Letters sent this month by Civil Rights Bureau Chief Kristen Clarke to the counties' election commissioners note the Voting Rights Act requires jurisdictions with significant numbers of Puerto Rican residents with limited English to ensure they can vote.
Measures include making all voting materials and ballots available in Spanish and having Spanish-language interpreters available at polling places.
The letter notes that counties without effective plans could face civil liability. Several lacked Spanish translations on their websites.
In addition to Erie and Chautauqua, the other counties are Monroe, Rockland, Dutchess, Ulster, Schenectady, Sullivan, Montgomery and Putnam.