Section 508 Compliance Guide
Section 508 is part of the Rehabilitation Act of 1973, a United States federal law that requires federal agencies to make their information and communications technology (ICT) accessible to people with disabilities. The law applies to all federal agencies, organizations receiving federal funding, and vendors doing business with the federal government.
Background and History
Section 508 was added to the Rehabilitation Act through amendments in 1986 and was strengthened significantly by the Workforce Investment Act of 1998. The U.S. Access Board, an independent federal agency, is responsible for developing and maintaining the technical standards.
The 2018 Refresh
On January 18, 2017, the U.S. Access Board issued a final rule updating the Section 508 Standards and Section 255 Guidelines. This rule went into effect on January 18, 2018, and is commonly referred to as the "Section 508 Refresh."
The refresh made several important changes:
- Adopted WCAG 2.0 Level AA as the technical standard for web and non-web electronic content.
- Harmonized requirements with international standards, including the European standard EN 301 549 and the W3C Web Content Accessibility Guidelines.
- Reorganized the standards to be technology-neutral, focusing on functional requirements rather than specific technologies.
- Expanded scope to apply equally to web content, electronic documents, and software applications.
Technical Requirements
WCAG 2.0 Level AA
The revised Section 508 Standards incorporate by reference the WCAG 2.0 Level A and Level AA Success Criteria. This means that federal ICT must conform to all 38 applicable WCAG 2.0 success criteria.
A page or document that fails to meet even one of the 38 applicable WCAG success criteria does not conform to the Section 508 Standards.
Scope of Application
The WCAG 2.0 Level AA requirements apply broadly to:
| Content Type | Requirement |
|---|---|
| Web pages | Must conform to WCAG 2.0 Level AA |
| Electronic documents (PDF, Word, etc.) | Must conform to WCAG 2.0 Level AA (substituting "document" for "web page") |
| Software applications | Must conform to WCAG 2.0 Level AA (substituting "software" for "web page") |
| Native mobile applications | Must conform to WCAG 2.0 Level AA |
Four Exceptions
The Section 508 Standards include four narrow exceptions to WCAG conformance:
- Non-web documents not accessed via ICT (e.g., a file stored on a shared drive that no one opens)
- Legacy ICT that conformed to the original 508 standards and has not been altered
- Content that is part of maintenance or monitoring and is not accessed by the public
- Archived content that has been designated as such and is not updated
Who Must Comply
Federal Agencies
All U.S. federal agencies must ensure their ICT conforms to Section 508 Standards. This includes:
- Public-facing websites and web applications
- Internal employee-facing systems (intranets, HR systems, collaboration tools)
- Electronic documents (PDFs, presentations, spreadsheets)
- Software applications and mobile apps
- Multimedia content (videos, audio, interactive media)
Federal Contractors and Vendors
Organizations that develop, procure, maintain, or use ICT on behalf of a federal agency must comply with Section 508. This includes:
- Government contractors and subcontractors
- Technology vendors selling to federal agencies
- Service providers managing federal IT systems
Organizations Receiving Federal Funding
Entities that receive federal financial assistance may also be required to meet Section 508 Standards. This includes:
- Universities and educational institutions
- State and local agencies receiving federal grants
- Healthcare organizations receiving federal funding
- Non-profit organizations with federal contracts
Procurement and VPATs
Voluntary Product Accessibility Template (VPAT)
When federal agencies procure ICT products and services, they require vendors to provide a Voluntary Product Accessibility Template (VPAT). The VPAT documents how a product or service conforms to the Section 508 Standards.
The VPAT has been updated to the Accessibility Conformance Report (ACR) format, which includes three editions:
- WCAG Edition — For products evaluated against WCAG criteria
- Section 508 Edition — For products evaluated against the revised Section 508 Standards
- EU Edition — For products evaluated against EN 301 549
Importance for Vendors
Federal procurement decisions increasingly consider accessibility. A well-documented VPAT/ACR can be a competitive advantage when selling to government agencies. Products with incomplete or inaccurate accessibility documentation may be excluded from procurement consideration.
Enforcement
Agency Responsibilities
Each federal agency is responsible for ensuring compliance with Section 508. Agencies must:
- Establish policies and procedures for ICT accessibility
- Test ICT products and services for conformance
- Provide accessibility training to employees
- Report on Section 508 compliance to the Office of Management and Budget (OMB)
Complaint Process
Individuals who encounter inaccessible ICT at a federal agency can file a complaint with that agency. If the agency does not resolve the complaint, the individual may file a complaint with the DOJ or pursue legal action.
Assessment and Reporting
The General Services Administration (GSA) conducts government-wide assessments of Section 508 compliance. These assessments evaluate how well agencies are implementing accessibility requirements and report findings to Congress.
Section 508 vs. WCAG 2.1
While Section 508 currently incorporates WCAG 2.0 Level AA, many organizations choose to target the newer WCAG 2.1 Level AA standard for several reasons:
| Aspect | Section 508 (Current) | WCAG 2.1 AA |
|---|---|---|
| Standard | WCAG 2.0 Level AA | WCAG 2.1 Level AA |
| Success Criteria | 38 criteria | 50 criteria |
| Mobile Support | Limited | Enhanced mobile and touch criteria |
| Cognitive Accessibility | Basic | Improved cognitive and learning criteria |
| Low Vision | Basic | Additional low vision support criteria |
WCAG 2.1 is backward compatible with WCAG 2.0, meaning that conformance with WCAG 2.1 Level AA also satisfies the Section 508 WCAG 2.0 requirement.
How WCAG Pulse Helps with Section 508 Compliance
WCAG Pulse provides automated accessibility testing that supports Section 508 compliance efforts:
- Scan against WCAG 2.0, 2.1, and 2.2 — Test your ICT against the required standard and newer versions.
- Generate compliance reports — Document your conformance status with detailed reports that map issues to specific WCAG success criteria.
- Monitor ongoing compliance — Schedule regular scans to detect accessibility regressions as content changes.
- Export CSV data — Provide compliance data for internal reporting and procurement documentation.
- Track remediation progress — Monitor issue resolution over time with scan history and trend analysis.
Automated testing can detect approximately 30-40% of WCAG success criteria violations. For comprehensive Section 508 compliance, supplement automated scanning with manual expert audits, assistive technology testing, and document accessibility reviews.