California businesses have been watching Assembly Bill 2190 because it proposed a detailed statutory framework for internet website accessibility claims, including WCAG-based standards, digital accessibility reports, remediation timelines, and potential responsibility for certain third-party website providers.
The first fact businesses should understand is the most important one: AB 2190 is not currently enacted California law. The California Legislature lists the bill as having been ordered to the inactive file on May 21, 2026, at the request of Assembly Member Greg Wallis. As of September 2026, businesses should not describe its proposed protections or obligations as if they are already in force.
Even so, the bill is worth understanding because it shows how California lawmakers have been thinking about website accessibility, remediation, documentation, and the relationship between businesses and the vendors that build or maintain their websites.
What is California AB 2190?
AB 2190, titled “Internet website accessibility,” was introduced in February 2026 and amended in April. The proposal would add a new part to the California Civil Code dealing with attorney’s fees and statutory damages in internet website accessibility claims.
The bill was developed against the background of the Unruh Civil Rights Act and California’s disability-access laws. California website accessibility litigation can involve both federal ADA theories and state-law claims, so the proposed bill attempted to create a more specific framework around digital accessibility.
What accessibility standard did the bill propose?
The April 23, 2026 amended text defined an “internet website accessibility standard” using WCAG. Under that version, WCAG 2.1 Level AA would be the referenced standard before January 1, 2028, and WCAG 2.2 Level AA would be referenced on or after January 1, 2028, subject to provisions for certain federal standards.
That would have been significant because private-business website accessibility obligations under federal ADA Title III do not currently operate through one universal federal regulation that simply says every private website must conform to WCAG 2.2 AA. The proposed California framework was much more explicit about the technical benchmark.
The proposed digital accessibility report was a major feature
AB 2190 did not focus only on whether a website had defects. It also proposed a structured documentation mechanism called a “digital accessibility report.”
Under the amended bill text, the report would have included information such as:
- where a specific accessibility barrier appeared;
- the function or component affected;
- a description of the barrier and user impact;
- the relevant accessibility criterion when applicable;
- who the business believed was responsible for the barrier;
- when the barrier was identified;
- an expected remediation date;
- the actual remediation date; and
- a historical record of reported barriers.
This concept is commercially important even though the bill is not law. It reflects a broader trend toward treating accessibility as an operational process: identify barriers, document them, assign ownership, remediate, verify, and maintain records.
AB 2190 proposed an affirmative defense tied to documented accessibility efforts
The amended bill proposed an affirmative defense to certain claims for statutory damages involving a specific website accessibility barrier if specified conditions were met and evidence was provided to the plaintiff within the proposed timeframe.
One path involved disclosing a specific barrier through a digital accessibility report and documenting remediation within 45 days. Another path involved a broader record of good-faith accessibility practices, including regular automated and manual testing, timely remediation, an accessibility page, a process for users to report barriers, and record retention.
This was not a blanket immunity provision. The proposed defense was detailed and conditional, and the bill expressly preserved other rights and remedies.
Why website owners should pay attention to the vendor provisions
Another notable part of AB 2190 concerned “resource service providers” — entities that build, license, distribute, or maintain websites or website resources for compensation.
The proposal would have prohibited certain providers from negligently, recklessly, or knowingly causing website resources under their control to be inaccessible or nonconformant, and from making false representations about accessibility. It also contemplated civil actions in specified circumstances.
For web agencies, SaaS vendors, plugin developers, e-commerce providers, and website maintenance companies, this is a signal that accessibility responsibility may increasingly become part of contracts, procurement, warranties, and vendor selection — even where a particular bill does not become law.
What is the status of AB 2190 now?
AB 2190 was ordered to the inactive file in May 2026 and is not enacted law.The official California Legislature status page shows that AB 2190 passed several committee votes in April and May 2026. On May 18 it was ordered to third reading, and on May 21 it was ordered to the inactive file at the author’s request.
That means businesses should be careful with headlines claiming that “California passed a new website accessibility law” based on AB 2190. It did not become enacted law in its current status.
Legislation can change, return in another vehicle, or influence later proposals, so businesses that operate in California should monitor the official Legislature website rather than relying on old vendor blog posts.
What California businesses should do even without AB 2190
The practical accessibility work does not need to wait for a new statute. California businesses can reduce digital barriers and create stronger documentation now.
- Identify critical customer journeys. Prioritize booking, ordering, checkout, forms, account access, menus, product search, and other revenue or service workflows.
- Combine automated and manual testing. Automated scans can find many code-level issues, but keyboard, screen-reader, focus, error handling, and complex interaction problems often require human review.
- Create a developer-ready remediation backlog. Each issue should identify the affected component, user impact, relevant standard, reproduction steps, and recommended fix.
- Retest fixes. A ticket marked “done” is not the same as a verified accessibility fix.
- Maintain an accessibility feedback channel. Customers should have a clear way to report barriers and request assistance.
- Keep records of testing and remediation. Documentation can help teams manage accessibility as an ongoing quality process and can be useful when working with counsel, insurers, customers, or vendors.
What AB 2190 signals for web agencies and developers
Even though AB 2190 is inactive, the bill should get the attention of agencies that market “ADA compliant websites” or promise automatic compliance through a plugin or widget.
Accessibility claims should be precise. A responsible provider should be able to explain what was tested, which standard was used, whether manual testing was performed, which third-party components are outside its control, what remains unresolved, and how regression testing works after future changes.
That is a stronger commercial position than offering a vague “100% ADA compliance” promise that cannot realistically be guaranteed.
The business takeaway
AB 2190 is not currently law, but its structure is informative. It emphasizes the same operational elements mature accessibility programs already use: standards, testing, documentation, remediation, user feedback, vendor accountability, and ongoing maintenance.
If your business operates in California and you want to understand the accessibility barriers on your website, request a Website Accessibility Review. ADA Access Group provides technical accessibility testing and remediation support; for legal advice about California claims, statutory exposure, or litigation strategy, consult qualified legal counsel.
Sources
- California Legislature — AB 2190 status
- California Legislature — AB 2190 amended bill text
- California Assembly Privacy and Consumer Protection Committee — AB 2190 analysis
This article is general technical and business information, not legal advice. The status and text of legislation can change; verify current information with official California sources and qualified counsel.