Digital Accessibility Guidelines
For Digital Accessibility Standard # IT-004
Effective Date: August 31, 2026
Introduction
Purpose
These guidelines support MnDOT’s Digital Accessibility Standard and provide practical steps for creating, managing, and procuring accessible digital content and technology. They help ensure consistency across MnDOT and demonstrate our commitment to equitable, sustainable digital practices compliant with the MnDOT Digital Accessibility Standard and the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA.
Who Must Follow These Guidelines
These guidelines apply to all MnDOT employees, contractors, consultants, and vendors who create, buy, manage, or deliver digital content or information and communications technology (ICT) products and services - whether for internal use or for the public.
Responsibilities include:
- MnDOT divisions are responsible for accessibility compliance for all digital documents and products within their division.
- Offices, districts and program areas that provide services related to creating, procuring, managing, or delivering digital content must ensure all deliverables are accessible unless an approved exception applies.
- Content owners must verify accessibility compliance before submitting digital documents or products for posting.
- The Digital Accessibility Team will assist as needed with testing, guidance, and remediation process.
Definitions
ACR (Accessibility Conformance Report)
The completed version of a VPAT. It is the actual report submitted by a vendor that details how well a product or service meets digital accessibility standards.
Assistive technology (AT)
Tools or systems designed to perform specific functions that support individuals with disabilities. These technologies are not required to conform to accessibility rules because they are inherently specialized and may be exclusionary to users without disabilities.
Compliant
A digital product or service that meets the requirements of this standard. It implies a pass/fail interpretation—either the criteria are met or they’re not.
Conformance
Satisfying all the requirements of a given standard, guideline, criteria, or specification.
Digital accessibility
The practice of ensuring that all digital content—such as emails, documents, spreadsheets, presentations, and websites—is accessible to people of all abilities (visual, auditory, motor, and cognitive) and is compatible with assistive technologies like screen readers.
Digital content
Information or media created, stored, or delivered electronically (such as websites, applications, software, electronic documents, images, audio, video, and interactive components) that must comply with the State of Minnesota Digital Accessibility Standard (WCAG 2.1 Level AA and Section 508).
Exception
A reason to not apply this standard to a particular situation considering the specific circumstances.
Exemption
A general category where this standard does not apply.
Information and communications technology (ICT)
All computing and telecommunications hardware and software, the activities undertaken to secure that hardware and software, and the activities undertaken to acquire, transport, process, analyze, store, and disseminate information electronically.
Partial conformance
Situations where the digital product or service meets some, but not all, of a given standard, guideline, criteria, or specification.
Reasonable accommodation
Any change to the application or hiring process, to the job, to the way the job is done, or to the work environment that allows a person with a disability who is qualified for the job to perform the essential functions of that job and have equal employment opportunities. Accommodations are considered “reasonable” if they do not create an undue hardship or pose a direct threat.
Remediation
Correcting an electronic document, product, or service so that it complies with this standard.
Urgent Business Need
A communication need that, if not addressed quickly, could harm MnDOT operations, the state, or Minnesota citizens.
Voluntary Product Accessibility Template (VPAT)
A standardized document template developed by the Information Technology Industry Council (ITIC). It is used by vendors to describe how their ICT product or service meets various digital accessibility standards, such as WCAG or Section 508.
Web Content Accessibility Guidelines (WCAG)
A set of internationally recognized standards developed by the World Wide Web Consortium (W3C) to make digital content accessible to all users, including people with disabilities.
The Web Content Accessibility Guidelines (WCAG) is a set of internationally recognized standards from the World Wide Web Consortium (W3C) that help make digital content accessible to everyone, including people with disabilities.
The guidelines outline three levels of accessibility:
- Level A: Addresses the most critical barriers to access.
- Level AA: The target level for Minnesota state agencies; removes common barriers for people with disabilities.
- Level AAA: The highest level, offering enhanced accessibility but not required for full compliance.
Requirements
Under the Americans with Disabilities Act (ADA), an accommodation is a change or adjustment to a job or workplace that helps a person with a disability do their job. Examples include assistive technology like screen readers or magnifiers.
Following these Digital Accessibility Guidelines does not remove the possibility that someone may still request an accommodation.
Implementation
MnDOT divisions are responsible for accessibility compliance related to their division’s digital documents and products.
MnDOT divisions or units that offer services related to creating, procuring, managing, or delivering digital documents and products (such as MnDOT purchasing and MNIT@DOT) must provide accessible deliverables unless they have been granted an exception (see Exceptions section below).
Content authors are responsible for verifying accessibility compliance before submitting digital documents and products to the Web Team or other division staff who post Web content. The Digital Accessibility Team will assist as needed.
Steps for Creating Accessible Digital Content
Think about accessibility at the start of any project—when defining goals or writing requirements. If you wait until later, it can lead to extra costs, delays, and more work.
For the latest tools and guidance, visit:
Step 1: Plan
- Think about digital accessibility early in your project, including goals, timelines and budgets.
- Use the MnDOT Digital Accessibility Standard and guidelines as your starting point.
- Consult the MnDOT Digital Accessibility Team for guidance if needed.
Step 2: Create
- Use the MnDOT templates (available in M365 products “File > New”).
- Make sure everything you add to the template follows accessibility rules.
- Follow State of Minnesota Expectations for Accessible Documents
- Use the Digital Accessibility Evaluation Tool to ensure every item on the checklist receives a green checkmark. Contact the Digital Accessibility Team for assistance.
- For ICT procurements: request Voluntary Product Accessibility Template / Accessibility Conformance Report (VPAT/ACR) from vendors; evaluate products for WCAG/Section 508 conformance and document exceptions.
Step 3: Test
- Run built-in accessibility checks (Microsoft 365, Adobe) and address issues before publication.
- Use automated tools and manual checks, test with keyboard only and screen readers.
- For details on testing tools and processes, go to the ‘Development/Testing’ tab in the Websites and Applications section of the MNIT Accessibility site.
Step 4: Publish
- Include the accessibility statement on all public-facing materials. For example: “To request a reasonable accommodation and/or an alternative format of web content, contact us at 1-833-400-8432, relay service 711, or email digital.accessibility.dot@state.mn.us. (or direct contact to the content owner, project manager)”
- Establish accountability for accessibility sign-off.
- Have a plan to address accessibility issues, track progress and set up target goals for remediation.
Step 4: Maintain and improve
- Confirm content update and software patches do not break accessibility.
- Review content regularly; remediate issues; update resources and training; document assessments and remediation plans.
Required Statement for Public Content
All digital content created, used, or purchased for the public must include this message:
If you need help accessing content or need materials in another format—such as braille, large print, or a different language—at no cost, please contact us:
Email: Accessibility.DOT@state.mn.us
Phone: 1-833-400-8432
Relay Service: 711
Language when linking to external sites
Links to websites outside of MnDOT are for information only. These sites do not have to meet the MnDOT digital accessibility standards, as long as the link clearly shows it goes to an external site. We recommend the following statement when linking to the external site:
At MnDOT, we are committed to making our digital content accessible to people with disabilities. We follow accessibility standards to improve everyone’s experience.
Please note: When you visit third-party websites through our links, MnDOT does not own or control that content. We cannot guarantee those sites are accessible.
Contract Language for Digital Products and Services
When a contract includes products or services that use digital technology—such as websites, software, electronic reports, training materials (documents, videos, webinars), and similar items—the following language must be included:
The Contractor acknowledges and is fully aware of the accessibility requirements of Minnesota Statutes section 16E.03 and the State of Minnesota Accessibility Standards – available online at: https://mn.gov/mnit/government/policies/accessibility/– that incorporate both Section 508 of the Rehabilitation Act and Web Content Accessibility Guidelines (WCAG) 2.1 level ‘AA’. The Standards apply to web sites, software applications, electronic reports and output documentation, training delivered in electronic formats (including, but not limited to, documents, videos, and webinars), among others.
As upgrades are made to the software/products/subscriptions (Products) available through this Contract, the Contractor agrees to develop functionality which supports accessibility. The Contractor warrants that its Products comply with the above-mentioned accessibility Standards and agrees to indemnify, defend, and hold harmless the State against any claims related to non-compliance of the Contractor’s Products with the above-mentioned accessibility Standards. If any issues arise due to nonconformance with the above-mentioned accessibility Standards, the Contractor agrees to provide alternative solutions upon request at no additional charge to the State.
When updates or upgrades are made to the Products, the Contractor agrees to document how the changes will impact and/or improve accessibility and usability. This documentation, upon request, must be provided to the State in advance of the change, occurring within an agreed upon timeframe sufficient for the State to review the changes and either approve them or request a remediation plan from the Contractor.
Where digital documents are part of the Contractor’s deliverables, the Contractor agrees to meet or exceed minimum accessibility requirements, which can be viewed at Expectations for Accessible Documents (Updated May 2024) (mn.gov).
Exceptions for Digital Content
MnDOT may share digital documents or products that are not accessible only if:
- There is an urgent business need, or
- It is required by law (for example, data requests, legal discovery, or disaster response).
Public comments, petitions, and attachments to citizen letters are also exceptions to the standard.
These exceptions must be thoroughly documented and do not remove the obligation to provide access through alternative means.
Exception categories recognized by the ADA include:
- Archived web content
- Preexisting conventional electronic documents
- Third-party content not posted under contract or agreement with MnDOT
- Password-protected individualized documents
- Preexisting social media posts
If you believe an exception may apply, contact the MnDOT Digital Accessibility Team for guidance.
Exceptions for ICT Procurement
Follow Minnesota State Accessibility Standard for allowable exceptions. MnDOT and MNIT DOT Digital Accessibility Coordinators must review and approve exception forms before Commissioner signature.
Resources and Related Information
Training and resources
- MnDOT Digital Accessibility SharePoint
- MNIT Office of Accessibility Website
- MnDOT Digital Accessibility Training
- MNIT Office of Accessibility Training
- MnDOT Digital Accessibility Resources including:
- Quick cards
- Links to training modules
- Links to accessibility laws and standards
- Links to guidance for multimedia, meetings and maps
References
- State of Minnesota Digital Accessibility Standard
- State of Minnesota Accessibility Guidelines
- State of Minnesota Expectations for Accessible Documents
- Minnesota Statutes § 16E.03, subds. 9 & 10
- Section 508 (Final Rule) of the Rehabilitation Act of 1973
- Web Content Accessibility Guidelines (WCAG) 2.1
- MnDOT Digital Accessibility Website Statement
- MnDOT Digital Accessibility SharePoint site
- ADA Fact Sheet: DOJ final rule on Title II Summary of the Exceptions
