Do your internal documents need to be Sec. 508-compliant?

The answer is … maybe.

This tutorial reviews how to determine which internal, non-public-facing documents are covered by the US Section 508 regulation.

Non-public-facing digital content

A colleague at a US federal government agency recently emailed us with this tech support question:

If a flyer is going to be sent out internally within our agency, does the flyer need to be made accessible? It will not be posted on any external public website or on our internal SharePoint site.

We'll examine the Sec. 508 regulation to determine if our colleague's flyer is covered.

References to Sec. 508 are indented (BlockQuote), like this paragraph.

Email requirements

Because the flyer won’t be posted anywhere, we’ll assume that it will be sent as an email attachment using a government email account and sent to others with government emails. It could also be printed and posted on a bulletin board in an agency break room.

First, the printed version is not covered by Sec. 508. Only electronic content is specified in the regulation.

E205.1 General. Electronic content shall comply with E205.

PDFs that are for printed versions of a document do not need to be accessible. These PDFs are often sent to copyshops, the GPO (US Government Publishing Office), and outside vendors for reproduction.

Second, Sec. 508 does apply to email and attachments.

E103.4 Defined Terms. For the purpose of the Revised 508 Standards, the terms defined in E103.4 have the indicated meaning …

Document. Logically distinct assembly of content (such as a file, set of files, or streamed media) that: functions as a single entity rather than a collection; is not part of software; and does not include its own software to retrieve and present content for users. Examples of documents include, but are not limited to, letters, email messages, spreadsheets, presentations, podcasts, images, and movies.

Email and email attachments must be accessible.

Non-public–facing content

If the ICT (information communication technology or digital content) is not public-facing (it will not distributed to or seen by the general public), then it’s internal agency communication. Items are one or the other.

Sec. 508 defines “agency official communication” with these 2 clauses:

E203.1 | A. That Federal employees with disabilities have access to and use of information and data that is comparable to the access and use by Federal employees who are not individuals with disabilities;

E205.3 Agency Official Communication. Electronic content that is not public facing shall conform to the accessibility requirements specified in E205.4 when such content constitutes official business and is communicated by an agency through one or more of the following:

A. An emergency notification;

B. An initial or final decision adjudicating an administrative claim or proceeding;

C. An internal or external program or policy announcement;

D. A notice of benefits, program eligibility, employment opportunity, or personnel action;

E. A formal acknowledgement of receipt;

F. A survey questionnaire;

G. A template or form;

H. Educational or training materials; or

I. Intranet content designed as a Web page.

Exception: Records maintained by the National Archives and Records Administration (NARA) pursuant to Federal recordkeeping statutes shall not be required to conform to the Revised 508 Standards unless public facing.

Without knowing the purpose of the flyer or its content, it’s tough to figure out whether it must be compliant. Only our colleague would be able to determine whether it falls within one or more of these defined categories and, therefore, is covered.

If your internal content fits into one or more of the 9 categories above (A–I), then it's covered by Sec. 508.


Sample flyer from the Department of Labor    Sample lunch room flyer.    Sample flyer from the Office of Personnel Management.

Here are some examples of flyers we’ve seen at government offices. Click each example to view its full-size PDF.

What do you think? Must they be Sec. 508-compliant?

  1. Announcement of a brown-bag lunch where an informal presentation about using the agency's new intranet will take place.
  2. Reminder to employees about an upcoming deadline for selecting healthcare and retirement benefit packages.
  3. Announcement of a lunchtime meeting for members of Weight Watchers.
  4. Announcement of a retirement party for an employee.
  5. Notice of a new policy regarding escorting visitors into and around the agency.
  6. Notice from the building’s management firm about new parking restrictions due to construction in the garage.
  7. “For Sale” flyer from an employee selling their car.

Smart answer

Make all of them accessible!

Can you justify leaving out some of your work colleagues? Can you ethically say that only employees who don't have a disability should know about these topics?

It’s clear that most of these examples are work-related, affect an employee’s ability to complete their job, or are HR/personnel-like topics, so examples 1, 2, 5, and 6 are definitely covered.

Examples 3 (Weight Watchers meeting) and 7 (For Sale) are personal, not “agency official communication,” and therefore aren’t covered by Sec. 508. On the other hand, why leave out some of your colleagues? Common sense says to make these flyers at least minimally accessible and cover headings, text, lists, hyperlinks, and logical reading order.

Example 4 (retirement party) is on the fringe of being work-related. If the party is sponsored by the agency, then it is covered, but if your colleagues chip in for the cake and party expenses, it could fall under the personal category and not be covered. Again, why leave out anyone?


CYA! Cover your anatomy and make the "gray areas" accessible, too.

For flyers that are clearly work-related agency official communication, ensure that they are fully PDF/UA-1–compliant in order to meet Sec. 508 requirements. Examine the PDFs with accessibility checkers (such as Adobe Acrobat Pro and PAC3), test, and validate them.

For the personal flyers (examples 3, 7, and maybe 4), make them “litely” accessible. Make sure the PDF is tagged with accessible headings, lists, and hyperlinks; put Alt-text on the graphics; and set a decent, logical tag reading order (RO). A quick check with Acrobat Pro’s accessibility checker will be enough to ensure none of your colleagues are left out of the loop.

Best practice: Always include people — and make our work world a little better.

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