What is NYCHRL?
The New York City Human Rights Law prohibits discrimination in public accommodations based on protected characteristics, including disability. In 2020, NYC explicitly clarified that this includes websites and digital services. Official information: NYC Commission on Human Rights
Applies to any entity operating in NYC (regardless of headquarters location)
Covers physical locations AND digital services equally
Enforced by NYC Commission on Human Rights (CCHR)
Private enforcement: Individuals can sue directly without government filing first
Monetary damages awarded directly to individuals
Scope and Coverage
NYCHRL applies very broadly to any business operating in NYC that provides goods, services, or accommodations to the public. NYCHRL applies even if your company is not based in NYC. If you do business with NYC residents or your website is accessible to NYC users, you must comply.
Retail businesses with websites
Restaurants and hospitality
Banks and financial services
Healthcare providers
E-commerce platforms
SaaS companies serving NYC clients
Non-profits and charities
Government agencies
Any business website accessible from NYC
Accessibility Standard: WCAG 2.1 Level AA
While NYCHRL doesn't mandate a specific standard, the CCHR and courts have endorsed WCAG 2.1 Level AA as the accessibility benchmark for compliance. WCAG reference: WCAG 2.1 Quick Reference
4.5:1 color contrast for normal text
3:1 contrast for large text (18pt+)
Keyboard navigation for all functionality
Alt text for all images
Captions and transcripts for video
Proper HTML heading structure
Form labels and error identification
Support for zoom up to 200%
Screen reader compatibility
Focus indicators visible at all times
Enforcement by NYC Commission on Human Rights
NYCHRL is uniquely powerful because enforcement is decentralized. Both individuals and the CCHR can take action. File a complaint: CCHR File a Complaint
People with disabilities can file complaints directly with CCHR
Individuals can sue in court for damages
No requirement to file with government first
Damages paid directly to individual complainant
Attorney fees typically awarded to plaintiffs
CCHR investigates accessibility complaints
Issues violation notices and fines
Can issue cease-and-desist orders
Conducts public hearings on violations
Posts violation records publicly
Penalties and Damages
NYCHRL violations carry significant financial consequences through both CCHR penalties and private lawsuits. Recent NYCHRL accessibility settlements include:
Civil penalties: Up to $250,000 per violation
Separate penalty for each day of violation
Damages awarded to affected individuals
Mandatory remediation orders
Attorney fees and costs
Compensatory damages for harm/lost access
Statutory damages: $500-$750 per violation
Attorney fees (typically awarded)
Multiple claims possible per plaintiff
Cumulative from many individual claimants
Retail chains: $50,000-$200,000+ settlements
Financial institutions: $100,000+ settlements
E-commerce platforms: $150,000+ settlements
Healthcare providers: $25,000-$100,000 settlements
Why NYC is an Accessibility Litigation Hotspot
NYCHRL creates unique incentives that have made NYC the center of digital accessibility litigation: NYC accessibility lawsuits increased dramatically post-2020, creating precedent that other jurisdictions now follow.
Private enforcement: Individuals don't need government permission to sue
Attorney fee awards: Make cases economically viable
Cumulative damages: Multiple claims from multiple plaintiffs
Aggressive CCHR: Active investigation and enforcement
Large plaintiff bar: Many lawyers willing to take accessibility cases
Extraterritorial reach: Applies to any company serving NYC
Public companies most vulnerable: High visibility targets
Steps to Achieve NYCHRL Compliance
Organizations doing business in NYC should prioritize accessibility remediation immediately. CCHR guidance: NYC Commission on Human Rights
Audit websites against WCAG 2.1 Level AA
Identify critical barriers (forms, payments, navigation)
Prioritize high-traffic/critical functions
Assess mobile app accessibility (if applicable)
Fix blocking issues immediately
Implement alt text for images
Ensure keyboard navigation
Test with screen readers
Verify color contrast ratios
Publish accessibility statement on website
Establish accessibility feedback mechanism
Train development team on accessible coding
Include accessibility in QA process
Regular testing and remediation
Document remediation efforts
Keep accessibility test results
Record staff training
Maintain audit trails
Evaluate Your NYCHRL Risk
NYC accessibility litigation is unprecedented. Assess your exposure and compliance status today.