OMB Memo M-23-22 — Federal Digital Experience & Web Standards

OMB Memorandum M-23-22 ("Delivering a Digital-First Public Experience," September 22, 2023) directed all executive branch agencies to transform how they deliver government services online — shifting from paper-centric, phone-dependent processes to genuinely usable digital services that work well on any device, are accessible to all users, and meet a consistent set of design and technology standards. Issued by OMB Deputy Director Jason Miller, M-23-22 implements the 21st Century Integrated Digital Experience Act (21st Century IDEA Act, P.L. 115-336, enacted December 2018), which requires agencies to modernize federal websites, digitize paper forms, and use the U.S. Web Design System as the standard framework for all public-facing federal digital properties.

The memo addresses a persistent failure mode of federal digital services: agencies that have websites but not usable ones. Studies consistently found that many federal websites failed accessibility standards, were not mobile-compatible, required users to download PDFs or visit a physical office to complete tasks, and offered poor or no search functionality. M-23-22 gives these problems deadlines and accountability mechanisms — requiring agencies to track their highest-impact services, set improvement targets, and report progress to GSA through the Federal Website Index.

Legal Authority

• 21st Century Integrated Digital Experience Act (21st Century IDEA Act, Pub. L. 115-336, December 2018) — Requires agencies to modernize their websites to be accessible, mobile-friendly, and compliant with the U.S. Web Design System; requires digitization of paper-based forms; requires all new and redesigned websites to comply with USWDS; directs OMB to issue implementing guidance
• 44 U.S.C. § 3601 — E-Government Act; promotes the use of internet-based information technology to enhance government services; authorizes OMB to establish e-government standards
• Section 508 of the Rehabilitation Act (29 U.S.C. § 794d) — Requires federal electronic and information technology to be accessible to individuals with disabilities; M-23-22 incorporates Section 508 compliance as a mandatory digital experience standard
• OMB Memorandum M-23-22 (September 22, 2023) — Implements 21st Century IDEA Act; establishes digital experience standards (USWDS adoption, accessibility, mobile-first design, search, analytics), the Federal Website Index for tracking compliance, and deadlines for digitizing forms and improving high-impact digital services

Key Mechanics

M-23-22 requires agencies to identify their high-impact public-facing services (those with the most user interactions) and establish improvement plans with measurable targets. Core requirements: (1) U.S. Web Design System (USWDS) adoption — all new and substantially redesigned federal websites must use USWDS components and tokens, ensuring consistent visual identity and built-in accessibility compliance; (2) Accessibility — all federal websites must meet WCAG 2.1 AA standards (Section 508 compliance); agencies must test and remediate accessibility issues on a defined schedule; (3) Mobile-first design — all public-facing websites must be fully functional on mobile devices; (4) Search — agencies must provide functional search that indexes their digital content; (5) Form digitization — agencies must identify all paper-based or PDF forms that can be digitized and publish a prioritized digitization roadmap; (6) Federal Website Index — all federal websites must be registered in GSA's Federal Website Index, which tracks compliance with digital standards. Agencies must report annually to OMB on digital experience improvement progress. The CIO of each agency is responsible for implementing M-23-22; GSA's Technology Transformation Services provides technical assistance and the USWDS codebase.

Overview

What This Memo Requires

Digitizing Paper-Based Services

The core mandate of M-23-22 is the shift to digital-first: agencies must identify their highest-impact public-facing services — those used most frequently or by the most users — and ensure they can be completed fully online without requiring a paper form, in-person visit, or phone call. For most services, this means:

• Building or improving an online form or application that accepts user input electronically
• Creating a digital authentication pathway so users can verify their identity online
• Enabling electronic signature where legally permitted
• Providing status tracking so users can check where their request stands without calling
• Sending confirmation and status updates via email or text

Within one year of the memo's issuance (September 2024 target), agencies were required to identify their top-tier public-facing services and submit a digitization plan to OMB covering which services would be digitized, in what timeframe, and what the current barriers are (legal, technical, or budget). Agencies that cannot fully digitize a service within the one-year window must explain why and propose a realistic timeline.

U.S. Web Design System (USWDS)

All new federal public-facing websites and all significant redesigns must use the U.S. Web Design System (USWDS) — an open-source design system maintained by GSA that provides standardized components, typography, color palettes, and design patterns. USWDS compliance does not mean that all federal websites look identical, but it means they use common components (navigation patterns, form components, alert banners, buttons) that are accessible, tested, and consistent with established usability best practices.

The practical requirement: agencies must demonstrate USWDS adoption through a maturity score (a self-reported metric measuring how much of a site's front-end uses USWDS components vs. custom code). GSA tracks USWDS adoption across the federal web and publishes the data through the Federal Website Index. Agencies with low USWDS maturity scores are expected to improve them in each annual reporting cycle.

Accessibility: WCAG 2.1 AA

All public-facing federal websites must comply with the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA — the accessibility standard that makes websites usable by people with visual, auditory, motor, and cognitive disabilities. WCAG 2.1 AA compliance requires, among other things:

• Sufficient color contrast between text and background (4.5:1 for normal text)
• Alternative text for all images
• Keyboard navigability for all functionality (no mouse required)
• Captions for all video content
• No content that flashes more than three times per second (seizure risk)
• Focus indicators visible for keyboard users

Section 508 of the Rehabilitation Act (29 U.S.C. § 794d) already requires federal agencies to make their electronic information technology accessible — WCAG 2.1 AA is the technical standard that operationalizes this legal requirement. M-23-22 reinforces and applies this standard to all public-facing web properties.

Mobile-First Design

All new and significantly redesigned federal websites must be mobile-responsive — meaning they work correctly on smartphones and tablets, not just desktop browsers. Given that a majority of users access government services via mobile devices, a website that requires a desktop browser is effectively inaccessible to a significant portion of the intended audience.

Analytics and Performance Monitoring

All public-facing federal websites must participate in the Digital Analytics Program (DAP) — a shared analytics service provided by GSA that gives agencies access to web traffic data (page views, session duration, device type, etc.) without requiring each agency to acquire its own analytics tools. DAP data is aggregated and published publicly at analytics.usa.gov, providing real-time insight into how users interact with the federal web.

Agencies must use DAP data to make evidence-based decisions about website improvements — identifying high-traffic pages with high bounce rates, most-searched terms, and user flow patterns. Performance data must inform the agency's annual digital experience progress report.

Website Inventory and Consolidation

Agencies must maintain an up-to-date inventory of all their public-facing websites, submitted through GSA's Federal Website Index. The inventory must include:

• The domain name and URL of each site
• The agency and sub-agency responsible
• The primary audience and purpose
• Whether the site meets USWDS, accessibility, and analytics requirements
• Whether the site is a candidate for consolidation or retirement

The Federal Website Index enables GSA and OMB to identify redundant sites — multiple agency websites serving the same audience with overlapping content — and direct agencies to consolidate them. The federal government had over 26,000 federal web domains at its peak; M-23-22 continues the consolidation push.

Key Requirements

• Identify top-tier digital services within 30 days; submit digitization plan to OMB within 1 year
• Digitize highest-impact paper forms and services on a published timeline, with barriers documented
• Adopt USWDS for all new and significantly redesigned public-facing websites; report USWDS maturity score annually to GSA
• Comply with WCAG 2.1 AA on all public-facing websites; run accessibility audits and fix failures
• Mobile-responsive design required for all new and significantly redesigned sites
• Deploy DAP (Digital Analytics Program) on all public-facing websites; use traffic data in decision-making
• Submit website inventory to Federal Website Index; identify consolidation candidates
• Provide user feedback mechanisms on high-traffic pages; review and act on feedback quarterly
• Implement HTTPS-only on all .gov websites (referencing M-15-13; HTTPS already required since 2016)

How It Affects You

If you work at a federal agency managing websites or digital services: M-23-22 establishes concrete accountability metrics that will be tracked by GSA and OMB. Your agency's USWDS maturity score, accessibility scan results, DAP participation, and website inventory are all reportable data that feed into OMB's annual digital experience assessment. Prioritize: (1) fix accessibility failures on your highest-traffic pages first — these carry legal exposure under Section 508; (2) adopt USWDS components on new work and in redesigns rather than building custom; (3) get DAP installed if it isn't already — it's a simple tag deployment; (4) build or improve the most-used online transactions. If your agency has a backlog of paper-only processes, document them and make the business case for digitization funding through the Technology Modernization Fund (TMF).

If you are a federal IT contractor, design agency, or UX firm: M-23-22 creates a defined, specific procurement target: federal clients need USWDS-compliant, WCAG 2.1 AA-accessible, mobile-responsive websites with DAP analytics. This is a bounded technical specification, not a vague "modern website" requirement. Develop USWDS expertise, invest in automated accessibility testing tooling (axe, Lighthouse, WAVE), and be prepared to demonstrate Section 508 compliance testing as part of project delivery. Agencies running solicitations under M-23-22 implementation are increasingly including accessibility testing and USWDS adoption as evaluation criteria, not afterthoughts.

If you are a citizen or user of government services: M-23-22 is directly aimed at improving your experience. If you've struggled with a federal website that didn't work on your phone, required you to download a PDF form to fill out by hand, or didn't work with your screen reader, this memo is OMB's commitment that those experiences should be fixed. You can check compliance for any federal website using Google Lighthouse (open Chrome DevTools, click Lighthouse, run an accessibility scan) or the DHS Trusted Tester process. The analytics.usa.gov dashboard shows which federal websites are most visited. If you encounter an inaccessible federal website, you can file a Section 508 complaint with the agency's Section 508 coordinator or with DOJ.

If you are a researcher or journalist: The Federal Website Index (search.gov/about/policy/web-policy.html) and analytics.usa.gov provide public data on federal web presence and traffic. GSA publishes USWDS adoption metrics and accessibility scores for federal websites. Comparing agencies' self-reported progress against independent accessibility audits reveals where agencies are over-reporting compliance. Section 508 complaint data (available through FOIA requests to agency 508 coordinators) shows where inaccessibility has generated formal complaints. The 21st Century IDEA Act required annual reports from agencies on their progress — these reports are publicly available and can be used to hold agencies accountable.

Implementation Status

Implementation has been uneven. Most agencies deployed DAP quickly — it requires only a JavaScript tag installation. USWDS adoption has progressed more slowly, particularly at agencies with large, legacy web presences built on proprietary CMS platforms. Accessibility compliance remains the most consistently weak area: automated accessibility scans of federal websites consistently find WCAG failures on a significant percentage of agencies' public-facing pages, including some high-traffic sites. Full service digitization — eliminating paper-only processes — is the longest-horizon goal and the most resource-intensive.

GSA's Federal Website Index has grown substantially since M-23-22 was issued and now tracks thousands of federal web domains. The Digital.gov community provides shared resources, training, and playbooks to help agencies comply with M-23-22 requirements.

Relationship to Broader Policy

• 21st Century IDEA Act (P.L. 115-336): the statutory foundation mandating digital-first services, USWDS adoption, and form digitization
• Section 508 (29 U.S.C. § 794d): the accessibility law; WCAG 2.1 AA is the technical standard for compliance
• E-Government Act: the 2002 law establishing the e-government framework; M-23-22 extends and modernizes its digital services vision
• FITARA: CIO authority over IT investments includes public-facing website spending; FITARA scorecard grades cybersecurity and modernization, creating overlapping accountability
• M-15-13 HTTPS-Only Standard: HTTPS requirement for all .gov sites; M-23-22 reinforces this baseline security standard

Recent Developments

• December 2018 — 21st Century IDEA Act enacted, requiring agencies to modernize websites, digitize forms, and use USWDS
• September 2023 — M-23-22 issued, establishing specific requirements and timelines for 21st Century IDEA Act implementation
• September 2024 — One-year digitization plan deadline; most agencies submitted plans with varying levels of ambition and detail
• Ongoing — GSA continues to maintain USWDS (current version 3.x) and Digital Analytics Program; federal Web Standards remain in effect under current administration
• 2025 — Some agencies reviewed their digital experience portfolios as part of broader efficiency reviews; M-23-22 requirements remain in effect