Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 1 

Federal Highway Administration Form 4260.1: Section 508 Information and Communication Technology (ICT) Standardized 

Conformance Criteria

Table of Contents

Part 1: Electronic Content...................................................................................................................................................................................................................... 2

Part 2: {Reserved} ..................................................................................................................................................................................................................................9

Part 3: Functional Performance Criteria .............................................................................................................................................................................................. 10

Part 4: Hardware ................................................................................................................................................................................................................................. 11

Part 5: Software................................................................................................................................................................................................................................... 25

Part 6: Support Documentation ........................................................................................................................................................................................................... 32
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 2 

Part 1: Electronic Content

36 CFR 1194 Appendix A

Content is defined as “Electronic information and data, as well as the encoding that defines its structure, presentation, and interactions.” All public-facing 

electronic content and internal electronic content defined as internal agency communication under the 508 Refresh will be validated against this criteria.

All electronic content will conform to Web Content Accessibility Guidelines (WCAG) 2.0 levels A and AA with the noted exceptions and wording substitution for 

non-web content.

1: Making ICT Perceivable for Everyone: Deliver ICT that users can perceive using any sense - sight, hearing, and/or touch. 

1.1 Text Alternatives: Provide text alternatives for any non-text content. 

Complete or 

N/A

Success Criteria Techniques

1.1.1 Non-text Content (Level A) • WCAG 2.0 discussion on SC 1.1.1

Test Results and Comments: Can be provided in a separate document.
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Replaces Form DOT 4260 Page | 3 

1.2 Audio and Video Files: Provide alternatives for audio and video files. NOTE: If the audio or video is designated as an alternative to text (e.g., an audio or 

sign language version of a web page, for example), and labeled as such. 

Complete or 

N/A

Success Criteria Techniques

1.2.1 Prerecorded Audio-only and Video-only 

(Level A)

• WCAG 2.0 discussion on SC 1.2.1

1.2.2 Captions (Prerecorded) (Level A) • WCAG 2.0 discussion on SC 1.2.2

1.2.3 Audio Description or Media Alternative 

(Prerecorded) (Level A)

• WCAG 2.0 discussion on SC 1.2.3

1.2.4 Captions (Live) (Level AA) • WCAG 2.0 discussion on SC 1.2.4

1.2.5 Audio Description (Prerecorded) (Level 

AA)

• WCAG 2.0 discussion on SC 1.2.5

Test Results and Comments: Can be provided in a separate document.

1.3 Content is Adaptable to Users’ Needs: Create content that can be presented in different ways (e.g., simpler layout) without losing information or 

structure. 

Complete or 

N/A

Success Criteria Techniques

1.3.1 Info and Relationships (Level A) • WCAG 2.0 discussion on SC 1.3.1

1.3.2 Meaningful Sequence (Level A) • WCAG 2.0 discussion on SC 1.3.2

1.3.3 Sensory Characteristics (Level A) • WCAG 2.0 discussion on SC 1.3.3

Test Results and Comments: Can be provided in a separate document.
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Replaces Form DOT 4260 Page | 4 

1.4 Make It Easier for Users to See and Hear Content: Make it easier for users to see and hear content including separating foreground from background. 

Complete or 

N/A

Success Criteria Techniques

1.4.1 Use of Color (Level A) • WCAG 2.0 discussion on SC 1.4.1

1.4.2 Audio Control (Level A) • WCAG 2.0 discussion on SC 1.4.2

1.4.3 Contrast (Minimum) (Level AA) • WCAG 2.0 discussion on SC 1.4.3

1.4.4 Resize text (Level AA) • WCAG 2.0 discussion on SC 1.4.4

1.4.5 Images of Text (Level AA) • WCAG 2.0 discussion on SC 1.4.5

Test Results and Comments: Can be provided in a separate document.

2: Ensure Operability for All Users: Interface forms, controls, and navigation are operable, for example all users can use your website without a mouse.

2.1 Keyboard Accessibility: Make all functionality available from a keyboard. 

Complete or 

N/A

Success Criteria Techniques

2.1.1 Keyboard (Level A) • WCAG 2.0 discussion on SC 2.1.1

2.1.2 No Keyboard Trap (Level A) • WCAG 2.0 discussion on SC 2.1.2

Test Results and Comments: Can be provided in a separate document.
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Replaces Form DOT 4260 Page | 5 

2.2 Provide Users Enough Time to Read and Use Content: Some users may need more time than expected to complete a task.

Complete or 

N/A

Success Criteria Techniques

2.2.1 Timing Adjustable (Level A) • W3C discussion on WCAG 2.0 SC 2.2.1

2.2.2 Pause, Stop, Hide (Level A) • W3C discussion on WCAG 2.0 SC 2.2.2

Test Results and Comments: Can be provided in a separate document.

2.3 Prevent Seizures: Do Not Design Content in a Way That is Known to Cause Seizures or Physical Reactions: 

Complete or 

N/A

Success Criteria Techniques

2.3.1 Three Flashes or Below Threshold (Level 

A)

• W3C discussion on WCAG 2.0 SC 2.3.1

Test Results and Comments: Can be provided in a separate document.
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2.4 Navigation: Provide ways to help users navigate, find content, and determine where they are. 

Complete or 

N/A

Success Criteria Techniques

2.4.1 Bypass Blocks (Level A) • W3C discussion on WCAG 2.0 SC 2.4.1

2.4.2 Page Titled (Level A) • W3C discussion on WCAG 2.0 SC 2.4.2

2.4.3 Focus Order (Level A) • W3C discussion on WCAG 2.0 SC 2.4.3

2.4.4 Link Purpose (In Context) (Level A) • W3C discussion on WCAG 2.0 SC 2.4.4

2.4.5 Multiple Ways (Level AA) • W3C discussion on WCAG 2.0 SC 2.4.5

2.4.6 Headings and Labels (Level AA) • W3C discussion on WCAG 2.0 SC 2.4.6

2.4.7 Focus Visible (Level AA) • W3C discussion on WCAG 2.0 SC 2.4.7

Test Results and Comments: Can be provided in a separate document.

3: Understandability: Information and the operation of user interface must be understandable.

3.1 Readability: Make text content readable and understandable. 

Complete or 

N/A

Success Criteria Techniques

3.1.1 Language of Page (Level A) • W3C discussion on WCAG 2.0 SC 3.1.1

3.1.2 Language of Parts (Level AA) • W3C discussion on WCAG 2.0 SC 3.1.2

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 7 

3.2 Predictability: Make Web pages appear and operate in predictable ways. 

Complete or 

N/A

Success Criteria Techniques

3.2.1 On Focus (Level A) • W3C discussion on WCAG 2.0 SC 3.2.1

3.2.2 On Input (Level A) • W3C discussion on WCAG 2.0 SC 3.2.2

3.2.3 Consistent Navigation (Level AA) • W3C discussion on WCAG 2.0 SC 3.2.3

3.2.4 Consistent Identification (Level AA) • W3C discussion on WCAG 2.0 SC 3.2.4

Test Results and Comments: Can be provided in a separate document.

3.3 Help Users Avoid and Correct Mistakes on Forms: Provide input assistance. 

Complete or 

N/A

Success Criteria Techniques

3.3.1 Error Identification (Level A) • W3C discussion on WCAG 2.0 SC 3.3.1

3.3.2 Labels or Instructions (Level A) • W3C discussion on WCAG 2.0 SC 3.3.2

3.3.3 Error Suggestion (Level AA) • W3C discussion on WCAG 2.0 SC 3.3.3

3.3.4 Error Prevention (Legal, Financial, Data) 

(Level AA)

• W3C discussion on WCAG 2.0 SC 3.3.4

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 8 

4: Create Robust Content that can be Widely Used: Ensure Content Can be Used Reliably by a Wide Variety of User Agents, Including Assistive 

Technologies. 

4.1 Maximize Compatibility with Current and Future User Technologies: “Users will operate a broad range of different technologies to view ICT. Make it

current and compatible with a full spectrum of technical advances. 

Complete or 

N/A

Success Criteria Techniques

4.1.1 Parsing (Level A) • W3C discussion on WCAG 2.0 SC 4.1.1

4.1.2 Name, Role, Value (Level A) • W3C discussion on WCAG 2.0 SC 4.1.2

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 9 

Part 2: {Reserved} 
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 10

Part 3: Functional Performance Criteria

36 CFR 1194 Appendix C, Chapter 3

For use in cases of equivalent facilitation. Where the requirements in Chapters 4 and 5 do not address one or more functions of ICT, the functions not 

addressed shall conform to the Functional Performance Criteria specified in Chapter 3.

Complete or N/A Conformance Techniques

302.1 Without Vision Where a visual mode of operation is provided, ICT shall provide at least one mode of operation 

that does not require user vision. 

302.2 With Limited Vision Where a visual mode of operation is provided, ICT shall provide at least one mode of operation 

that enables users to make use of limited vision. 

302.3 Without Perception of 

Color

Where a visual mode of operation is provided, ICT shall provide at least one visual mode of 

operation that does not require user perception of color. 

302.4 Without Hearing Where an audible mode of operation is provided, ICT shall provide at least one mode of 

operation that does not require user hearing. 

302.5 With Limited Hearing Where an audible mode of operation is provided, ICT shall provide at least one mode of 

operation that enables users to make use of limited hearing. 

302.6 Without Speech Where speech is used for input, control, or operation, ICT shall provide at least one mode of 

operation that does not require user speech. 

302.7 With Limited 

Manipulation

Where a manual mode of operation is provided, ICT shall provide at least one mode of 

operation that does not require fine motor control or simultaneous manual operations. 

302.8 With Limited Reach and 

Strength

Where a manual mode of operation is provided, ICT shall provide at least one mode of 

operation that is operable with limited reach and limited strength. 

302.9 With Limited Language, 

Cognitive, and Learning 

Abilities

ICT shall provide features making its use by individuals with limited cognitive, language, and 

learning abilities simpler and easier. 

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 11

Part 4: Hardware 

36 CFR 1194 Appendix C, Chapter 4

4.1 General

Where components of ICT are hardware and transmit information or have a user interface, such components shall conform to the requirements in this section.

Exception: Hardware that is assistive technology shall not be required to conform to the requirements of this section.

4.1.1 Scope The requirements of this section apply to ICT that is hardware where required by Section 508. 

Complete the following sections. 

4.2 Closed Functionality

Closed Functionality is characteristics that limit functionality or prevent a user from attaching or installing assistive technology. Examples of ICT with closed 

functionality are self-service machines, information kiosks, set-top boxes, fax machines, calculators, and computers that are locked down so that users may not 

adjust settings due to a policy such as Desktop Core Configuration.

4.2.1 General: ICT with closed functionality shall be operable without requiring the user to attach or install assistive technology other than personal headsets or 

other audio couplers and shall conform to Part 4.2. 

Test Results and Comments: Can be provided in a separate document.
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Replaces Form DOT 4260 Page | 12

4.2.2 Speech-Output Enabled: ICT with a display screen shall be speech-output enabled for full and independent use by individuals with vision impairments.

Exceptions: 

1. Variable message signs conforming to 4.2.5 shall not be required to be speech-output enabled. Variable Message Signs (VMS) are on-interactive 

electronic signs with scrolling, streaming, or paging-down capability. An example of a VMS is an electronic message board at a transit station that 

displays the gate and time information associated with the next train arrival.

2. Speech output shall not be required where ICT display screens only provide status indicators and those indicators conform to 4.9.

3. Where speech output cannot be supported due to constraints in available memory or processor capability, ICT shall be permitted to conform to 4.9 in lieu 

of 4.2.2.

4. Audible tones shall be permitted instead of speech output where the content of user input is not displayed as entered for security purposes, including, but 

not limited to, asterisks representing personal identification numbers.

5. Speech output shall not be required for: the machine location; date and time of transaction; customer account number; and the machine identifier or 

label.

6. Speech output shall not be required for advertisements and other similar information unless they convey information that can be used for the transaction 

being conducted.

Complete or N/A Conformance Techniques

4.2.2.1 Information 

Displayed On-Screen

Speech output shall be provided for all information displayed on-screen.

4.2.2.2 Transactional 

Outputs

Where transactional outputs are provided, the speech output shall audibly provide all information 

necessary to verify a transaction.

4.2.2.3 Speech Delivery 

Type and Coordination

Speech output shall be delivered through a mechanism that is readily available to all users, 

including, but not limited to, an industry standard connector or a telephone handset. Speech shall 

be recorded or digitized human, or synthesized. Speech output shall be coordinated with 

information displayed on the screen.

4.2.2.4 User Control Speech output for any single function shall be automatically interrupted when a transaction is 

selected. Speech output shall be capable of being repeated and paused.

4.2.2.5 Braille Instructions Where speech output is required by 402.2, braille instructions for initiating the speech mode of 

operation shall be provided. Braille shall be contracted and shall conform to 36 CFR part 1191, 

Appendix D, Section 703.3.1.

Exception: Devices for personal use shall not be required to conform to 4.2.2.5. Desk phone, 

personal phone, etc.

Test Results and Comments: Can be provided in a separate document.
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Replaces Form DOT 4260 Page | 13

4.2.3 Volume: ICT that delivers sound, including speech output required by 4.2.2, shall provide volume control and output amplification conforming to this 

section. 

Exception: ICT conforming to 4.12.2 shall not be required to conform to this section. 

Complete or N/A Conformance Techniques

402.3.1 Private Listening Where ICT provides private listening, it shall provide a mode of operation for controlling the 

volume. Where ICT delivers output by an audio transducer typically held up to the ear, a means for 

effective magnetic wireless coupling to hearing technologies shall be provided.

The requirement for “effective magnetic wireless” could be met a few ways: 

− Headphone jack

− Telephone style handset

− Bluetooth

402.3.2 Non-private 

Listening

Where ICT provides non-private listening, incremental volume control shall be provided with output 

amplification up to a level of at least 65 dB. A function shall be provided to automatically reset the 

volume to the default level after every use.

Test Results and Comments: Can be provided in a separate document.

4.2.4 Characters on Display Screens

Complete or N/A Conformance Techniques

4.2.4.1 Font At least one mode of characters displayed on the screen shall be in a sans serif font.

4.2.4.2 Font Size Where ICT does not provide a screen enlargement feature, characters shall be 3/16 inch (4.8 mm) 

high minimum based on the uppercase letter “I”.

4.2.4.3 Font Contrast Characters shall contrast with their background with either light characters on a dark background 

or dark characters on a light background.

Test Results and Comments: Can be provided in a separate document.
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Replaces Form DOT 4260 Page | 14

4.2.5 Characters on Variable Message Signs

Characters on variable message signs shall conform to section 703.7 Variable Message Signs of ICC A117.1-2009. 

Test Results and Comments: Can be provided in a separate document.

4.3 Biometrics

4.3.1 General: Where provided, biometrics shall not be the only means for user identification or control.

Exception: Where at least two biometric options that use different biological characteristics are provided, ICT shall be permitted to use biometrics as the only 

means for user identification or control.

Test Results and Comments: Can be provided in a separate document.

4.4 Preservation of Information Provided for Accessibility

4.4.1 General: ICT that transmits or converts information or communication shall not remove non-proprietary information provided for accessibility or shall 

restore it upon delivery.

Test Results and Comments: Can be provided in a separate document.

4.5 Privacy

4.5.1 General: The same degree of privacy of input and output shall be provided to all individuals. When speech output required by 4.2.2 is enabled, the screen 

shall not blank automatically.

Test Results and Comments: Can be provided in a separate document.
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Replaces Form DOT 4260 Page | 15

4.6 Standard Connections

4.6.1 General: Where data connections used for input and output are provided, at least one of each type of connection shall conform to industry standard nonproprietary formats.

Test Results and Comments: Can be provided in a separate document.

4.7 Operable Parts

4.7.1 General: Where provided, operable parts used in the normal operation of ICT shall conform to this section. 

4.7.2 Contrast: 

Complete or N/A Conformance Techniques

4.7.2.1 Tactilely Discernible Where provided, keys and controls shall contrast visually from background surfaces.

4.7.2.2 Alphabetic Keys Characters and symbols shall contrast visually from background surfaces with either light 

characters or symbols on a dark background or dark characters or symbols on a light background. 

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 16

4.7.3 Input Controls

At least one input control conforming to this section shall be provided for each function.

Exception: Devices for personal use with input controls that are audibly discernable without activation and operable by touch shall not be required to conform to 

this section. 

Complete or N/A Conformance Techniques

4.7.3.1 Tactilely Discernible Input controls shall be operable by touch and tactilely discernible without activation.

4.7.3.2 Alphabetic Keys Where provided, individual alphabetic keys shall be arranged in a QWERTY-based keyboard 

layout and the “F” and “J” keys shall be tactilely distinct from the other keys.

4.7.3.3 Numeric Keys Where provided, numeric keys shall be arranged in a 12-key ascending or descending keypad 

layout. The number five key shall be tactilely distinct from the other keys. Where the ICT provides 

an alphabetic overlay on numeric keys, the relationships between letters and digits shall conform to 

ITU-T Recommendation E.161.

Test Results and Comments: Can be provided in a separate document.

4.7.4 Key Repeat: Where a keyboard with key repeat is provided, the delay before the key repeat feature is activated shall be fixed at, or adjustable to, 2 

seconds minimum.

Test Results and Comments: Can be provided in a separate document.

4.7.5 Timed Response: Where a timed response is required, the user shall be alerted visually, as well as by touch or sound, and shall be given the opportunity 

to indicate that more time is needed.

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 17

4.7.6 Operation: At least one mode of operation shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The 

force required to activate operable parts shall be 5 pounds (22.2 N) maximum.

Test Results and Comments: Can be provided in a separate document.

4.7.7 Tickets: Fare Cards, and Keycards. Where tickets, fare cards, or keycards are provided, they shall have an orientation that is tactilely discernible if 

orientation is important to further use of the ticket, fare card, or keycard.

Test Results and Comments: Can be provided in a separate document.

4.7.8 Reach Height and Depth.

Stationary ICT – multifunction printer

At least one of each type of operable part of stationary ICT shall be at a height conforming to 4.7.8.2 or 4.7.8.3 according to its position established by the 

vertical reference plane specified in 4.7.8.1 for a side reach or a forward reach. Operable parts used with speech output required by 4.2.2 shall not be the only 

type of operable part complying with 4.7.8 unless that part is the only operable part of its type.

4.7.8.1 Vertical Reference Plane: Operable parts shall be positioned for a side reach or a forward reach determined with respect to a vertical reference plane.

The vertical reference plane shall be located in conformance to this section.

Complete or N/A Conformance Techniques 

4.7.8.1.1 Vertical Plane for 

Side Reach

Where a side reach is provided, the vertical reference plane shall be 48 inches (1220 mm) long 

minimum. 

4.7.8.1.2 Vertical Plane for 

Forward Reach

Where a forward reach is provided, the vertical reference plane shall be 30 inches (760 mm) long 

minimum.

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 18

4.7.8.2 Side Reach: Operable parts of ICT providing a side reach shall conform to this section. The vertical reference plane shall be centered on the operable 

part and placed at the leading edge of the maximum protrusion of the ICT within the length of the vertical reference plane. Where a side reach requires a reach 

over a portion of the ICT, the height of that portion of the ICT shall be 34 inches (865 mm) maximum.

Complete or N/A Conformance Techniques

4.7.8.2.1 Unobstructed 

Side Reach

Where the operable part is located 10 inches (255 mm) or less beyond the vertical reference plane, 

the operable part shall be 48 inches (1220 mm) high maximum and 15 inches (380 mm) high 

minimum above the floor.

4.7.8.2.2 Obstructed Side 

Reach

Where the operable part is located more than 10 inches (255 mm), but not more than 24 inches 

(610 mm), beyond the vertical reference plane, the height of the operable part shall be 46 inches 

(1170 mm) high maximum and 15 inches (380 mm) high minimum above the floor. The operable 

part shall not be located more than 24 inches (610 mm) beyond the vertical reference plane.

Test Results and Comments: Can be provided in a separate document.

4.7.8.3 Forward Reach: Operable parts of ICT providing a forward reach shall conform to 4.7.8.3.1 or 4.7.8.3.2. The vertical reference plane shall be centered, 

and intersect with, the operable part. Where a forward reach allows a reach over a portion of the ICT, the height of that portion of the ICT shall be 34 inches 

(865 mm) maximum.

4.7.8.3.1 Unobstructed Forward Reach: Where the operable part is located at the leading edge of the maximum protrusion within the length of the vertical 

reference plane of the ICT, the operable part shall be 48 inches (1220 mm) high maximum and 15 inches (380 mm) high minimum above the floor.

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 19

4.7.8.3.2 Obstructed Forward Reach: Where the operable part is located beyond the leading edge of the maximum protrusion within the length of the vertical 

reference plane, the operable part shall conform to 407.8.3.2. The maximum allowable forward reach to an operable part shall be 25 inches (635 mm). 

Complete or N/A Conformance Techniques

4.7.8.3.2.1 Operable Part 

Height for ICT with 

Obstructed Forward Reach

The height of the operable part shall conform to the following measurements: 

Reach Depth Operable Part Height 

Less than 20 inches (510 

mm)

48 inches (1220 mm) 

maximum

20 inches (510 mm) to 25 

inches (635 mm) 

44 inches (1120 mm) 

maximum 

4.7.8.3.2.2 Knee and Toe 

Space under ICT with 

Obstructed Forward Reach

Knee and toe space under ICT shall be 27 inches (685 mm) high minimum, 25 inches (635 mm) 

deep maximum, and 30 inches (760 mm) wide minimum and shall be clear of obstructions.

Exceptions: 

1. Toe space shall be permitted to provide a clear height of 9 inches (230 mm) minimum above 

the floor and a clear depth of 6 inches (150 mm) maximum from the vertical reference plane 

toward the leading edge of the ICT.

2. At a depth of 6 inches (150 mm) maximum from the vertical reference plane toward the 

leading edge of the ICT, space between 9 inches (230 mm) and 27 inches (685 mm) 

minimum above the floor shall be permitted to reduce at a rate of 1 inch (25 mm) in depth for 

every 6 inches (150 mm) in height.

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 20

4.8 Display Screens

Complete or N/A Conformance Techniques

408.1 General Where provided, display screens shall conform to this section. 

408.2 Visibility Where stationary ICT provides one or more display screens, at least one of each type of display 

screen shall be visible from a point located 40 inches (1015 mm) above the floor space where the 

display screen is viewed.

408.3 Flashing Where ICT emits lights in flashes, there shall be no more than three flashes in any one-second 

period.

Exception: Flashes that do not exceed the general flash and red flash thresholds defined in WCAG 

2.0 are not required to conform to this section.

Test Results and Comments: Can be provided in a separate document.

4.9 Status Indicators: Where provided, status indicators shall be discernible visually and by touch or sound.

Test Results and Comments: Can be provided in a separate document.

4.10 Color Coding: Where provided, color coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or 

distinguishing a visual element.

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 21

4.11 Audible Signals: Where provided, audible signals or cues shall not be used as the only means of conveying information, indicating an action, or 

prompting a response. 

Test Results and Comments: Can be provided in a separate document.

4.12 ICT with Two-Way Voice Communication

4.12.1 General: ICT that provides two-way voice communication shall conform to this section.

4.12.2 Volume Gain ICT that provides two-way voice communication shall conform to this section. 

Complete or N/A Conformance Techniques

4.12.2.1 Volume Gain for 

Wireline Telephones

Volume gain conforming to 47 CFR 68.317 shall be provided on analog and digital wireline 

telephones.

4.12.2.2 Volume Gain for 

Non-Wireline ICT

A method for increasing volume shall be provided for non-wireline ICT.

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 22

4.12.3 Interference Reduction and Magnetic Coupling: Where ICT delivers output by a handset or other type of audio transducer that is typically held up to 

the ear, ICT shall reduce interference with hearing technologies and provide a means for effective magnetic wireless coupling in conformance with 412.3.1 or 

412.3.2.

Complete or N/A Conformance Techniques

4.12.3.1 Wireless Handsets ICT in the form of wireless handsets shall conform to ANSI/IEEE C63.19-2011. 

4.12.3.2 Wireline Handsets ICT in the form of wireline handsets, including cordless handsets, shall conform to TIA-1083-B. 

Test Results and Comments: Can be provided in a separate document.

4.12.4 Digital Encoding of Speech: ICT in IP-based networks shall transmit and receive speech that is digitally encoded in the manner specified by ITU-T 

Recommendation G.722.2 (incorporated by reference, see 702.7.2) or IETF RFC 6716 (incorporated by reference, see 702.8.1).

Test Results and Comments: Can be provided in a separate document.

4.12.5 Real-Time Text Functionality [Reserved]. Pending Rulemaking by the FCC. 

4.12.6 Caller ID: Where provided, caller identification and similar telecommunications functions shall be visible and audible.

Test Results and Comments: Can be provided in a separate document.

4.12.7 Video Communication: Where ICT provides real-time video functionality, the quality of the video shall be sufficient to support communication using sign 

language.

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 23

4.12.8 Legacy TTY Support ICT equipment or systems with two-way voice communication that do not themselves provide TTY functionality shall conform to 

this section. 

Complete or N/A Conformance Techniques

412.8.1 TTY Connectability ICT shall include a standard non-acoustic connection point for TTYs. 

412.8.2 Voice and Hearing 

Carry Over

ICT shall provide a microphone capable of being turned on and off to allow the user to intermix 

speech with TTY use. 

412.8.3 Signal 

Compatibility

ICT shall support all commonly used cross-manufacturer non-proprietary standard TTY signal 

protocols where the system interoperates with the Public Switched Telephone Network (PSTN). 

412.8.4 Voice Mail and 

Other Messaging Systems

Where provided, voice mail, auto-attendant, interactive voice response, and caller identification 

systems shall be usable with a TTY. 

Test Results and Comments: Can be provided in a separate document.

4.13 Closed Caption Processing Technologies

4.13.1 General.: Where ICT displays or processes video with synchronized audio, ICT shall provide closed caption processing technology that conforms to this 

section

Complete or N/A Conformance Techniques

4.13.1.1 Decoding and 

Display of Closed Captions

Players and displays shall decode closed caption data and support display of captions. 

4.13.1.2 Pass-Through of 

Closed Caption Data Cabling and ancillary equipment shall pass through caption data.

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 24

4.14 Audio Description Processing Technologies

4.14.1 General: Where ICT displays or processes video with synchronized audio, ICT shall provide audio description processing technology conforming to this 

section.

Complete or N/A Conformance Techniques

4.14.1.1 Digital Television 

Tuners.

Digital television tuners shall provide audio description processing that conforms to ATSC A/53 

Digital Television Standard, Part 5 (2014) (incorporated by reference, see 702.2.1). Digital 

television tuners shall provide processing of audio description when encoded as a Visually 

Impaired (VI) associated audio service that is provided as a complete program mix containing 

audio description according to the ATSC A/53 standard.

4.14.1.2 Other ICT. ICT other than digital television tuners shall provide audio description processing.

Test Results and Comments: Can be provided in a separate document.

4.15 User Controls for Captions and Audio Descriptions

4.15.1 General: Where ICT displays video with synchronized audio, ICT shall provide user controls for closed captions and audio descriptions conforming to 

this section. 

Exception: Devices for personal use shall not be required to conform to this section provided that captions and audio descriptions can be enabled through 

system-wide platform settings.

Complete or N/A Conformance Techniques

415.1.1 Caption Controls Where ICT provides operable parts for volume control, ICT shall also provide operable parts for 

caption selection.

415.1.2 Audio Description 

Controls.

Where ICT provides operable parts for program selection, ICT shall also provide operable parts for 

the selection of audio description.

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 25

Part 5: Software

36 CFR 1194 Appendix C, Chapter 4

Software is defined as ”programs, procedures, rules, and related data and documentation that direct the use and operation of ICT and instruct it to perform a 

given task or function. Software includes, but is not limited to, applications, non-Web software, and platform software.” Software Tools are “software for which 

the primary function is the development of other software.” This includes software that is integral to the use of telecommunications functions of 

telecommunications equipment or customer premises equipment and has a user interface. 

Where components of ICT are software and transmit information or have a user interface, such components will conform to these requirements. 

Mobile software is treated the same as other software. 

Exceptions/Substitutions: 

• Software that is assistive technology and that supports the accessibility services of the platform shall not be required to conform. 

• Non-Web software shall not be required to conform to the following four Success Criteria in WCAG 2.0: 2.4.1 Bypass Blocks; 2.4.5 Multiple Ways; 3.2.3 

Consistent Navigation; and 3.2.4 Consistent Identification. 

• Word Substitution when Applying WCAG to Non-Web Software. For non-Web software, wherever the term “Web page” or “page” appears in WCAG 2.0 

Level A and AA Success Criteria and Conformance Requirements, the term “software” shall be substituted for the terms “Web page” and “page”. In 

addition, in Success Criterion in 1.4.2, the phrase “in software” shall be substituted for the phrase “on a Web page.

• Where non-Web software requires multiple steps to accomplish an activity, all software related to the activity to be accomplished shall conform to WCAG 

2.0 with the exceptions and substitutions noted above. 

• Web software/applications only needs to conform to Level A and Level AA Success Criteria and Conformance Requirements in WCAG 2.0. 

5.1 WCAG Conformance: User interface components, as well as the content of platforms and applications, shall conform to Level A and Level AA Success 

Criteria and Conformance Requirements in WCAG 2.0 with the noted exceptions and wording substitution, software for web page for non-web software.

Complete or N/A Conformance Techniques

5.1.1 WCAG 2.0, A and AA Complete the WCAG 2.0 conformance section found in Part 1: Electronic Content. 

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 26

5.2 Interoperability with Assistive Technology: 

5.2.1 Software shall interoperate with assistive technology. 

Exception: Software that conforms with 36 CFR 1194 Appendix C, Chapter 402 (software with closed functionality) does not need to conform to this section. 

Treat the system as a closed hardware system – kiosk, mobile phone where users can’t add their own assistive technologies.

Complete the following sections.

5.2.2 Documented Accessibility Features : Software with platform features defined in platform documentation as accessibility features shall conform to:

Complete or N/A Conformance Techniques

5.2.2.1 User Control of 

Accessibility Features

Platform software shall provide user control over platform features that are defined in the platform 

documentation as accessibility features.

System administrators cannot disable documented accessibility features of platforms. 

5.2.2.2 No Disruption of 

Accessibility Features.

Software shall not disrupt platform features that are defined in the platform documentation as 

accessibility features.

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 27

5.2.3 Accessibility Services: Platform software and software tools that are provided by the platform developer shall provide a documented set of accessibility 

services that support applications running on the platform to interoperate with assistive technology. Applications that are also platforms shall expose the 

underlying platform accessibility services or implement other documented accessibility services. 

• Programmatically determinable, programmatically set etc., – the user can get to it without a mouse. 

Complete or N/A Conformance Techniques

5.2.3.1 Object Information The object role, state(s), properties, boundary, name, and description shall be programmatically 

determinable.

5.2.3.2 Modification of 

Object Information

States and properties that can be set by the user shall be capable of being set programmatically, 

including through assistive technology.

5.2.3.3 Row, Column, and 

Headers

If an object is in a data table, the occupied rows and columns, and any headers associated with 

those rows or columns, shall be programmatically determinable.

5.2.3.4 Values Any current value(s), and any set or range of allowable values associated with an object, shall be 

programmatically determinable.

5.2.3.5 Modification of 

Values

Values that can be set by the user shall be capable of being set programmatically, including 

through assistive technology.

5.2.3.6 Label Relationships Any relationship that a component has as a label for another component, or of being labeled by 

another component, shall be programmatically determinable.

5.2.3.7 Hierarchical 

Relationships

Any hierarchical (parent-child) relationship that a component has as a container for, or being 

contained by, another component shall be programmatically determinable.

5.2.3.8 Text. The content of text objects, text attributes, and the boundary of text rendered to the screen, shall 

be programmatically determinable. No images of text. 

5.2.3.9 Modification of Text Text that can be set by the user shall be capable of being set programmatically, including through 

assistive technology.

5.2.3.10 List of Actions A list of all actions that can be executed on an object shall be programmatically determinable.

5.2.3.11 Actions on Objects Applications shall allow assistive technology to programmatically execute available actions on 

objects.

5.2.3.12 Focus Cursor Applications shall expose information and mechanisms necessary to track focus, text insertion 

point, and selection attributes of user interface components. The focus is visible.

5.2.3.13 Modification of 

Focus Cursor

Focus, text insertion point, and selection attributes that can be set by the user shall be capable of 

being set programmatically, including through the use of assistive technology. 

5.2.3.14 Event Notification Notification of events relevant to user interactions, including but not limited to, changes in the 

component’s state(s), value, name, description, or boundary, shall be available to assistive 

technology. Anything that happens visually on the screen is also available to assistive technology 

users. 
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 28

Test Results and Comments: Can be provided in a separate document.

5.2.4 Platform Accessibility Features: Platforms and platform software shall conform to the following requirements in ANSI/HFES 200.2, Human Factors 

Engineering of Software User Interfaces - Part 2: Accessibility (2008).

Complete or N/A Conformance Techniques

5.2.4. Enable sequential 

entry of multiple (chorded) 

keystrokes

Sticky keys, Shift + letter. 

5.2.4.2 Provide adjustment 

of delay before key 

acceptance

Bounce keys. 

5.2.4.3 .Provide adjustment 

of same-key double-strike 

acceptance

Filter keys, key repeat time. 

5.2.4.4 Allow users to 

choose visual alternative 

for audio output

Show sounds. 

5.2.4.5 Synchronize audio 

equivalents for visual 

events

Hear things as they are seen on the screen. 

5.2.4.6 Provide speech 

output services;

5.2.4.7 Display any 

captions provided

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 29

5.3 Applications

Exception: Assistive Technology is exempt. 

5.3.1 General

Complete the following sections. 

5.3.2 User Preferences: Applications shall permit user preferences from platform settings for color, contrast, font type, font size, and focus cursor.

Exception: Applications that are designed to be isolated from their underlying platform software, including Web applications (sandboxed), shall not be required 

to conform.

Test Results and Comments: Can be provided in a separate document.

5.3.3 Alternative User Interfaces.: Where an application provides an alternative user interface that functions as assistive technology, the application shall use 

platform and other industry standard accessibility services.

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 30

5.3.4 User Controls for Captions and Audio Description: For software presenting multimedia. 

Where ICT displays video with synchronized audio, ICT shall provide user controls for closed captions and audio descriptions conforming to 503.4.

Complete or N/A Conformance Techniques

5.3.4.1 Caption Controls Where user controls are provided for volume adjustment, ICT shall provide user controls for the 

selection of captions at the same menu level as the user controls for volume or program selection.

5.3.4.2 Audio Description 

Controls

Where user controls are provided for program selection, ICT shall provide user controls for the 

selection of audio descriptions at the same menu level as the user controls for volume or program 

selection.

Test Results and Comments: Can be provided in a separate document.

5.4 Authoring Tools An authoring tool is any software, or collection of software components, that can be used by authors, alone or collaboratively, to create or 

modify content for use by others, including other authors.

5.4.1 General: Where an application is an authoring tool, the application shall conform to this section to the extent that information required for accessibility is 

supported by the destination format.

Complete the following sections. 
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 31

5.4.2 Content Creation or Editing: Authoring tools shall provide a mode of operation to create or edit content that conforms to Level A and Level AA Success 

Criteria and Conformance Requirements in WCAG 2.0 or all supported features and, as applicable, to file formats supported by the authoring tool. Authoring 

tools shall permit authors the option of overriding information required for accessibility. 

Exception: Authoring tools shall not be required to conform to this section when used to directly edit plain text source code.

Complete or N/A Conformance Techniques

5.4.2.1 Preservation of 

Information Provided for 

Accessibility in Format 

Conversion

Authoring tools shall, when converting content from one format to another or saving content in 

multiple formats, preserve the information required for accessibility to the extent that the 

information is supported by the destination format.

5.4.2.2 PDF Export. Authoring tools capable of exporting PDF files that conform to ISO 32000-1:2008 (PDF 1.7) shall 

also be capable of exporting PDF files that conform to ANSI/AIIM/ISO 14289-1:2016 (PDF/UA-1). 

Test Results and Comments: Can be provided in a separate document.

5.4.3 Prompts: Authoring tools shall provide a mode of operation that prompts authors to create content that conforms to Level A and Level AA Success 

Criteria and Conformance Requirements in WCAG 2.0 for supported features and, as applicable, to file formats supported by the authoring tool.

Test Results and Comments: Can be provided in a separate document.

5.4.4 Templates: Where templates are provided, templates allowing content creation that conforms to Level A and Level AA Success Criteria and 

Conformance Requirements in WCAG 2.0 shall be provided for a range of template uses for supported features and, as applicable, to file formats supported by 

the authoring tool.

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 32

Part 6: Support Documentation

36 CFR 1194 Appendix C, Chapter 6

6.1 General: Where an agency provides support documentation or services for ICT, such documentation and services shall conform to the requirements in this 

section. 

Complete the three following sections.

6.2 Support Documentation

Complete or N/A Conformance Techniques

6.2.1 General. Placeholder. 

6.2.2 Accessibility and 

Compatibility Features

Documentation shall list and explain how to use the accessibility and compatibility features 

required by Parts 4 and 5. Documentation shall include accessibility features that are built-in and 

accessibility features that provide compatibility with assistive technology.

602.3 Electronic Support 

Documentation

Documentation in electronic format, including Web-based self-service support, shall conform to 

Level A and Level AA Success Criteria and Conformance Requirements in WCAG 2.0. 

6.2.4 Alternate Formats for 

Non-Electronic Support 

Documentation

Where support documentation is only provided in non-electronic formats, alternate formats usable 

by individuals with disabilities shall be provided upon request.

Test Results and Comments: Can be provided in a separate document.
Form FHWA 4260.1 (8/19, updated 6/20) 

Replaces Form DOT 4260 Page | 33

6.3 Support Services

Complete or N/A Conformance Techniques

6.3.1 General ICT support services including, but not limited to, help desks, call centers, training services, and 

automated self-service technical support, shall conform. 

6.3.2 Information on 

Accessibility and 

Compatibility Features

ICT support services shall include information on the accessibility and compatibility features 

required by Part 6.2.

6.3.3 Accommodation of 

Communication Needs

Support services shall be provided directly to the user or through a referral to a point of contact. 

Such ICT support services shall accommodate the communication needs of individuals with 

disabilities.

Test Results and Comments: Can be provided in a separate document.