All about Section 508 Guide: Federal ICT Accessibility Compliance

Section 508 is a key digital accessibility law for federal agencies. It requires government technology to be accessible to people with disabilities. This applies to technology that agencies create, buy, maintain, or use. Developers, procurement teams, content creators, and vendors should understand these requirements. Knowing Section 508 helps organizations meet legal obligations and support equal access.

4 Most Important Takeaways

WCAG 2.0 AA Is the Minimum Requirement

Section 508 requires WCAG 2.0 Level AA compliance. Many experts recommend following WCAG 2.1 or 2.2 AA instead. These newer versions improve accessibility for mobile users. They also support people with cognitive and motor disabilities better. Following newer standards can help prepare for future regulations.

Section 508 Affects More Than Federal Agencies

Section 508 applies beyond federal government organizations. Contractors and subcontractors must also meet accessibility requirements. Software vendors serving federal agencies are affected as well. Basically, organizations receiving federal funds must comply with Section 504 of the Rehabilitation Act. It mandates digital and physical accessibility, and often leads to adopting similar technical standards.

Automated + Manual Accessibility Testing (Including Users with Disabilities) Is the Way Forward

Automated tools help identify common accessibility problems quickly. However, they cannot detect every accessibility issue. Screen readers and keyboard navigation require manual testing. Human testing can uncover problems with content flow and usability. Real users provide valuable feedback that tools cannot replace.

Accessibility Should Be Planned Early

Accessibility works best when included from the beginning. Requirements should be part of procurement and development processes. Content creation workflows should also include accessibility checks. Early planning reduces remediation costs and project risks. Organizations that delay accessibility often face greater challenges later.

Fundamentals of Section 508

What is Section 508 and what problem does it solve?

Section 508 is a US federal accessibility law. It requires accessible information and communication technology for people with disabilities. The law covers technology developed, procured, maintained, or used by federal agencies.
The core problem it solves is that of digital exclusion of disabled employees and public users. Therefore, Section 508 promotes equal access to federal digital services and tools.

How did the 2017 “Section 508 Refresh” change the standards?

The 2017 Section 508 Refresh modernized outdated technical standards. It aligned federal accessibility requirements with WCAG 2.0 Level A and AA success criteria.

The Refresh applied WCAG 2.0 standards to both web and non‑web electronic content.
It introduced clear scoping for documents, software, hardware, and authoring tools.

Besides, it also updated functional performance criteria for a broader disability range. The revised standards took legal effect in January 2018 for US federal agencies.

What does “accessible ICT” mean under Section 508?

Under Section 508, accessible ICT (Information and Communication Technology) refers to technology that can be used by people with disabilities in a way that provides access comparable to that of people without disabilities. This requirement applies to technology that federal agencies develop, purchase, maintain, or use.

What Types of ICT Must Be Accessible?

Under Section 508, a wide range of digital and electronic technologies must be accessible for people with disabilities.

• Websites and digital content
  Websites and digital content must work with assistive technologies like screen readers and keyboard navigation.
• Software and applications
  Software and applications should support keyboard-only use. They should allow adjustments like text size, zoom, and contrast settings.
• Hardware and interactive devices
  hardware and interactive devices must include accessible controls and usable interfaces for all users.
• Support and training materials
  Support and training materials must be provided in accessible formats.

Why It Matters

Section 508 requires federal agencies and ICT vendors to provide equal access to electronic information and communications. Accessibility is expected unless providing it would create an undue burden.

What are the four WCAG principles and how do they support Section 508?

The four WCAG (Web Content Accessibility Guidelines) principles are known as POUR. They provide the foundation for making digital content accessible to people with different disabilities.

1. Perceivable

Users must be able to access and understand information through their senses. This includes providing text alternatives for images, captions for videos, and content that is easy to see and read.

2. Operable

All users should be able to navigate and interact with a website or application. This means content should work with keyboards, voice controls, and other assistive technologies.

3. Understandable

Content and navigation should be clear, consistent, and easy to follow. Users should be able to understand information and predict how the interface will behave.

4. Robust

Digital content should be built using reliable coding practices. This allows it to remain compatible with current and future assistive technologies, such as screen readers.

How These Principles Support Section 508

• Providing the foundation for the WCAG 2.0 Level AA requirements referenced by Section 508.
• Helping ensure equal access for people with visual, hearing, motor, and cognitive disabilities.
• Supporting long-term accessibility through coding practices that work with evolving browsers and assistive technologies.

Who and What Must Comply to Section 508

Which organizations are directly obligated to comply with Section 508? Which entities are indirectly affected through contracts, grants, or funding relationships?

Section 508 is a federal law that requires information and communication technology (ICT) used by the U.S. government to be accessible to people with disabilities. Some organizations must comply directly. Others are affected through their relationship with the federal government.

Organizations Directly Obligated to Comply

• Executive Branch departments and agencies
• Independent federal agencies
• The U.S. Postal Service
• Certain legislative and judicial branch entities

Organizations Indirectly Affected by Section 508

Many non-federal organizations are also impacted. This is because they work with or receive support from the federal government.

Contractors, Vendors, and Suppliers

• Software and SaaS providers
• Web development companies
• Hardware manufacturers
• IT consultants and service providers

Accessibility responsibilities can also extend to subcontractors and suppliers involved in delivering a larger solution. To demonstrate compliance, organizations are often asked to provide documents such as a VPAT or Accessibility Conformance Report (ACR). Organizations can hire VPAT services to build credible, audit-ready accessibility documentation.

Section 504 Compliance for Organizations Receiving Federal Funding

Organizations that receive federal grants or other federal financial assistance must comply with Section 504 of the Rehabilitation Act. This law requires both digital and physical accessibility for people with disabilities.

In practice, Section 504 compliance often leads these organizations to adopt similar technical standards used in Section 508, especially for websites, documents, and digital services.

• Colleges and universities
• Nonprofit organizations
• Hospitals and medical centers

When does Section 508 apply to vendors, contractors, and third‑party providers selling ICT products or services to federal agencies?

Section 508 applies when vendors, contractors, and service providers supply ICT to federal agencies. If a product or service is used by a federal agency, accessibility requirements may apply.

1. Direct Sales to Federal Agencies

• Hardware such as computers, servers, and kiosks
• Software and operating systems
• Websites, web applications, and digital services
• Electronic content, including PDFs and training materials
• User documentation and technical support services

2. Federal Contract Requirements

Section 508 requirements are embedded in federal purchasing rules through the Federal Acquisition Regulation (FAR).

To compete for federal contracts, vendors are asked to submit a VPAT (Voluntary Product Accessibility Template) as part of the RFP process.

The VPAT is used as the framework to create an Accessibility Conformance Report (ACR). ACR documents how the product or service conforms to accessibility standards. In practice, organizations submit a completed ACR built using the VPAT template.

3. Prime Contractors and Subcontractors

Prime contractors are responsible for the accessibility of all project deliverables.

This responsibility also extends to subcontractors whose products or services are included in the final solution. If a subcontractor's deliverable is not compliant, the prime contractor may face contract risk.

4. Services Provided on Behalf of an Agency

Section 508 also applies when third-party providers host, manage, or maintain government digital services.

If federal employees or the public use those services, they must remain accessible regardless of where they are hosted.

5. Limited Exceptions

In specific situations, federal agencies may approve documented exceptions. Examples include undue burden claims or certain national security systems. When a valid exception applies, accessibility requirements may be waived for that specific circumstance.

What categories of digital assets must meet Section 508 standards?

Section 508 requires federal agencies to ensure accessible electronic and information technology. Any digital asset used to provide information or services may fall under these requirements.

Websites and Web Applications - Public and Internal Web Platforms

• Public websites
• Intranet sites
• Browser-based applications

Electronic Documents- Digital Files and Records

• PDF files
• Microsoft Word documents
• Excel spreadsheets
• PowerPoint presentations

Software and Mobile Applications - Desktop and Mobile Technology

• Desktop software
• Operating systems
• Native mobile applications

Multimedia Content - Audio and Video Resources

• Training videos
• Webinars
• Podcasts
• Other synchronized audio and video content

Online Training and E-Learning - Digital Learning Materials

• Online courses
• Training platforms
• Digital educational resources

Communications - Electronic Messaging

• Internal emails
• External emails
• Social media content

Forms and Templates - Data Collection Tools

• Online forms
• Surveys
• Digital templates

You can review the full criteria and requirements on the Section 508 website.

Does Section 508 cover internal-only content?

No, Section 508 applies to both public-facing and internal digital content used by federal agencies. The law requires all information and communication technology (ICT) developed, purchased, maintained, or used by federal agencies to be accessible.

• Intranet websites
• HR and employee portals
• Internal software applications
• Agency email communications
• Employee forms and documents
• Training materials
• Internal policies and procedures

See the Content Scope Guidance for a full breakdown of the kind of internal content that is covered.

How Do the Revised 508 Standards Define Conformance for Electronic Content?

The Revised 508 Standards outline accessibility requirements in Section E205. They require electronic content to meet WCAG 2.0 Level A and AA standards. This applies whether content is accessed online or offline.

Non-Web Software Requirements - Accessibility for Stand-Alone Applications

• Native desktop applications
• Stand-alone software programs
• Non-web user interfaces

The standards apply WCAG accessibility principles to software interfaces, It helps ensure consistent accessibility across platforms.

Non-Web Document Requirements - Accessibility for Electronic Documents

• PDF files
• Word documents
• Spreadsheets

• Text alternatives for non-text content
• Proper document structure and semantics
• Keyboard accessibility

Exceptions for Non-Web Documents - Criteria That Do Not Apply

• Bypass Blocks
• Multiple Ways
• Consistent Navigation
• Consistent Identification

General Exceptions

Accessibility conformance is generally required for covered content. However, exceptions may apply when compliance creates an undue burden or fundamentally changes the technology.

When an approved exception exists, agencies must provide another accessible way to access the information.

Are there specific exceptions under Section 508? How are those exceptions evaluated and documented?

Yes, Section 508 includes several limited exceptions where accessibility requirements may not fully apply. These exceptions are evaluated for specific features or functions rather than entire products.

Types of Section 508 Exceptions

• Undue Burden: An exception may apply when accessibility would create significant difficulty or expense.
• Fundamental Alteration: An exception may be allowed if accessibility would change the technology's core purpose.
• Best Meets: When no fully compliant option exists, agencies must select the most accessible solution available.
• National Security Systems: Certain systems supporting intelligence, cryptographic, or military operations may be exempt.
• Contractor Incidental Use: ICT used only by contractors and not by federal agencies may qualify.
• Maintenance or Monitoring Spaces: Technology located in restricted maintenance or monitoring areas may be exempt.
• Legacy ICT: Existing technology that remains unchanged generally does not require retrofitting. However, new updates or components must comply.

How Are Exceptions Evaluated?

A designated agency official must evaluate the technology before approving an exception. For procurement projects, agencies must first conduct market research. This lets them identify accessible alternatives.

If accessibility barriers remain, agencies must create an Alternative Means Plan. This plan explains how people with disabilities will access the information or service.

How Are Exceptions Documented?

• Undue Burden
• Fundamental Alteration
• Best Meets

The documentation must explain:

• The accessibility challenges
• Describe the impact of compliance
• Include approval from the responsible agency official.

Technical Standards and Requirements

Which WCAG 2.0 Level A and AA Success Criteria Are Included in the Revised 508 Standards?

The Revised 508 Standards adopt all WCAG 2.0 Level A and Level AA success criteria as their minimum accessibility benchmark.

These requirements are organized under four core accessibility principles given below.

Perceivable (Making Content Available to Different Users)

Content must be presented in ways users can perceive and understand.

• Text alternatives for non-text content
• Captions for prerecorded and live audio
• Audio descriptions for video content
• Proper content structure and reading order
• Instructions that do not rely only on sensory cues
• Adequate color contrast for text
• Resizable text without losing functionality
• Limited use of images containing text

Operable (Making Content Easy to Navigate and Use)

Users must be able to interact with content using different input methods.

• Full keyboard accessibility
• No keyboard traps
• Adjustable time limits
• Controls for moving or auto-updating content
• Protection against excessive flashing
• Clear page titles and headings
• Logical focus order
• Visible keyboard focus indicators
• Multiple ways to locate content

Understandable (Making Information Clear and Predictable)

Content and functionality should be easy to understand.

• Programmatically identifiable language settings
• Consistent navigation and identification
• Clear labels and instructions
• Error identification and correction guidance
• Protections for legal, financial, and data submissions

Robust (Supporting Assistive Technologies)

Content must work reliably with current and future assistive technologies.

• Properly structured markup
• Programmatically identifiable names, roles, states, and values for interface components

Why is targeting WCAG 2.1 or 2.2 AA considered a forward‑looking strategy for agencies and vendors?

Many agencies and vendors choose WCAG 2.1 or 2.2 AA to prepare for future accessibility expectations. WCAG follows a backward-compatible model. So, newer versions include requirements from earlier versions while adding new accessibility improvements.

Here’s why targeting WCAG 2.1 or 2.2 AA is regarded as forward looking for agencies and vendors.

Regulatory Future-Proofing

Accessibility regulations often take years to update after new guidelines are released. WCAG 2.1 expanded on WCAG 2.0. WCAG 2.2 added further requirements.

Organizations that adopt WCAG 2.2 AA today are better positioned for future regulatory changes.

Moreover, WCAG 2.2 AA includes all WCAG 2.1 requirements plus additional criteria. Meeting WCAG 2.2 AA therefore also satisfies WCAG 2.1 AA requirements.

Reducing Legal and Compliance Risks

Many digital accessibility disputes reference WCAG requirements. Building to newer standards helps reduce potential compliance gaps. It lowers the need for costly future remediation efforts.

Strengthening Competitive Advantage

Many public sector and enterprise organizations expect strong accessibility conformance from vendors.

Organizations that support WCAG 2.1 or 2.2 AA have higher likelihood for procurement opportunities and accessibility-focused projects.

Improving the User Experience

• Larger touch targets for easier interaction
• Accessibility features that reduce memory-related barriers
• More consistent support across modern digital experiences

How do Section 508 requirements apply to non-web ICT?

Section 508 applies to many types of non-web information and communication technology (ICT). These technologies must be accessible to people with disabilities and work with assistive technologies.

Common requirements include compatibility with screen readers, support for platform accessibility features, and accessible hardware controls.

Desktop Software and Native Mobile Apps

• Compatibility with screen readers
• Keyboard-accessible navigation
• Text alternatives for non-text content
• Support for user settings such as text size and color preferences

These applications are evaluated using accessibility requirements adapted for non-web software environments.

Kiosks and Interactive Transaction Machines

• Tactilely identifiable controls
• Visible focus indicators
• Private listening connections for audio output
• Screen zoom and contrast controls

Telecommunications Systems

• Real-time text (RTT)
• Hearing aid compatibility
• Volume controls
• TTY connectivity

Systems that depend on voice interaction should also provide visual or touch-based alternatives.

Support Documentation

User guides, help resources, and support systems must also be accessible.

They should explain accessibility features and describe compatibility options. They should provide alternate formats when requested.

When Can a Conforming Alternate Version Be Used Under the Revised 508 Standards? What constraints do the Revised 508 Standards impose on this option?

The Revised 508 Standards generally require information and communication technology (ICT) to be directly accessible. A conforming alternate version may be used only when making the original content accessible is not possible due to legal or technical limitations.

In most situations, agencies are expected to make the primary content accessible. Relying on an alternative version is generally avoided.

Requirements for a Conforming Alternate Version

Same Information and Features

The alternate version must provide the same content and functionality as the original version. Users should not lose access to information or features by using the alternate version.

Same Accessibility Level

The alternate version must meet the same accessibility requirements that apply to the original content. For example, if WCAG 2.0 Level AA conformance is required, the alternate version must meet that standard as well.

Easy Access

Users must be able to find and reach the alternate version without difficulty. A clear and direct method for accessing the alternate version should be available from the original content.

Equal Maintenance and Updates

The alternate version must be updated whenever the original content changes. Both versions should remain consistent and available at the same time.

Additional Exceptions

Undue Burden and Fundamental Alteration

An agency may claim an exception if accessibility would create significant difficulty, expense. An exception can also be made if accessibility creates a fundamental change to the technology.

Legacy Content

Certain existing legacy content may qualify for safe harbor provisions. If that content remains unchanged it may not need urgent updates.

Procurement and VPATs

How must federal procurement processes incorporate Section 508 requirements when agencies acquire new ICT products or services?

Federal agencies must include accessibility requirements throughout the entire procurement process. Here’s how.

Acquisition Planning

Define Accessibility Requirements Early

Accessibility requirements should be identified before a solicitation is released. Agencies should determine which accessibility standards apply to the planned purchase.

Identify Applicable Standards

Procurement teams should review the specific technical requirements relevant to the product or service. They should also determine whether any documented exceptions apply.

Solicitation and Vendor Evaluation

Include Accessibility Requirements in Solicitations

Solicitations should clearly state the Section 508 requirements vendors must meet. This ensures accessibility expectations are communicated from the beginning.

Review Vendor Accessibility Documentation

• Accessibility Conformance Reports (ACRs)
• Voluntary Product Accessibility Templates (VPATs)

Evaluate Accessibility During Selection

Accessibility should be considered alongside other evaluation criteria. This helps agencies identify products that meet required standards.

Contract Award and Management

Include Accessibility in Contracts

Accessibility requirements should be written into contracts and task orders. Acceptance criteria should also reflect Section 508 obligations.

Verify Compliance

Contracting officials should confirm that accessibility requirements are included before award.

Handling Exceptions

Document Approved Exceptions

If compliance creates significant difficulty or changes a product's core purpose, an exception may apply. Any approved exception should be formally documented.

Provide Alternative Access

When an exception is granted, agencies should ensure alternative access remains available.

What is a Voluntary Product Accessibility Template (VPAT)? How is it used to produce an Accessibility Conformance Report (ACR) that documents a product’s 508 conformance?

A Voluntary Product Accessibility Template (VPAT) is a standardized reporting framework used by vendors. It helps evaluate how well an Information and Communication Technology (ICT) product meets accessibility requirements.

• Section 508
• WCAG

The VPAT itself is only a reporting framework. It does not contain evaluation results.

VPAT vs. ACR

A VPAT becomes an ACR after the evaluation is completed.

How a VPAT Is Used to Create an ACR

Step 1: Select the Correct VPAT

The vendor begins with the appropriate VPAT edition. For Section 508 evaluations, the Revised Section 508 version is typically used.

Step 2: Evaluate the Product

• Automated testing
• Manual reviews
• Assistive technology testing
• Screen reader testing

Step 3: Complete the Conformance Tables

• Supports: The requirement is fully met.
• Partially Supports: Most requirements are met, but some issues remain.
• Does Not Support: The requirement is not met.
• Not Applicable: The requirement does not apply to the product.
• Not Evaluated: The requirement was not assessed.

Step 4: Add Explanations

• Partially Supports
• Does Not Support

Step 5: Finalize the Report

The completed ACR should include basic administrative details about the product and evaluation. This information helps procurement teams understand the scope and results of the assessment.

Why ACRs Are Important for Section 508 Compliance

Federal agencies use ACRs to review a product's accessibility before purchasing it. The report provides documented evidence of how the product aligns with Section 508 requirements. It also helps agencies compare products and make informed procurement decisions.

What Information Should a Thorough VPAT/ACR Include?

A thorough Accessibility Conformance Report (ACR) should clearly and in detail explain how the product meets accessibility requirements and identify any limitations.

The report should be accurate, transparent, and useful for procurement teams and end users.

Conformance Status Ratings - Standard Conformance Levels

• Supports: The product fully meets the requirement.
• Partially Supports: Some features meet the requirement, while others do not.
• Does Not Support: Most functionality does not meet the requirement.
• Not Applicable: The requirement does not apply to the product.
• Not Evaluated: Used only for certain WCAG Level AAA criteria.

Information Required for Partial Support or Non-Conformance

• Describe the Accessibility Barrier - The report should clearly explain what prevents full compliance. Examples may include missing labels, navigation issues, or compatibility problems.
• Identify Affected Features - The report should specify which pages, functions, or workflows are impacted. This helps buyers understand the scope of the issue.
• Document Available Workarounds - Any alternative method for completing a task should be explained. Workarounds help users continue using the product when limitations exist.
• Note Assistive Technology Impact - The report should explain how accessibility issues affect assistive technologies. It should also mention whether certain tools reduce the impact.

Additional Details a Strong ACR Should Include

• Product Description - A brief overview should explain the product’s purpose and functionality. This provides context for evaluating accessibility findings.
• Testing Methods - The report should describe how accessibility testing was performed. Testing information may include:
  • Automated testing tools
  • Manual accessibility reviews
  • Screen reader testing
  • Keyboard navigation testing
• Remediation Plans - If issues remain, the report should outline planned improvements. A timeline for future fixes proves helpful here.
• Product Version Information - The report should identify the exact version evaluated. Accessibility results may change as the product evolves.

How do agencies evaluate and compare vendor accessibility claims in VPATs during source selection and contract award decisions?

Federal agencies carefully review accessibility claims to confirm that Information and Communication Technology (ICT) meets Section 508 requirements.

Accessibility findings are compared alongside other procurement factors during source selection.

Verifying Accessibility Claims - Review Testing Methods

• Automated testing
• Manual testing
• Assistive technology testing

Reports based only on automated scans may receive closer scrutiny.

Conduct Independent Validation

Agencies may perform their own accessibility reviews to verify vendor claims. Independent testing helps confirm the accuracy of reported conformance levels.

Analyze Conformance Status

• Supports
• Partially Supports
• Does Not Support
• Not Applicable

Examine Remarks and Explanations

Reviewers look beyond ratings and study the supporting explanations. Detailed descriptions help agencies understand the nature of accessibility limitations.

Identify Missing Information

• Blank explanation fields
• Vague statements
• Missing workaround information

Evaluate Workarounds

Agencies review whether users can complete tasks despite known barriers. Effective alternatives can reduce the impact of accessibility limitations.

Consider Issue Severity

• Navigation
• Login processes
• Form submissions

Comparing Vendors During Source Selection

Compare Accessibility Performance

Accessibility results are compared across competing vendors. Agencies consider both current conformance and future improvement plans.

Review Remediation Commitments

Vendors with documented accessibility improvement plans may receive favorable consideration. Clear timelines demonstrate a commitment to addressing known issues.

Consider Contract Requirements

Accessibility obligations may be included in contract terms. Vendors can be required to resolve identified issues within agreed timeframes.