Section 508 Compliance: Your Questions Answered
Section 508 compliance requires federal agencies to make all information and communication technology (ICT) accessible to people with disabilities under 29 U.S.C. § 794d. The current standard incorporates the Web Content Accessibility Guidelines (WCAG) 2.0 Level AA.
Section 508 is an amendment to the Rehabilitation Act of 1973 that directly covers federal agencies and indirectly impacts organizations that sell digital products or services to the federal government.
Key insights
- Section 508 requires federal agencies to ensure that all ICT is accessible to people with disabilities.
- The U.S. Access Board sets the technical accessibility standards referenced in Section 508.
- Vendors selling ICT to federal agencies must demonstrate accessibility conformance, typically through a Voluntary Product Accessibility Template (VPAT) or accessibility conformance report (ACR).
- The GSA FY24 assessment found that only 23% of top federal websites fully conform to Section 508 standards.
- Non-compliance carries legal risk, including private lawsuits such as the Orozco v. Garland (2023) ruling.
- Organizations should aim for WCAG 2.2 Level AA to stay ahead of regulatory changes.
What is Section 508?
Section 508 is an amendment to the Rehabilitation Act of 1973 requiring federal agencies to ensure their electronic and information technology is accessible to people with disabilities.
Congress enacted Section 508 in 1998 to ensure federal employees and members of the public with disabilities have equal access to digital information and services.
The U.S. Access Board develops accessibility standards for information and communication technology, while the General Services Administration (GSA) provides guidance and reports federal compliance to Congress.
Section 508 applies whenever federal agencies develop, procure, maintain, or use ICT systems.
Which digital assets must meet Section 508 standards?
Section 508 standards apply to all electronic and information technology used by federal agencies.
- Public websites and web applications
- Electronic documents such as PDFs, Word files, spreadsheets, and presentations
- Software applications and mobile apps
- Email communications
- Online training and e-learning platforms
- Employment application systems
- Multimedia including video and audio
- Hardware interfaces and kiosks
Any digital content created, procured, maintained, or used by federal agencies must conform to Section 508 accessibility standards.
Which organizations must comply with Section 508?
Section 508 directly applies to federal government agencies as defined in 29 U.S.C. § 794d.
The law also indirectly affects vendors that develop or sell ICT products and services to the federal government. Federal agencies require vendors to demonstrate accessibility conformance during procurement.
This is typically documented using a completed VPAT or accessibility conformance report.
Related accessibility regulations
- State and local governments must comply with new accessibility rules under ADA Title II requiring WCAG 2.1 Level AA by April 24, 2026.
- Healthcare organizations receiving federal funding must comply with Section 504 accessibility requirements by May 11, 2026.
Organizations working with multiple government sectors should aim for WCAG 2.1 or WCAG 2.2 Level AA to meet overlapping regulatory requirements.
What are the Section 508 compliance requirements?
The U.S. Access Board integrated WCAG 2.0 Level A and AA success criteria into the revised Section 508 standards in 2017, which took effect in January 2018.
Current technical standard
Federal ICT must conform to WCAG 2.0 Level AA, which includes accessibility requirements organized around four principles:
- Perceivable: Content must be presented in ways users can perceive.
- Operable: Interface components must be operable using assistive technologies.
- Understandable: Information and navigation must be clear and predictable.
- Robust: Content must work with assistive technologies such as screen readers.
WCAG evolution
- WCAG 2.1 added 12 success criteria addressing mobile accessibility and cognitive disabilities.
- WCAG 2.2 added additional success criteria improving usability for touch interfaces and authentication processes.
Organizations are encouraged to target WCAG 2.2 Level AA to ensure future compliance readiness.
Core compliance obligations
Procurement requirements
Federal agencies must include Section 508 requirements in all ICT procurement solicitations.
Equal access
Individuals with disabilities must have comparable access to information and services as users without disabilities.
Testing and validation
Accessibility testing must include both automated tools and manual testing using assistive technologies.
Training
Federal agencies must train staff involved in technology development, procurement, and content creation on accessibility requirements.
Compliance reporting
Federal agencies report Section 508 compliance through the annual GSA government-wide accessibility assessment.
How does Section 508 differ from the ADA?
Section 508 and the Americans with Disabilities Act (ADA) both require digital accessibility but apply to different sectors.
Section 508
- Applies to federal agencies and federal procurement
- Current technical standard: WCAG 2.0 Level AA
ADA Title II
- Applies to state and local governments
- Requires WCAG 2.1 Level AA
ADA Title III
- Applies to private businesses open to the public
- Courts frequently reference WCAG 2.0 or 2.1 AA
Because WCAG standards are backward compatible, organizations often adopt WCAG 2.1 or 2.2 to satisfy multiple regulations simultaneously.
What is a VPAT and accessibility conformance report?
A Voluntary Product Accessibility Template (VPAT) is a document used to describe how well a product conforms to accessibility standards including Section 508.
A completed VPAT is called an accessibility conformance report (ACR).
VPAT purpose
- Identify which accessibility criteria a product meets
- Explain partial conformance or limitations
- Describe remediation plans for accessibility gaps
Federal agencies review VPAT reports during procurement to evaluate accessibility compliance.
Transition to OpenACR
Traditional VPATs are static documents. OpenACR introduces machine-readable accessibility reports that allow automated comparison of vendor accessibility claims.
The GSA has released an OpenACR editor to help vendors create standardized accessibility conformance reports.
How to create a Section 508 compliant document
Structure and navigation
Use proper heading hierarchy to allow screen readers to navigate documents effectively.
Alternative text
Provide descriptive alt text for all images and visual elements.
Reading order
Ensure documents follow a logical reading sequence so assistive technologies present content correctly.
Form accessibility
Label form fields clearly and ensure they are accessible via keyboard navigation.
Color contrast
Maintain sufficient color contrast and avoid relying solely on color to convey meaning.
Accessible links
Use descriptive link text rather than generic phrases like “click here.”
HTML-first strategy
The General Services Administration recommends publishing content as HTML pages rather than PDFs whenever possible.
HTML content is easier to maintain, works better with assistive technologies, and supports responsive design.
What are the risks of Section 508 non-compliance?
Legal exposure
Private lawsuits and administrative complaints may arise when accessibility barriers prevent users with disabilities from accessing federal digital services.
Procurement consequences
Contractors that fail to meet Section 508 requirements may face contract termination or exclusion from future federal contracts.
Section 508 compliance tips
- Ensure full keyboard accessibility for all interactive elements.
- Make all controls clearly visible with focus indicators.
- Provide alt text for images and visual content.
- Maintain sufficient color contrast.
- Use semantic markup and structured headings.
- Test with assistive technologies such as screen readers.
- Provide accessibility training for staff.
- Include accessibility requirements in procurement processes.
Summary
Section 508 compliance ensures that federal information and communication technology remains accessible to people with disabilities.
Federal agencies must meet WCAG 2.0 Level AA requirements, and vendors working with federal agencies must demonstrate accessibility conformance through VPAT reports.
Accessibility should be integrated into development, procurement, and training processes to maintain long-term compliance.