1. Do documents submitted to the Secretary of State’s Office need to meet accessibility standards?

Yes. In accordance with Colorado’s accessibility rules and statutes, all public entities and state agencies must comply with the accessibility standards established by the Governor’s Office of Information Technology (OIT) when submitting documents to be published by the Secretary of State’s Office, per sections 24-34-802(1) and 24-4-103(12), C.R.S.

All public entities and state agencies are encouraged to submit their filings ahead of their relevant filing deadlines, as the Secretary of State’s Office will, where possible, evaluate whether filings are compliant with 8 CCR 1501-11, Rule 11.5, and require inaccessible documents to be resubmitted in an accessible format. Failure to submit compliant documents may impact a rulemaking deadline, including publication, adoption, and effective dates.

2. How to run an accessibility check in Word

1. Open your document in Microsoft Word
2. Go to the “Review” tab
3. Click “Check Accessibility”
4. Review the results and follow the recommendations provided to fix any issues

This process helps ensure your documents are readable by screen readers and accessible to all members of the public.

3. What are the most common accessibility issues?

The most common issues we have identified are the following:

The absence of alternative text on images. Alternative text (alt text) is a brief description of an image that helps screen readers convey its content to visually impaired users and improves accessibility.

Missing headings. Heading levels play a crucial role in accessibility because they provide structure and hierarchy to content, which benefits users who rely on assistive technologies like screen readers.

Missing alt text

If an image is flagged, you can add alt text by completing the following steps:

1. Click “Missing alt text”
2. Enter the image description
3. Click “Save”
4. If the image is decorative and doesn’t convey meaningful information, you can check the box labeled “Mark as decorative”

Note: AI often adds alt text automatically, which means those images might not appear in the accessibility check. However, AI-generated descriptions aren’t always accurate. To ensure compliance and accessibility, review all images, not just those flagged, and confirm the alt text is correct.

To add alt text before running the accessibility check, simply right-click on the image, select “View Alt Text”, and enter a description in the provided field.

Missing headings

All documents must have the appropriate heading structure. Ensure headings are applied whether they are flagged or not.

If your document is missing headings, you can add them by following these steps:

1. Go to the Home tab
2. In the Styles group on the ribbon, select the appropriate heading style
3. Apply Heading 1 to your document title
4. Use Heading 2, Heading 3, and so on for subsections to maintain a logical structure

Additional tips for using headings effectively:

• Start with a Heading 1
• Each document should have one, and only one, unique Heading 1
• Nest headings and don’t skip levels
• Do not exceed more than five or six levels of headings

4. How do I resubmit a filing after it has been rejected?

When a filing is rejected, the person who submitted the rulemaking and listed their email address as the AG / SOS / OLLS contact will receive an email notification. That email will explain the reason for the rejection and include instructions for resubmission.

To resubmit the filing:

1. Log in to your Secretary of State Admin Rules account
2. Select the type of rulemaking you are submitting
3. Choose the option “Resubmit a Rejected Filing”
4. Follow the instructions provided to correct and resubmit the filing

Please ensure that you are resubmitting rejected documents at least five days before the Colorado Register publication to ensure our office has enough time to review and process the resubmitted documents.

5. What happens if a rejected filing is not corrected at least five days before Colorado Register publication?

If a rejected filing is not corrected and resubmitted at least five days before a Colorado Register publication date, it will not be included in that Register. Instead, once the corrected filing is successfully resubmitted and accepted, it will be posted in the next available Colorado Register.

The Colorado Register is published twice each month, on the 10th and 25th.

6. How do I know if my table is accessible?  

Microsoft Word’s accessibility checker does not always identify accessibility issues with tables, especially tables that are pasted in from Excel, PDFs, or other sources. Because of this, tables must be manually reviewed to ensure they follow accessibility best practices.

7. What accessibility best practices should I follow when creating tables?

When creating or reviewing tables, follow these accessibility guidelines:

• Use tables only for data. Tables should present information that requires comparison across rows and columns. Do not use tables for visual layout or formatting
• Avoid overly complex tables. Keep tables simple and easy for screen readers to navigate
• Do not merge or split cells. Merged or split cells can confuse screen readers and disrupt reading order
• Do not nest tables within other tables. Nested tables are difficult for assistive technology to interpret
• Do not include blank rows or columns. Empty cells can be misleading or confusing for users of assistive technology
• Prevent rows from breaking across pages. Table rows should remain intact to preserve context and readability

8. What should I do if I am copying tables from a PDF?

Create a new table in Word or Excel and only copy the data from the PDF into the table. Avoid copying any formatting from the PDF table. Make sure to follow accessibility best practices for tables (as mentioned previously) when creating the new table.

If the data is copied into Excel, copy it into the Word document. Microsoft Word’s accessibility checker may not check Excel-copied tables for accessibility, so it will need manual review.

9. How are signatures protected in electronic documents?

We understand that some agencies choose to include signatures in supporting documents filed as part of the rulemaking process. However, the APA does not require signatures. When included, they are generally added at the agency’s discretion in accordance with internal policy.

You may consider including a placeholder in the document submitted to us using language such as: “Approved and signed by [Title], [Agency], on [Date]. The signed version is maintained by the agency.” This allows your agency to retain the executed version as the official signed record.

Ultimately, it is up to each agency, in consultation with its Attorney General, to determine whether a signature is necessary, whether the materials posted are sufficient, and how any signature is added to the document.

As a best practice, we recommend that signatures not be included in the actual text of the rule itself.

10. What security considerations should I be aware of when submitting electronic files?

All documents submitted for rulemaking are publicly accessible. Agencies should review files before submission to ensure they do not contain unintended or sensitive metadata. Each agency is responsible for ensuring submitted files meet its security and records requirements.

Remove items such as comments and hidden text. As a best practice, update the document author to the agency name rather than an individual.

In Microsoft Word, metadata can be reviewed and removed by:

1. Select “File”
2. Select “Info”
3. Select “Check for Issues”
4. Select “Inspect Document”
5. Select “Remove All” as needed
6. Save the document

11. Can I use Google Docs to create my document, and what accessibility issues should I watch for when saving as a DOCX?

Yes. You may use Google Docs to draft your document, but you should review accessibility carefully when saving and submitting it as a DOCX file.

When exporting from Google Docs to DOCX, watch for common accessibility issues such as missing heading structure, incorrect reading order, images without alternative text, and tables without header rows.

12. How should I use the Microsoft Word accessibility checker, and what are its limitations (for example, with tables)?

In Word, open your document, select “Review”, then “Check Accessibility”, and address any errors or warnings it identifies.

The checker is effective at detecting issues such as missing headings, insufficient color contrast, and missing alternative text for images. However, it has limitations. You should manually review tables to ensure header rows are defined, reading order is logical, and table layout is simple and meaningful. Similar manual review is recommended for charts, images, and document reading order. The accessibility checker should be used as a support tool alongside human review, not as a substitute for it.

13. How can state agencies make accessibility updates to existing rules?

Contact your Assistant Attorney General (AAG) to determine whether the accessibility updates are substantive or non-substantive.

The Attorney General’s office has advised that for non-substantive accessibility updates, agencies should use the standard correction filing process: Instructions for a correction filing.

Request your assigned AAG to prepare a correction letter that:

• Details the changes
• Explains the reason for the updates
• Confirms the changes are non-substantive

14. Where can I get help with accessibility requirements?

Our office is unable to provide guidance on correcting accessibility issues. We recommend reaching out to an accessibility specialist within your agency. If your agency does not have one, you may consider contacting OIT for assistance. There are also a lot of helpful online resources that assist with making documents accessible.