What is Section 508 Compliance? Government Accessibility Requirements

Section 508 is a federal law requiring accessible electronic and information technology (ICT). Unlike the ADA, which courts have interpreted to cover websites, Section 508 explicitly addresses digital accessibility with specific technical standards. If you work with the federal government—as an agency, contractor, or recipient of federal funds—Section 508 compliance isn't optional.

This guide explains what Section 508 requires, who must comply, the technical standards involved, and how organizations achieve and demonstrate compliance.

The Basics of Section 508

Section 508 is part of the Rehabilitation Act of 1973, significantly amended in 1998 to address electronic accessibility, and updated again in 2017 to incorporate modern standards. The law requires federal agencies to make their ICT accessible to employees and members of the public with disabilities.

The core principle is straightforward: people with disabilities should have comparable access to information and services as people without disabilities. When federal agencies develop, procure, maintain, or use ICT, that technology must be accessible unless doing so would impose an "undue burden."

What makes Section 508 distinctive is its specificity. Unlike the ADA, which provides general principles, Section 508 points to detailed technical standards defining what "accessible" means.

Who Must Comply

Federal Agencies

All federal agencies must comply with Section 508. This includes executive branch agencies, independent agencies, and the legislative and judicial branches (with some specific provisions). Agency websites, internal applications, documents, and any ICT used in conducting government business falls under the requirement.

Federal Contractors

Companies that contract with federal agencies to provide ICT—whether products or services—must deliver accessible solutions. This includes software developers, IT service providers, website designers, and companies providing digital products.

The accessibility requirement typically appears in contracts, often referencing Section 508 or WCAG standards. Contractors may be required to provide documentation demonstrating compliance, and contracts may include remediation obligations for accessibility defects.

Recipients of Federal Funding

Organizations receiving federal financial assistance—grants, loans, or other funding—must comply with Section 504 of the Rehabilitation Act, which has been interpreted to include accessibility requirements similar to Section 508. Universities, healthcare organizations, state and local governments, and nonprofits receiving federal funds face these obligations.

Practical Reach

Section 508's practical reach extends beyond direct government relationships. Organizations that want to sell to federal agencies must ensure their products are accessible, creating market pressure that influences product development broadly. Companies that might someday pursue government business often adopt Section 508 compliance proactively.

Technical Standards

The 2017 Refresh

The current Section 508 standards, finalized in 2017, modernized requirements to reflect current technology. Key changes included:

WCAG adoption: Section 508 now incorporates WCAG 2.0 Level AA for web content. Websites and web applications must meet all Level A and Level AA success criteria.

Harmonization: The updated standards align with EN 301 549, the European accessibility standard, reducing conflicts for organizations operating internationally.

Functional performance criteria: Beyond technical standards, Section 508 includes functional requirements ensuring that technology works for people with various disabilities—vision, hearing, mobility, cognition, and speech.

What the Standards Cover

Section 508 addresses multiple categories of ICT:

Web content and applications: Websites, web applications, and content published on the web must meet WCAG 2.0 Level AA.

Software: Native applications and software platforms must be accessible, supporting platform accessibility features and assistive technologies.

Hardware: Physical devices including computers, kiosks, and telecommunication equipment have accessibility requirements.

Documents: Electronic documents, including PDFs, Word documents, and spreadsheets, must be accessible.

Support services: Documentation and support for ICT products must be available in accessible formats.

WCAG 2.0 Level AA

For web content, Section 508 requires conformance to WCAG 2.0 Level AA. This includes 38 success criteria organized under four principles:

Perceivable: Information must be presentable in ways users can perceive—alternative text for images, captions for video, adaptable layouts, and distinguishable colors.

Operable: Users must be able to operate the interface—keyboard accessibility, sufficient time, seizure prevention, and navigability.

Understandable: Content must be understandable—readable text, predictable behavior, and input assistance.

Robust: Content must be robust enough to work with assistive technologies—valid markup and proper naming of components.

Compliance in Practice

Procurement

When federal agencies purchase ICT, they must consider accessibility throughout the procurement process. The Federal Acquisition Regulation (FAR) requires agencies to:

• Include accessibility requirements in solicitations
• Evaluate vendor accessibility claims
• Document exceptions when fully accessible alternatives aren't available
• Award contracts that meet accessibility needs

Vendors respond to these requirements with Voluntary Product Accessibility Templates (VPATs), which document how their products conform to Section 508 standards.

Development

Agencies and contractors developing ICT must build accessibility into the development process. This includes:

• Accessibility requirements in project planning
• Accessible design practices
• Accessibility testing throughout development
• User testing with people with disabilities
• Documentation of accessibility features

Retrofitting accessibility after development is expensive and often incomplete. Organizations that succeed with Section 508 integrate accessibility from the start.

Documentation

Compliance requires documentation demonstrating that ICT meets standards. For vendors, this typically means producing VPATs or Accessibility Conformance Reports (ACRs). For agencies, this includes maintaining records of accessibility evaluations, exception determinations, and remediation efforts.

Documentation serves multiple purposes: demonstrating compliance, informing users about accessibility features and limitations, and providing accountability for ongoing maintenance.

Exceptions and Limitations

Section 508 recognizes that complete accessibility isn't always achievable. Several exceptions exist:

Undue Burden

If compliance would impose "significant difficulty or expense," agencies may claim an undue burden exception. However, this exception requires documented analysis of the specific burden, consideration of alternatives, and approval by the agency head or designated official. It's not a general escape clause.

Fundamental Alteration

If accessibility would fundamentally alter the nature of the product or service, an exception may apply. This rarely applies to standard ICT functions.

National Security

Systems critical to national security may be exempt from certain requirements.

Back Office Systems

Internal systems not accessed by the public or employees with disabilities may have different requirements, though this exception has narrowed over time.

Even when exceptions apply, agencies must provide alternative access methods enabling people with disabilities to use their services.

Enforcement

Agency Responsibility

Each federal agency is responsible for its own Section 508 compliance. Agencies must designate a Section 508 coordinator, establish policies and procedures, and report on compliance status.

Complaint Process

Individuals who encounter accessibility barriers can file complaints with the relevant agency. Agencies must have procedures for addressing complaints and resolving issues.

Oversight

The Access Board develops and maintains Section 508 standards. The General Services Administration (GSA) provides guidance, tools, and resources supporting implementation. The Office of Management and Budget (OMB) oversees government-wide IT policies including accessibility.

Practical Consequences

Non-compliance can result in:

• Failed contract bids (inaccessible products don't meet requirements)
• Contract disputes or termination
• Formal complaints and required remediation
• Reputational damage within government circles
• Employee accommodation issues

Achieving Compliance

Organizations working toward Section 508 compliance typically follow a process:

Assessment: Evaluate current ICT against standards. Identify gaps between current state and requirements.

Prioritization: Not all issues are equally important. Focus first on high-impact barriers affecting critical functionality.

Remediation: Fix identified issues. This may involve code changes, content updates, configuration adjustments, or product replacements.

Documentation: Create or update VPATs and other compliance documentation.

Monitoring: Establish ongoing processes to maintain compliance as ICT changes.

Training: Ensure staff understand accessibility requirements and how to implement them.

The timeline and effort required depend on current accessibility status, the complexity of ICT involved, and available resources.

Taking Action

Section 508 compliance requires sustained attention. For organizations working with the federal government, compliance is a business necessity. For others, Section 508 standards provide a useful benchmark for accessibility even without legal obligation.

Whether you're responding to contract requirements, preparing to pursue government business, or simply seeking clear accessibility standards, understanding Section 508 helps guide effective accessibility programs.

TestParty provides monitoring against WCAG standards referenced by Section 508, helping organizations achieve and maintain compliance.

Schedule a TestParty demo and get a 14-day compliance implementation plan.

Related Resources

• Section 508 Compliance Checklist
• Government Section 508 Guide
• VPAT Creation Guide
• WCAG 2.2 Level AA Checklist