A complete guide to Section 508 compliance

Section 508 requires US federal agencies to make covered information and communication technology (ICT) accessible to people with disabilities. Its requirements affect websites, software, electronic content, hardware, and other technology that agencies develop, procure, maintain, or use. This guide explains who Section 508 applies to, what the standards require, how WCAG fits in, and how organisations can work towards and maintain compliance.

What is Section 508 compliance?

Section 508 is part of the Rehabilitation Act of 1973. It requires federal agencies to ensure that people with disabilities can access and use covered ICT, including federal employees and members of the public using federal information or services.

The law applies when federal agencies develop, procure, maintain, or use ICT. The technical requirements are set out in the Revised Section 508 Standards developed by the US Access Board. Section 508 compliance monitoring can help organisations identify supported accessibility issues on websites and track results as content changes.

Federal agencies have been required to comply with the revised standards since 18 January 2018. Automated monitoring can support this work, alongside appropriate manual evaluation for accessibility requirements that cannot be determined automatically.

Who needs to comply with Section 508?

Section 508 applies directly to US federal departments and agencies, including the United States Postal Service. It covers ICT that those agencies develop, procure, maintain, or use.

Private businesses are not automatically subject to Section 508 simply because they operate in the United States. Section508.gov confirms that Section 508 applies to federal agencies, although other accessibility laws may apply to private businesses depending on their activities and circumstances.

Companies that supply technology to the federal government can still encounter Section 508 requirements through federal procurement. Vendors offering ICT products or services to federal agencies may need to provide information showing how their products meet applicable accessibility requirements.

This makes Section 508 relevant to software providers, contractors, technology vendors, and other organisations seeking federal business, even though responsibility for complying with Section 508 ultimately sits with the federal agency.

What technology does Section 508 cover?

Section 508 applies to information and communication technology (ICT), including websites, software, electronic content, hardware, and other technology. The Revised Section 508 Standards contain requirements for ICT developed, procured, maintained, or used by federal agencies. Covered ICT can include:

• Websites and web applications.
• Software and mobile applications.
• Electronic documents and other digital content.
• Computers and other hardware.
• Telecommunications equipment.
• Information kiosks and transaction machines.
• Support documentation and services.

For web content specifically, Section 508 can apply to federal public-facing websites as well as extranets and internal websites such as intranets. Certain electronic content used for official agency communications is also covered by the Revised Section 508 Standards.

The requirements that apply depend on the technology and its functionality, so identifying the ICT in scope is an important first step when evaluating Section 508 compliance.

How does Section 508 apply to electronic documents?

Electronic documents can fall within Section 508 when they meet the conditions for covered electronic content. This can include documents such as PDFs, word-processing files, presentations, and spreadsheets used for official agency communications.

Accessibility requirements vary with the document and its content. Depending on the format, accessible documents may need appropriate headings and structure, meaningful reading order, text alternatives for informative images, sufficient colour contrast, accessible tables, and properly labelled form fields.

The Revised Section 508 Standards also contain exceptions for certain electronic content. For example, some records maintained by the National Archives and Records Administration and certain archived web content may be exempt when the conditions set out in the standards are met.

Document accessibility therefore needs to be assessed according to both the content and the applicable Section 508 provisions. A website meeting its relevant requirements does not establish that documents made available through that website are also accessible.

What is the difference between Section 508 and WCAG?

Section 508 and WCAG are closely connected, but they serve different purposes. Section 508 is a US federal law. It establishes accessibility obligations for ICT developed, procured, maintained, or used by federal agencies. WCAG is a technical accessibility standard. It provides testable success criteria for making web content more accessible to people with disabilities.

The Revised Section 508 Standards incorporate WCAG 2.0 Level A and Level AA success criteria and conformance requirements for covered web content. Many of these requirements are also applied to non-web electronic documents and software.

This distinction is particularly important because newer WCAG versions now exist. WCAG 2.1 and WCAG 2.2 contain additional success criteria, but they have not replaced WCAG 2.0 within the current Section 508 Standards.

Federal agencies and other organisations can choose to apply newer WCAG criteria as accessibility best practice, but those additional criteria should not be presented as though they are currently incorporated into Section 508.

How can you work towards Section 508 compliance?

Working towards Section 508 compliance starts with determining which ICT and requirements are in scope. The process will vary according to whether an organisation is assessing a website, software product, electronic document, hardware, or another type of ICT.

A useful process is to:

1. Identify the ICT in scope. Determine which websites, applications, documents, software, hardware, or other technologies need to be assessed.
2. Establish the applicable requirements. Map the ICT to the relevant provisions of the Revised Section 508 Standards.
3. Evaluate current accessibility. Use appropriate automated, manual, and assistive technology testing to identify accessibility problems.
4. Prioritise remediation. Address findings according to the applicable requirements and their effect on users.
5. Retest corrected issues. Confirm that remediation has resolved the identified barrier without introducing new accessibility problems.
6. Document the results. Maintain appropriate records of testing, findings, remediation, and any relevant exceptions.
7. Plan for future changes. Include accessibility in development, content, procurement, and maintenance processes.

For vendors, this process may also include documenting how an ICT product or service meets applicable requirements so federal customers can evaluate it during procurement.

Section 508 compliance is therefore connected to the wider ICT lifecycle. Accessibility decisions made during procurement, design, development, and content creation can affect how much remediation is required later.

How do you test for Section 508 compliance?

Section 508 testing should evaluate the requirements applicable to the ICT being assessed. For a federal website, this includes testing against the relevant Revised Section 508 Standards and incorporated WCAG 2.0 Level A and AA requirements.

Automated accessibility testing can identify supported problems efficiently across large amounts of web content. Welcoming Web can scan websites for supported accessibility issues and provide information that helps teams investigate detected findings.

Manual testing is also needed because some accessibility requirements depend on interaction or human judgement. Keyboard operation, focus behaviour, meaningful content structure, form instructions, and the behaviour of interactive components are examples that may require manual evaluation.

Assistive technology testing provides additional information about how ICT works for people who use technologies such as screen readers or magnification software. The appropriate technologies and test scenarios should reflect the ICT and its expected users.

Federal teams can also use the ICT Testing Baseline for Web, which provides baseline tests for evaluating web content against the Revised Section 508 Standards. The baseline is intended to improve testing consistency, but it does not prescribe a complete testing process.

What are the Section 508 requirements for federal procurement?

Accessibility should be considered before a federal agency purchases ICT. Federal procurement guidance instructs agencies to determine whether Section 508 applies, identify the relevant standards, and include appropriate accessibility requirements when procuring covered technology.

Agencies can request accessibility information from vendors when evaluating software, hardware, electronic content, support documentation, and related services. The evidence requested will depend on the ICT and procurement.

Vendors commonly document accessibility using an Accessibility Conformance Report (ACR). An ACR records how an ICT product or service conforms to specified accessibility criteria and can be created using a Voluntary Product Accessibility Template (VPAT).

The terms ACR and VPAT are sometimes used interchangeably, but they refer to different things. The VPAT is the template, while the ACR is the completed report describing the accessibility of the product or service.

An ACR does not transfer responsibility for Section 508 compliance from the federal agency to the vendor. Federal agencies remain responsible for ensuring that the ICT they procure meets applicable Section 508 requirements.

Are there exceptions to Section 508 requirements?

The Revised Section 508 Standards contain specific exceptions, so agencies should determine whether an exception applies when establishing the requirements for particular ICT.

Examples include circumstances involving national security systems, certain legacy ICT, ICT that is incidental to a contract, and specified functions located in maintenance or monitoring spaces. Section 508 also addresses situations where conformance would impose an undue burden or cause a fundamental alteration.

An exception does not necessarily remove every accessibility responsibility associated with the information or service. For example, where conforming to the applicable standards would impose an undue burden, Section 508 requires the agency to provide the information and data to people with disabilities through an alternative means of access. Agencies must also document an undue burden determination as required by the applicable rules.

How can organisations maintain Section 508 compliance?

Accessibility needs to remain part of ICT management after the initial evaluation. Websites, applications, documents, and other technologies can change through new content, software releases, redesigns, updates, and procurement decisions.

Responsibilities can be incorporated across acquisition, product management, development, content creation, and quality assurance. This helps accessibility requirements enter the process before inaccessible technology or content reaches employees or the public.

For websites, ongoing monitoring can help identify supported accessibility issues introduced through new pages and content updates. Welcoming Web can run recurring scans and retain scan history, helping teams follow detected accessibility results over time.

Periodic manual evaluation remains necessary for requirements automated tools cannot assess. Organisations can also maintain records of testing, remediation, exceptions, procurement evidence, and other relevant accessibility information to support future reviews.

Build Section 508 accessibility into your processes

Section 508 affects accessibility throughout the federal ICT lifecycle, from procurement and development to maintenance and ongoing use. Identifying the applicable requirements early gives agencies and their suppliers an opportunity to address accessibility before technology reaches employees or the public.

Testing should reflect the ICT being assessed and use the methods needed to evaluate its applicable requirements. Accessibility can then remain part of procurement, development, content management, and future updates as the technology evolves.

Run a free accessibility scan with Welcoming Web today to identify supported accessibility issues on your website.