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Electronic documents will be explicitly addressed in the Section 508 Refresh. Electronic documents are arguably covered under the current standards especially when posted to websites, but are not always put into practice. With the current draft of the Section 508 Refresh, coverage of electronic content is limited to specific categories of information communicated by agencies to employees or to members of the general public during the conduct of official agency business, as determined by the agency mission. The standards for this content are currently tracking as the WCAG 2.0 A and AA conformance requirements with PDF/UA-1 as an option.

These categories include:

  • content that is public facing or broadly disseminated within the agency, including:
    • websites
    • blog posts
    • social media posts
    • emails, etc.;
  • letters adjudicating any cause within the jurisdiction of the agency;
  • internal and external program and policy announcements;
  • notices of benefits, program eligibility, employment opportunity, or personnel action;
  • questionnaires and surveys;
  • forms and templates;
  • emergency notifications;
  • formal acknowledgments or receipts; and
  • any educational and training materials.

There are two exceptions to covered content:

  • archival copies retained solely for preserving an exact image of a hard copy, and
  • draft versions of documents. (Access to draft content by an employee with a disability would likely be covered under Section 504 of the Rehabilitation Act as an accommodation.)

Authoring tools will also be covered by the Refresh, so organizations will need a system that can generate accessible content. Content creators will also need training to ensure their content conforms to WCAG 2.0 A & AA requirements. Product documentation including accessibility features of products will now need to be directly accessible without request. However, product documentation in alternative formats (e.g., Braille, large print) still must be available upon request.

In practice, these new standards will mean that many government agencies and vendors will need to make significant efforts to ensure all products that allow for authored content can create accessible content and assist authors in this process.