Section 508: Federal ICT Accessibility

Federal Law Since 1998

Section 508 of the Rehabilitation Act requires federal agencies to make their information and communications technology (ICT) accessible to people with disabilities.

What is Section 508?

Section 508 is a federal law that requires U.S. federal agencies to make their electronic and information technology (EIT) accessible to people with disabilities. Originally enacted in 1998 and significantly updated in 2017, Section 508 ensures that federal employees and members of the public with disabilities have equal access to information and data.

The 2017 "Refresh" aligned Section 508 with WCAG 2.0 Level AA, and federal agencies are now incorporating WCAG 2.1 and 2.2 requirements as best practices.

Who Must Comply?

Federal Agencies
  • All executive branch agencies
  • Independent agencies
  • U.S. Postal Service
  • Government corporations
  • Legislative branch (Congress)
  • Judicial branch (Courts)
Federal Contractors
  • Technology vendors selling to government
  • Software developers
  • Web design firms
  • Content management system providers
  • Hardware manufacturers
  • Document conversion services

What's Covered (ICT)

Section 508 applies to all "Information and Communications Technology" (ICT), including:

Web Content
  • Websites and web applications
  • Intranets and internal portals
  • Online forms
  • Electronic documents (PDFs, Word)
Software
  • Desktop applications
  • Mobile applications
  • Operating systems
  • Development tools
Hardware
  • Computers and peripherals
  • Kiosks and self-service machines
  • Telecommunications equipment
  • Multifunction devices

Technical Standards (Revised 508 Standards)

The 2017 Refresh established technical requirements organized into chapters:

Web content must conform to WCAG 2.0 Level A and Level AA success criteria. This includes websites, web applications, and electronic documents.

Key requirements:

  • All WCAG 2.0 Level A criteria (25 success criteria)
  • All WCAG 2.0 Level AA criteria (13 success criteria)
  • Agencies encouraged to also meet WCAG 2.1/2.2 criteria

When technical requirements don't apply or are insufficient, ICT must meet functional performance criteria:

  • 302.1 Without Vision
  • 302.2 With Limited Vision
  • 302.3 Without Perception of Color
  • 302.4 Without Hearing
  • 302.5 With Limited Hearing
  • 302.6 Without Speech
  • 302.7 With Limited Manipulation
  • 302.8 With Limited Reach and Strength
  • 302.9 With Limited Language, Cognitive, and Learning Abilities

Software (including mobile apps) must meet requirements for:

  • Interoperability with assistive technology
  • Platform accessibility features
  • User preferences (colors, contrast, fonts)
  • Keyboard accessibility
  • Timing and focus management

Hardware with user interfaces must meet requirements for:

  • Operable controls (buttons, keys)
  • Status indicators
  • Biometrics alternatives
  • Physical connections and cables
  • Display screens

Procurement Requirements (FAR)

The Federal Acquisition Regulation (FAR) requires agencies to:

Before Purchasing ICT
  1. Determine applicable standards - Identify which Section 508 requirements apply
  2. Conduct market research - Identify products that meet accessibility requirements
  3. Include requirements in solicitations - Add Section 508 compliance language to RFPs/RFQs
  4. Require VPATs/ACRs - Request Voluntary Product Accessibility Templates from vendors
  5. Evaluate accessibility - Include accessibility as an evaluation factor
Vendor VPAT Requirement

Federal agencies are required to obtain and evaluate Accessibility Conformance Reports (ACRs) or VPATs from vendors before procurement. Vendors selling to the federal government should have current VPATs for all products.

Key Agencies and Resources

U.S. Access Board

Develops and maintains the Section 508 Standards (36 CFR Part 1194)

access-board.gov
GSA Section508.gov

Provides guidance, training, and resources for federal agencies

section508.gov

Enforcement and Complaints

Section 508 enforcement mechanisms include:

  • Internal agency grievance procedures - Federal employees can file internal complaints
  • Civil Rights complaints - Complaints to agency civil rights offices
  • Administrative complaints - Filing with agency Section 508 Coordinators
  • OMB oversight - Agencies report Section 508 compliance to OMB
Potential Consequences
  • Procurement challenges and delays
  • Contract termination for non-compliant vendors
  • Fines up to $55,000 (first violation) / $110,000 (subsequent)
  • Negative audit findings
  • Loss of federal contracts

VPAT (Voluntary Product Accessibility Template)

A VPAT is a document that vendors use to describe how their product conforms to Section 508 standards. The completed VPAT becomes an Accessibility Conformance Report (ACR).

VPAT Sections
  • WCAG 2.x Report - Web content conformance
  • Revised Section 508 Report - Federal requirements conformance
  • EN 301 549 Report - European accessibility standard (optional)

VPATs are available from the Information Technology Industry Council (ITI).

Quick Facts
Law
Rehabilitation Act of 1973, Section 508
Last Updated
January 2017 ("Refresh")
Technical Standard
WCAG 2.0 Level AA
Applies To
Federal agencies and contractors
Standards Body
U.S. Access Board
Guidance
GSA Section508.gov
For Vendors

Selling to the federal government? Learn about VPAT requirements and accessibility conformance.

Vendor Guidance
Related Topics