Electronic technology requirements

Yes — the agency must ensure that electronic and information technology it develops, procures, maintains, or uses provides employees with disabilities access and use comparable to employees without disabilities, unless doing so would cause an undue burden. See 2205.135(a) and the broader 2205 requirement.

• Follow standards published by the Architectural and Transportation Barriers Compliance Board at 36 CFR part 1194 when possible.
• Document any determination of undue burden and the alternative means provided if full compliance is not possible (see 2205.135(b) for alternatives).

Yes — the requirement covers both current agency employees and applicants with disabilities, ensuring they have comparable access to agency electronic and information technology. See 2205.135(a)(1) and 2205.135(a).

• This means accessibility should be considered when recruiting, applying, and onboarding systems handle applicants' information.

Yes — members of the public with disabilities seeking information or services must have access and use of information and data comparable to the public without disabilities. See 2205.135(a)(2) and 2205.135(a).

• This applies to public-facing websites, online forms, PDFs, videos, and other electronic information and services.

The agency must provide individuals with disabilities access to the information and data by an alternative means that allows use of the information and data. See 2205.135(b).

• The agency should document the undue burden determination and describe the alternative means of access provided.
• Alternatives might include providing information in accessible formats, offering staff assistance, or telephone support, but must allow comparable access.

It means the agency must procure accessible electronic and information technology unless making that purchase accessible would cause significant difficulty or expense (an undue burden); if so, the agency must provide an alternative means of access. See 2205.135(a) and 2205.135(b).

• When evaluating procurement, include accessibility requirements in contracts and use conformance to 36 CFR part 1194 as criteria.
• If accessibility raises undue burden, document the analysis and planned alternative access methods.

Agencies must ensure electronic and information technology allows comparable access in accordance with section 508 and the standards published at 36 CFR part 1194, except where doing so would create an undue burden. See 2205.135(a).

• Treat 36 CFR part 1194 as the applicable technical standards for accessibility.
• If full conformance is not possible, follow 2205.135(b) to provide alternatives and document the undue burden.

The agency is responsible for maintaining electronic and information technology so accessibility is preserved absent an undue burden. See 2205.135(a).

• Include accessibility checks in maintenance plans, software updates, and replacement schedules.
• If a maintenance update would cause an undue burden to make accessible, follow 2205.135(b) to offer alternative access.

Comparable access does not always mean identical interfaces; it means access and use are comparable in effectiveness, timeliness, and convenience, allowing employees with disabilities equivalent opportunity. See 2205.135(a)(1) and 2205.135(a).

• Reasonable accommodations or alternative interfaces may be appropriate when they provide equivalent access.
• Document choices and user testing to show comparability.

Yes — electronic information and data used for agency communications, including emergencies, must be accessible so individuals with disabilities have comparable access, absent undue burden. See 2205.135(a).

• Consider multiple accessible formats (e.g., text captions, screen-reader text, TTY/relay services) to ensure timely access.
• If accessibility would impose an undue burden, provide an alternative that ensures prompt access per 2205.135(b).

Yes — public-facing electronic documents, including PDFs, must allow members of the public with disabilities to access information comparably, following 36 CFR part 1194 unless an undue burden exists. See 2205.135(a)(2) and 2205.135(a).

• Use accessible document practices (proper tags, readable text, alt text for images, logical structure).
• If converting older documents is an undue burden, provide alternative formats under 2205.135(b).

It is acceptable when making the technology meet 36 CFR part 1194 would impose an undue burden; in that case, the agency must provide an alternative means of access, which can include staff assistance. See 2205.135(b) and 2205.135(a).

• Ensure staff assistance reliably gives comparable access in timeliness and usefulness.
• Document the undue burden analysis and the alternative access plan.

The agency should document the facts and analysis showing why conformance with 36 CFR part 1194 would cause significant difficulty or expense, and describe the alternative means of access provided. See 2205.135(b).

• Include cost estimates, technical barriers, and steps taken to reduce the burden before concluding undue burden.
• Keep records so reviewers or complainants can understand the decision and alternatives offered.

Yes — mobile applications developed, procured, or used by the agency must allow individuals with disabilities comparable access unless an undue burden exists. See 2205.135(a) and 2205.135(a)(2) for public-facing apps.

• Apply the same 36 CFR part 1194 standards and accessibility testing practices to mobile apps.
• If accessibility is an undue burden, provide alternative access per 2205.135(b).

Yes — when the agency procures or uses vendor-hosted services, it must ensure those services allow comparable access for individuals with disabilities absent an undue burden. See 2205.135(a).

• Include accessibility requirements in procurement contracts and evaluate vendor compliance with 36 CFR part 1194.
• If vendor remediation would create an undue burden, document the analysis and provide alternatives under 2205.135(b).

Yes — providing captions is a means to ensure individuals with hearing disabilities have comparable access to video information; agencies should follow 36 CFR part 1194 accessibility standards unless an undue burden exists. See 2205.135(a).

• Use accurate captions for prerecorded videos and live-captioning or real-time alternatives for live events.
• If captioning would be an undue burden in a specific case, offer a timely alternative means of access under 2205.135(b).

The agency should involve IT staff, accessibility specialists, procurement officers, and representatives of users with disabilities to assess accessibility and undue burden. See 2205.135(a).

• Including user testing with people who have disabilities helps demonstrate comparable access.
• Document the assessment and any undue burden decisions as required by 2205.135(b).

Yes — training materials delivered electronically must allow employees with disabilities comparable access to the content, unless making them accessible would cause an undue burden. See 2205.135(a)(1).

• Offer accessible formats (e.g., accessible slide decks, transcripts, captions) and reasonable accommodations during training.
• If an undue burden prevents full accessibility, provide equally effective alternatives per 2205.135(b).

Yes — internal electronic and information technology used by agency employees must provide comparable access to employees with disabilities, as required by 2205.135(a)(1).

• Accessibility should be part of internal IT policies, procurement, and maintenance.
• If updating internal tools to meet standards creates an undue burden, follow 2205.135(b) for alternative access.

Agencies should assess whether updating legacy systems to meet 36 CFR part 1194 is feasible; if it would impose an undue burden, they must provide alternative means of access to individuals with disabilities. See 2205.135(a) and 2205.135(b).

• Document efforts to reduce the burden, timelines for replacement, and temporary alternative access solutions.
• Plan for eventual migration to accessible technologies when possible.

Yes — public online forms must allow members of the public with disabilities to access and use the forms comparably; if complying with 36 CFR part 1194 is an undue burden, provide an alternative method to submit requests. See 2205.135(a)(2) and 2205.135(b).

• Alternatives can include phone submission, in-person assistance, or accessible paper forms provided promptly.
• Keep records of alternatives offered and how they match the timeliness and usefulness of the online form.

An agency can consider third-party accessibility certifications as part of its evaluation, but must still ensure the technology provides comparable access in practice and meets 36 CFR part 1194 standards unless an undue burden exists. See 2205.135(a).

• Use certifications as one input and perform acceptance testing with users with disabilities where possible.
• If the product fails to provide comparable access and remediation would be an undue burden, document the analysis and provide alternatives per 2205.135(b).

Yes — alternatives provided under an undue burden determination must enable individuals with disabilities to use the information and data comparably; agencies should not impose barriers or extra charges for such access. See 2205.135(b) and 2205.135(a).

• Alternatives should be timely, effective, and as convenient as the original means.
• Document availability and the agency’s commitment to provide access without creating new burdens.