CCR Translation and Accessibility Requirements Under the 2027 Rule
For twenty-eight years, the Consumer Confidence Report (CCR) was effectively an English-language document. The 1998 CCR Rule asked community water systems to make the report available in a language other than English only if a substantial portion of the service population spoke that language, and left the threshold, the required elements, and the enforcement mechanism to the primacy agency. Most utilities translated a short notice — a sentence on the front page that said "important information, contact us for a translation" — and considered that sufficient. The result, over two decades, was a CCR disclosure regime that reached English-language customers clearly and everyone else only in principle.
The revised CCR Rule, finalized by EPA on May 24, 2024 (Federal Register docket EPA-HQ-OW-2022-0260, 89 FR 45980; regulatory text at 89 FR 46012) with a January 1, 2027 compliance date, keeps the primacy-agency-driven translation duty under 40 CFR §141.153(h)(3) and adds a new language-assistance-plan requirement under §141.155(i) for systems serving 100,000 or more persons. The rule does not set a fixed federal percentage threshold — the trigger is "a large proportion of consumers with limited English proficiency, as determined by the Primacy Agency." On top of that, EPA's 2024 rulemaking formalizes digital accessibility for electronic CCR delivery, aligning it with the Americans with Disabilities Act (ADA) and Section 508 of the Rehabilitation Act.
This guide walks through the federal CCR language requirements under §141.153(h)(3) and the §141.155(i) language-assistance-plan obligation, the state-specific translation thresholds primacy agencies have adopted (California, New York, New Jersey, and others), the Title VI civil-rights implications of failing to translate, the digital accessibility obligations tied to direct-URL electronic delivery, and the plain-English reading-level guidance that applies across both the English and translated versions of the CCR. For the broader rule, see the CCR requirements 2027 summary; for the full drafting workflow, see how to write a CCR.
Translation-trigger decision matrix
| Layer | Source | Trigger | What's required |
|---|---|---|---|
| Federal floor | 40 CFR §141.153(h)(3) | "A large proportion of consumers with limited English proficiency, as determined by the Primacy Agency" | Report must contain information in the appropriate language(s) on the importance of the report and either a path to a translated copy / in-language assistance, or be delivered in the appropriate language(s) |
| Large-system layer | 40 CFR §141.155(i) | Community water system serves ≥100,000 persons | Written language-assistance plan submitted with the first 2027 report; evaluated annually and updated as needed |
| Primacy-agency layer | State regulations (CA, NY, NJ, TX, etc.) | State-specific percentage or population thresholds (often more stringent than the federal floor) | Varies by state — see state-specific translation mandates below |
| Title VI layer | Civil Rights Act of 1964 / DOJ LEP Guidance | Recipient of federal financial assistance + LEP population in service area | Meaningful access for LEP individuals via a four-factor analysis; enforced by EPA ECRCO / DOJ |
The practical sequence for any utility is (1) confirm the primacy agency's adopted threshold, (2) if the system serves ≥100,000, draft the §141.155(i) plan, (3) overlay Title VI obligations if the system receives federal funds.
Federal CCR language requirements under §141.153(h)(3)
The revised 40 CFR §141.153(h)(3) preserves — and does not replace — the primacy-agency-driven translation trigger the 1998 rule established. The regulatory text reads: "In communities with a large proportion of consumers with limited English proficiency, as determined by the Primacy Agency, the report must contain information in the appropriate language(s) regarding the importance of the report and either contain information where such consumers may obtain a translated copy of the report, or assistance in the appropriate language(s), or the report must be in the appropriate language(s)."
What that means operationally: there is no fixed federal percentage or headcount that automatically triggers translation. The primacy agency — a state or tribal drinking-water program acting under SDWA delegation — decides which communities qualify as having "a large proportion" of limited-English-proficient (LEP) consumers, and which languages are "appropriate." Many primacy agencies have adopted explicit percentage or headcount tests (see the state-specific section below); others apply a case-by-case determination.
The utility has three compliance paths once the primacy-agency trigger is met: (a) include in-language text inside the CCR about the importance of the report plus a pointer to where a translated copy or in-language assistance can be obtained, (b) provide in-language assistance directly, or (c) deliver the report itself in the appropriate language(s). Most utilities choose option (a) at the minimum-compliance margin and option (c) for primary languages with large service-population shares.
The rule does not require utilities to translate every data table, every footnote, or every piece of marketing content in the CCR. The operational constraint is clarity over completeness: the translated content must enable an LEP customer to understand the importance of the report and find a path to a full translation or in-language assistance.
§141.155(i) — language-assistance plans for systems serving 100,000 or more
The 2024 rulemaking adds a new §141.155(i) obligation separate from §141.153(h)(3). Every community water system serving 100,000 or more persons must develop a written plan for providing assistance to consumers with limited English proficiency. The plan must (1) evaluate the languages spoken by LEP persons in the service area and (2) describe the utility's anticipated approach to translation needs. The first plan must be submitted to the state with the first 2027 CCR, and plans must be evaluated annually and updated as necessary; updates are reported with the §141.155(c) certification.
This large-system plan requirement operates in parallel with — not as a substitute for — §141.153(h)(3). A utility serving 200,000 people with a substantial LEP population is subject to both: the §141.155(i) planning obligation and the §141.153(h)(3) in-CCR translation duty triggered by the primacy agency.
Translation quality is not explicitly regulated in the federal text, but EPA's 2024 preamble points to professional translation standards — ASTM F2575 or ISO 17100 — as the benchmark utilities should meet. A word-for-word machine translation that produces ambiguous or technically incorrect content does not satisfy the "appropriate language(s)" standard; the translation must preserve the technical meaning of the English source. Most utilities subject to translation obligations contract with professional translation vendors rather than relying on in-house bilingual staff or free machine translation.
State-specific translation mandates
Because §141.153(h)(3) delegates the "large proportion" determination to primacy agencies, state rules and guidance are the operative tests in most jurisdictions. Utilities should treat the thresholds below as illustrative of the public-facing guidance or rule text each agency has issued, and confirm the current version with the primacy agency before relying on any specific number.
California. The California State Water Resources Control Board Division of Drinking Water (DDW) administers CCR language requirements through state-level health-communication practice, which commonly uses a 5-percent or 1,000-resident threshold for "threshold languages" (Spanish, Chinese, Vietnamese, Korean, Tagalog, Armenian, Russian, Farsi, Arabic, Punjabi, and others depending on the region). DDW has published state-specific model translations for the required health-effects language. California's CCR translation obligation operates in parallel with the state's civil-rights framework under the Dymally-Alatorre Bilingual Services Act (Government Code §7290 et seq.). Confirm current DDW guidance with your district engineer.
New York. The New York State Department of Health Bureau of Water Supply Protection historically has used a substantial-LEP-population trigger for CCR translation and has not codified a single statewide numeric threshold. New York City separately operates Local Law 30, which designates Spanish, Chinese, Russian, Bengali, Haitian Creole, Korean, Arabic, Urdu, French, and Polish as city-level languages for municipal agency communications. NYC-area utilities operating under both state and city frameworks should align their translation list to the broader of the two.
New Jersey. The New Jersey Department of Environmental Protection (NJDEP) enforces §141.153(h)(3) as an SDWA-primacy obligation and issues guidance through its Bureau of Safe Drinking Water. NJDEP has not published a single statewide numeric percentage; the agency evaluates "substantial LEP population" against service-area demographics. See the revised CCR rule 2027 New Jersey guide for the NJDEP electronic-reporting-portal context.
Texas, Illinois, Florida, and Massachusetts. Primacy agencies in these states (TCEQ, IEPA, FDEP, MassDEP) apply the §141.153(h)(3) standard through state rules and guidance. Spanish is the most common secondary language across Texas and south Florida; Haitian Creole is a common additional language in south Florida; Portuguese, Chinese, and Spanish are common secondary languages in Massachusetts. Check each agency's current drinking-water-program guidance for the specific numeric trigger applied in your service area.
Utilities operating across multiple primacy jurisdictions must apply the most stringent translation threshold for each portion of their service area. A wholesale provider serving retail customers in two states with different thresholds must translate against the lower of the two thresholds for customers in the stricter state.
Title VI civil-rights implications
Translation failures under the CCR Rule are not only SDWA compliance issues; they are also potentially Title VI civil-rights issues. Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin by recipients of federal financial assistance, and the US Department of Justice has long interpreted Title VI to require meaningful access to federally-assisted programs for limited-English-proficient (LEP) individuals.
Community water systems that receive federal funding — through the State Revolving Fund (SRF), through EPA infrastructure grants, through USDA Rural Development, or through other federal programs — are subject to Title VI. A utility that serves a substantial LEP population and fails to provide meaningful access to the CCR (the federal disclosure document that tells the customer whether their drinking water is safe) can be subject to a Title VI complaint filed with EPA's External Civil Rights Compliance Office (ECRCO) or with the US Department of Justice.
ECRCO has investigated and resolved several Title VI CCR complaints since the mid-2010s, with findings that include required translation of the full CCR into Spanish and other primary service-area languages, required translation of the direct-URL notice, and required provision of in-person interpretation at public meetings where the CCR is discussed. The Title VI enforcement mechanism operates in parallel with SDWA compliance: a utility that technically satisfies the primacy agency's §141.153(h)(3) determination can still face a Title VI finding if the threshold language is inadequate for the LEP population the utility serves.
The DOJ Title VI guidance on language access, most recently updated in the "LEP Guidance for Recipients of Federal Financial Assistance" framework, provides a four-factor analysis that utilities can use to evaluate their Title VI exposure: the number or proportion of LEP persons in the service area, the frequency of contact with the program, the nature and importance of the program, and the resources available to the recipient. For CCR disclosures, the "nature and importance" factor is weighed heavily because the CCR is the federal disclosure document for drinking-water safety — a service that is federally designated as essential to public health.
Utilities that receive federal funding should treat Title VI compliance as a companion obligation to §141.153(h)(3), not as a separate workstream. A translation program that satisfies the primacy agency's SDWA determination but does not adequately serve the actual LEP customer base is a Title VI exposure regardless of technical SDWA compliance.
Spanish as the most common secondary language
Spanish is the most common secondary language in community water system service areas across the United States. According to ACS 2019-2023 five-year estimates, Spanish is spoken at home by approximately 41.8 million US residents, representing roughly 13.2 percent of the population. In several states — California, Texas, New Mexico, Arizona, Florida — Spanish-speaking residents represent 20 percent or more of the state population, and in many utility service areas the share exceeds 30 percent.
For utilities whose primacy agency triggers a Spanish translation obligation under §141.153(h)(3), Spanish translation is the baseline. EPA has published Spanish-language model language for the standard CCR health-effects disclosures, and state primacy agencies in Spanish-heavy jurisdictions (California, Texas, New Mexico) publish state-specific Spanish model language that utilities can adopt directly.
Professional Spanish translation for CCR content typically runs 15 to 25 cents per word for the initial translation plus 10 to 15 percent for review and quality assurance. For a typical mid-size community water system CCR of 2,500 to 4,000 English words, the full Spanish translation cost runs roughly $500 to $1,200 per year. The cost is not the binding constraint for most utilities; the binding constraint is vendor-coordination lead time, which typically requires a 4 to 6 week turnaround from English draft lock to finished Spanish deliverable.
The CCR small utility compliance guide covers the translation budgeting and vendor-coordination sequence for smaller systems that need to translate Spanish (or another secondary language) but do not have an existing vendor relationship. Larger utilities with established translation vendors can typically integrate CCR translation into existing translation workflows with minimal incremental cost.
Vietnamese, Chinese, Korean, and other threshold languages
Beyond Spanish, utilities in specific regional markets face translation obligations for other high-population secondary languages.
Vietnamese. Vietnamese is a common threshold language in several California primacy jurisdictions (Orange County, San Jose) and in parts of Houston and Dallas-Fort Worth. The Vietnamese-American population in Orange County, California exceeds 200,000 residents, and several retail service areas within the county have Vietnamese-speaking shares large enough that the state primacy agency treats Vietnamese as a required language. Vietnamese translation vendors are less common than Spanish vendors, and lead times are typically 6 to 8 weeks.
Chinese. Chinese is a common threshold language in California (Simplified and Traditional), New York, and several other jurisdictions. The Chinese-speaking population in California's San Francisco Bay Area and the Los Angeles region, as well as New York City's outer boroughs, frequently triggers primacy-agency translation requirements. Utilities must translate into the appropriate character set — Simplified Chinese is standard for mainland-China-origin populations, Traditional Chinese for Taiwan-origin populations — and most utilities serving substantial Chinese populations translate into both.
Korean. Korean is a threshold language in parts of California (Los Angeles, Orange County) and the New York City metropolitan area. Korean translation vendors are established in these markets but less common outside them.
Tagalog. Tagalog is a threshold language in Hawaii and in parts of California (San Francisco Bay Area, San Diego). Hawaii's Department of Health Safe Drinking Water Branch has adopted state-specific Tagalog model language for CCR delivery.
Arabic. Arabic is a threshold language in parts of Michigan (Dearborn), California, and the Washington, DC metropolitan area. Arabic translation requires attention to the right-to-left text direction in the CCR layout, which adds design complexity beyond the translation itself.
Haitian Creole. Haitian Creole is a threshold language in South Florida and in Massachusetts. Florida and Massachusetts primacy agencies publish state-specific Haitian Creole model language for CCR delivery.
Utilities should identify candidate threshold languages through American Community Survey (ACS) language-at-home data for the specific service area rather than statewide data, then confirm the applicable trigger with the primacy agency. A utility serving a specific neighborhood or municipality may face translation obligations that differ from the statewide picture.
ADA Section 508 digital accessibility
Electronic delivery of the CCR via direct URL triggers a set of digital-accessibility obligations beyond translation. Under the 2024 rulemaking, EPA formalized the alignment of CCR electronic delivery with the Americans with Disabilities Act (ADA) and Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. §794d), which together require that electronic and information technology produced or used by federal agencies (and by recipients of federal funding) be accessible to individuals with disabilities.
The operational standard is the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, which the US Access Board adopted as the Section 508 refresh standard in 2017. For CCR electronic delivery, WCAG 2.1 AA compliance requires several specific elements. First, all non-text content — contaminant tables, charts, graphics — must include alternative text (alt text) that conveys the information to a screen-reader user. Second, contaminant tables must be marked up with proper HTML table semantics (header rows, column scopes) so that screen readers can navigate the table structure. Third, the CCR document must support keyboard navigation — a user who cannot use a mouse must be able to access every element of the CCR via keyboard-only input. Fourth, color contrast between text and background must meet the 4.5:1 ratio for body text and the 3:1 ratio for large text. Fifth, the CCR must be readable at 200 percent zoom without loss of content or functionality.
For CCRs delivered as PDF documents, the accessibility obligations are tied to PDF/UA (ISO 14289-1) compliance, which is the PDF-specific implementation of WCAG principles. A PDF CCR must include tagged document structure, alt text for images, and accessible table markup. Most utilities using PDF delivery run their CCR PDFs through PDF accessibility checkers (Adobe Acrobat's built-in accessibility checker, PAC 2021, or CommonLook PDF) before publication.
Mobile accessibility is a practical extension of the WCAG framework. CCRs hosted at a direct URL must render legibly on mobile devices, including responsive table layouts for contaminant data, touch-friendly tap targets for any interactive elements, and a mobile-readable summary section. Utilities that publish their CCR as a desktop-optimized PDF and do not provide a mobile-responsive HTML version often fail the mobile-accessibility prong of the WCAG standard even when the underlying content meets other requirements.
Alt text for contaminant tables
Contaminant tables are the most information-dense part of a CCR and the part most likely to fail accessibility review. Under WCAG 2.1 AA, each contaminant table must include a table caption or summary that describes the purpose of the table, header rows marked as <th> with appropriate scope attributes, and alt text for any chart or graphic embedded in the table.
For the standard CCR contaminant table — contaminant name, detected level, MCL, MCLG, violation status, source — the alt text requirement applies to any embedded chart (a detected-level-versus-MCL bar chart, for example) but not to the table itself, which is structurally accessible when marked up properly. A common mistake is rasterizing the contaminant table as a single image for layout convenience, which produces an image that a screen reader cannot parse. The fix is to render the table as actual HTML (or as an accessible PDF table) rather than as an image.
For charts and graphics embedded in the CCR body — source-water schematics, treatment-process diagrams, contaminant-trend charts — the alt text must describe the information conveyed by the graphic, not merely its appearance. An alt-text description of "bar chart showing detected total trihalomethane levels of 42, 48, 51, and 55 μg/L for Q1 through Q4 of 2026, with an MCL of 80 μg/L marked as a reference line" conveys the information; an alt-text description of "trihalomethane chart" does not.
The CCR 2027 checklist includes the accessibility-review elements as a compliance-tracking checklist so that tagged document structure, alt text, and table markup are not deferred to the final production pass. Software support for accessibility-friendly CCR rendering, including template libraries that produce WCAG-compliant output by default, is covered in the CCR software guide.
Screen-reader compatibility
Screen-reader compatibility is the operational test of accessibility for the electronic CCR. A utility can verify screen-reader compatibility by running the CCR through NVDA (open-source, Windows), JAWS (commercial, Windows), or VoiceOver (built-in, macOS and iOS) and confirming that the summary section, compliance-status statement, contaminant tables, and direct-URL notice are all rendered intelligibly.
Common screen-reader compatibility failures include tables rendered as images (unreadable), contaminant names rendered with special characters that the screen reader mispronounces (fixable with phonetic spelling or pronunciation hints), footnote numbers that disrupt sentence flow (fixable by moving footnotes to end-of-section), and direct-URL text that is rendered as a hyperlink without plain-text backup (fixable by including the URL in plain text in addition to the hyperlink).
Utilities subject to ADA Title II (state and local government agencies) or Title III (public accommodations) face a legal-exposure prong beyond the technical accessibility standard. The 2022 DOJ ADA Title II guidance on web accessibility explicitly identifies WCAG 2.1 AA as the reference standard for ADA compliance, and federal district court decisions have applied that standard to state and municipal agency websites including utility-operated CCR portals. A utility that operates a non-accessible CCR portal can be subject to an ADA complaint filed with DOJ or with the utility's state attorney general.
Plain-English reading-level guidance
The plain-language requirement finalized in the 2024 rulemaking applies across the entire CCR — including the translated versions — and interacts with the translation and accessibility obligations in practical ways.
EPA did not finalize a specific Flesch-Kincaid target grade level in the 2024 rulemaking, but the preamble points to readability guidance used by federal agencies under the Plain Writing Act of 2010 and CDC clear-communication guidance. The consensus target for general-audience health communications — drawn from the CDC, the National Institutes of Health, and the Centers for Medicare and Medicaid Services — is a 6th-grade reading level. Some state primacy agencies have adopted a 5th-grade reading level for CCR content specifically, on the theory that the CCR must be understandable to customers with limited formal education.
In practice, three drafting rules get a utility to a 5th- or 6th-grade reading level. First, use short sentences (average 15 words or fewer) and active voice ("we tested our water" instead of "water testing was conducted"). Second, define technical terms on first use and use the defined term consistently ("maximum contaminant level, or MCL, is the highest level of a contaminant that is allowed in drinking water under federal rules"). Third, avoid jargon and unnecessary acronyms ("the state drinking-water program" is clearer than "the primacy agency" even though the second term is more precise).
Readability applies to translated content as well. A Spanish translation of a CCR written at a 10th-grade English reading level will produce a Spanish translation at a 10th-grade Spanish reading level, which does not meet the plain-language standard. The practical fix is to write the English source at the target reading level first, then translate. Translating a complex English source and hoping the translator simplifies it produces inconsistent results.
The how to write a CCR guide covers the drafting sequence that produces a plain-language source. The CCR summary section 2027 guide covers the summary-specific application of the plain-language standard. Utilities coordinating translation and drafting teams should review the utilities resource hub for workflow references, and the CCR 2027 deadline calendar for scheduling translation vendor engagement relative to the July 1, 2027 delivery deadline.
FAQ
What is the federal threshold for translating my CCR?
There is no fixed federal percentage. Under 40 CFR §141.153(h)(3), translation is required "in communities with a large proportion of consumers with limited English proficiency, as determined by the Primacy Agency." The primacy agency — typically a state drinking-water program — decides which communities meet the "large proportion" standard and which languages are "appropriate." Some primacy agencies have published explicit percentage or headcount tests; others apply a case-by-case determination. Utilities must also comply with §141.155(i), which requires every community water system serving 100,000 or more persons to develop a written language-assistance plan submitted with the first 2027 CCR and updated annually. For background on the broader CCR rule framework, see what is a CCR.
What CCR content must be translated?
Under §141.153(h)(3), once the primacy agency has determined translation is required, the report must contain — in the appropriate language(s) — information on the importance of the report and either (a) a pointer to where a translated copy or in-language assistance can be obtained, or (b) the appropriate language(s) directly embedded throughout. State primacy agencies may require translation of additional content; some states expect full-CCR translation, not only a summary. Utilities should default to translating the summary section and the direct-URL notice at a minimum and be prepared to produce a full translated CCR on request.
How does Title VI affect my CCR translation obligation?
Community water systems that receive federal funding are subject to Title VI of the Civil Rights Act, which requires meaningful access for limited-English-proficient (LEP) individuals. A utility that technically satisfies its primacy agency's §141.153(h)(3) determination can still face a Title VI complaint if the translation program is inadequate for the actual LEP customer base. The DOJ LEP Guidance four-factor analysis — number of LEP persons, frequency of contact, nature and importance, resources available — governs Title VI compliance. Utilities with substantial LEP populations should treat Title VI compliance as a companion obligation to SDWA compliance.
What accessibility standard applies to my electronic CCR?
WCAG 2.1 Level AA is the reference standard, adopted by the US Access Board as the Section 508 refresh standard in 2017 and identified by DOJ as the benchmark for ADA web-accessibility compliance. For PDF CCRs, PDF/UA (ISO 14289-1) is the PDF-specific implementation. Utilities delivering CCRs via direct-URL electronic delivery must ensure the hosted document meets WCAG 2.1 AA including alt text for non-text content, accessible table markup, keyboard navigation, adequate color contrast, and 200-percent zoom without content loss. Mobile accessibility is a practical extension of the WCAG framework and is enforced through the same standard.
What reading level should my CCR target?
A 5th- to 6th-grade reading level, aligned with federal clear-communication guidance under the Plain Writing Act of 2010 and CDC health-communication standards. EPA did not finalize a specific Flesch-Kincaid threshold in the 2024 rulemaking, but the preamble points to the federal plain-language framework as the benchmark. State primacy agencies may adopt more specific standards; some have adopted a 5th-grade target specifically for CCR content. The reading-level standard applies to both the English source and any translated versions, which means utilities should draft the English source at the target reading level first rather than translating from a complex source and hoping the translation simplifies.
Author: Andy Zhang. Last reviewed: April 18, 2026.
Sources
- 40 CFR §141.153 — Consumer Confidence Reports: content (including §141.153(h)(3)) — accessed 2026-04-18.
- 40 CFR §141.155 — Consumer Confidence Reports: delivery (including §141.155(i) language-assistance plan for systems serving ≥100,000) — accessed 2026-04-18.
- Federal Register, May 24, 2024 — National Primary Drinking Water Regulations: Consumer Confidence Reports, docket EPA-HQ-OW-2022-0260, 89 FR 45980 (regulatory text at 89 FR 46012).
- EPA Consumer Confidence Report Rule landing page.
- US Department of Justice — Title VI of the Civil Rights Act and LEP Guidance for Recipients of Federal Financial Assistance.
- US Access Board — Information and Communication Technology (ICT) Section 508 standards and WCAG 2.1 AA adoption.
- Plain Writing Act of 2010 (Public Law 111-274) — federal plain-language framework.
- Americans with Disabilities Act (ADA) Titles II and III — digital accessibility obligations for state and local government agencies and public accommodations.
- ASTM F2575 and ISO 17100 — professional translation quality standards.