are consistently accessible across systems

For organizations, this means accessibility is directly tied to:

Revenue opportunities
Contract eligibility
Delivery success

Common Risk Areas for Vendors

Organizations working with New York State may face risk under §170‑F if they:

Deliver websites that do not meet WCAG standards
Provide inaccessible forms or workflows within contracted systems
Rely on third-party tools that introduce accessibility barriers
Fail to test and validate accessibility before delivery

These issues are not just technical defects. They may lead to:

Contract non-compliance
Rework requirements
Loss of business opportunities

Practical Interpretation

Executive Law §170‑F shifts accessibility into the commercial and operational domain.

The key question is no longer:

Is accessibility a best practice?

Instead, it becomes:

Is this solution accessible enough to meet contractual obligations?

If the answer is no, the organization may not be able to deliver under the contract.

Key Takeaway

New York Executive Law §170‑F makes accessibility a mandatory requirement for vendors delivering digital services to the state. By requiring WCAG conformance as part of contractual obligations, it ensures that accessibility is consistently enforced across both public and private sectors.

How 4Point can help

Start with an accessibility audit. If you’re unsure where you stand against federal expectations and WCAG, 4Point can run a practical audit to establish a baseline, identify the highest-risk barriers, and give you a prioritized remediation roadmap.

Scoping session: 4Point will confirm which forms are in scope, the number to be reviewed, and the accessibility standard(s) to assess against.
Forms accessibility audit: 4Point will review an agreed number of forms and document accessibility gaps.
Conformance report and prioritization: 4Point will provide conformance findings, severity ratings, and a recommended fix order.
Recommendations and remediation plan: 4Point will share recommendations for addressing identified gaps and provide a statement of work for remediation of the audited forms (remediation is not included in the audit engagement).

Next step: request an audit by sharing your digital scope (properties, platforms, documents), your target standard (e.g., WCAG 2.1 AA), and any upcoming procurement or reporting deadlines. We’ll confirm the audit approach, sample size (templates/journeys), and deliver a prioritized findings summary with recommended fixes.

Contact 4Point: Request an accessibility audit

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