What Is OMB M-23-22 and What Does It Require of Federal and State Websites?

TL;DR: OMB Memorandum M-23-22, “Delivering a Digital-First Public Experience,” is guidance from the Office of Management and Budget that directs federal agencies to build websites and digital services that are accessible, mobile-friendly, fast, secure, and written in plain language. It operationalizes the 21st Century IDEA Act and sets concrete expectations: WCAG conformance, consistent design, performance standards, and human-centered service design. It binds federal agencies — not state or local governments — but it has become the de facto reference for what a modern public-sector digital experience should look like, and many states model their standards on it.

If you run a federal website, OMB M-23-22 is one of the most consequential documents on your desk. Issued by the Office of Management and Budget in September 2023, it moves federal digital service from aspiration to expectation, translating the high-level goals of the 21st Century Integrated Digital Experience Act (IDEA) into specific, actionable requirements. And if you run a state digital service, M-23-22 still matters: it’s the clearest articulation of best practice in U.S. government, and state digital service teams routinely borrow its framework even though it doesn’t legally bind them.

This guide explains what M-23-22 is, what it requires across accessibility, design, plain language, and performance, who it applies to, and how state and local teams can use it as a model. For the statutory backdrop, pair this with our overview of the 21st Century IDEA Act and federal websites.

What M-23-22 Is

OMB memoranda are policy directives issued to executive-branch agencies. They carry significant weight: agencies are expected to comply, and OMB tracks implementation. M-23-22 is titled “Delivering a Digital-First Public Experience,” and it implements the 21st Century IDEA Act (passed in 2018), which had set goals for federal websites — accessibility, consistency, mobile-friendliness, and so on — without spelling out the operational detail. M-23-22 supplies that detail.

The core philosophy is digital-first and human-centered: the public’s default experience with government should be a high-quality digital one, designed around the needs of real people rather than the structure of the agency. The memo organizes its requirements around the full lifecycle of a digital service — from the first web page a person finds to the form they submit and the notification they receive afterward.

Who It Applies To

This is the most common point of confusion, so it’s worth being explicit.

• M-23-22 binds federal executive-branch agencies. If you work for a federal department, bureau, or agency, the memo applies to your public websites, web-based services, and digital products.
• It does not bind state, local, tribal, or territorial governments. A city, county, public university, or state agency is not legally subject to M-23-22.
• But it is widely influential. State digital service teams, university web offices, and modern city governments frequently adopt its principles because it represents the current consensus on good public-sector digital experience. Many state “digital standards” and design systems are visibly modeled on the federal approach M-23-22 codifies.

So the practical answer to “does this apply to me?” is: legally, only if you’re federal; aspirationally, to anyone building government digital services. For state and local legal obligations, the binding standard is the DOJ 2024 final rule under ADA Title II, not M-23-22.

What It Requires

M-23-22 spans the full digital experience. Here are the major requirement areas in plain language.

1. Accessibility

Accessibility is foundational, not optional. M-23-22 reinforces that federal digital services must be accessible to people with disabilities, consistent with Section 508 and WCAG. Agencies are expected to:

• Conform to WCAG Level AA success criteria
• Test with assistive technologies, not just automated scanners
• Treat accessibility as a design and development requirement from the start, not a remediation afterthought
• Make digital documents (PDFs and other files) accessible

Because federal accessibility runs through Section 508, it’s worth understanding how that framework differs from the state/local Title II framework — see Section 508 vs. ADA Title II. Either way, the underlying technical standard is WCAG; if WCAG is new to you, start with what WCAG means for government websites.

2. Consistent, modern design

The memo pushes for a consistent visual and interaction design across federal digital services so the public experiences government as coherent rather than as hundreds of disconnected sites. In practice this means:

• Using a shared design system (the U.S. Web Design System, USWDS, is the federal standard)
• Consistent navigation, layout, and components
• Responsive, mobile-first design — a large and growing share of the public reaches government on phones
• Designs that work across browsers and assistive technologies

The accessibility benefit here is real: consistent, well-engineered components mean predictable keyboard navigation and reliable color contrast across the whole property.

3. Plain language

M-23-22 requires content written in plain language — clear, concise, and understandable by the intended audience. This builds on the Plain Writing Act and is itself an accessibility and equity measure: dense bureaucratic prose excludes people with cognitive disabilities, limited literacy, and limited English proficiency. Agencies are expected to:

• Write at an appropriate reading level for the audience
• Use clear headings, short sentences, and active voice
• Avoid jargon and acronyms, or define them
• Structure content so people can find answers quickly

Plain language is one of the most overlooked dimensions of accessibility. It overlaps with WCAG’s guidance on readable, understandable content and with the broader principle behind web accessibility for government.

4. Performance and reliability

A page that doesn’t load fast enough or fails on a slow connection isn’t truly accessible to everyone. M-23-22 sets expectations around performance, availability, and reliability:

• Fast page loads and responsiveness, including on mobile and low-bandwidth connections
• High availability and uptime
• Monitoring and continuous improvement of performance

This maps cleanly onto the same web performance metrics private-sector sites track. For the practical version of this on government sites, see Core Web Vitals for government websites.

5. Security and privacy

The memo also reinforces that digital services must be secure and protect user privacy — using HTTPS, following federal security guidance, and handling personal data responsibly. Security and accessibility are often treated as separate workstreams, but they’re both part of a trustworthy public experience. See security headers for government websites and CISA cybersecurity guidance for government sites.

6. Human-centered, data-driven service design

Underpinning all of the above is a methodological requirement: agencies should design around user needs, test with real users, measure outcomes, and improve continuously. This is the “human-centered design” thread that runs through the entire memo. The implication is that compliance isn’t a one-time launch event — it’s an ongoing practice of measuring and improving.

Federal-Specific Mechanics

A few elements of M-23-22 are specific to how the federal government operates:

• Designated lead. Agencies are expected to designate responsibility for digital experience, ensuring someone owns these outcomes rather than leaving them to diffuse across teams.
• Inventory and prioritization. Agencies are expected to inventory their websites and digital services and prioritize the highest-traffic, highest-impact ones for improvement.
• Use of shared standards and tools. Reliance on USWDS, shared services, and common platforms rather than every agency reinventing the basics.
• Reporting. OMB tracks progress, which gives the memo teeth that purely advisory guidance lacks.

What State and Local Teams Should Take From It

If you’re at a state agency, county, city, or public university, M-23-22 isn’t a legal obligation — but it’s an excellent blueprint. Here’s how to use it:

1. Treat WCAG AA as the accessibility floor. This is also your actual legal requirement under the ADA Title II 2026 deadline, so adopting the federal posture aligns you with both.
2. Adopt a design system. You don’t have to use USWDS, but consistency across your properties reduces accessibility defects and maintenance cost.
3. Invest in plain language. It’s cheap, high-impact, and improves both accessibility and resident satisfaction.
4. Measure performance. Page speed and mobile experience materially affect who can actually use your services.
5. Build continuous monitoring, not point-in-time launches. The human-centered, “measure and improve” ethos of M-23-22 is the single most transferable idea — and the one most government teams skip.

For a structured starting point, our government website compliance checklist and accessibility audit guide translate these principles into concrete tasks.

How M-23-22 Fits the Broader Landscape

It helps to see where M-23-22 sits relative to the other major frameworks:

M-23-22 is the operational layer for federal agencies, sitting on top of the IDEA Act and incorporating Section 508. For state and local governments, the binding analog is the DOJ rule — but the quality bar M-23-22 describes is what excellent public-sector teams aim for everywhere.

OMB M-23-22 is, at its heart, a statement that the public deserves a government digital experience that is accessible, clear, fast, and designed around real human needs — and that meeting that bar is an ongoing discipline, not a one-time project. Whether you’re a federal agency bound by the memo or a state or local team using it as a model, the through-line is continuous measurement and improvement. Govzu supports that discipline by continuously monitoring government websites for accessibility, performance, and security issues, so your team can hold the line on a digital-first experience long after launch day.