What does Section 508 require?

Section 508 requires US federal agencies and their contractors to ensure ICT products and services (websites, software, hardware, documents) are accessible to people with disabilities. For web content, the 2017 Refresh requires conformance to WCAG 2.0 Level A and AA success criteria. It applies to development, procurement, maintenance, and use of ICT by federal agencies.

Does Section 508 apply to private companies?

Section 508 applies to private companies when they are developing or providing ICT products or services to federal agencies (as contractors or vendors). It does not apply to private sector companies that do not contract with the federal government. For private sector obligations, ADA Title III (for public accommodations) and state laws are the relevant frameworks.

What is the Section 508 refresh?

The 2017 ICT Standards and Guidelines Refresh (effective January 2018) completely replaced the 1998 Section 508 standards. Key changes: (1) adopted WCAG 2.0 Level A and AA by reference, replacing technology-specific rules; (2) expanded scope to include software, support documentation, and hardware; (3) harmonized with the international standard EN 301 549; (4) introduced functional performance criteria as a safety net for gaps in specific technical requirements.

What is a VPAT and when is it required?

VPAT (Voluntary Product Accessibility Template) is a document maintained by the ITI (Information Technology Industry Council) used to report how a product or service conforms to Section 508 standards. Federal agencies typically require contractors to provide a VPAT (also called an Accessibility Conformance Report, ACR) as part of procurement. The VPAT 2.5 template includes tables for WCAG 2.0, WCAG 2.1, WCAG 2.2, EN 301 549, and revised Section 508.

How does Section 508 relate to ADA Title III?

Section 508 and ADA Title III are separate legal frameworks. Section 508 applies to federal agencies and their contractors; ADA Title III applies to places of public accommodation (private businesses). However, both use WCAG as their technical benchmark — Section 508 references WCAG 2.0, while the ADA DOJ rule (April 2024) references WCAG 2.1 AA for Title II (state/local government). Courts in ADA Title III litigation frequently use WCAG 2.1 or 2.2 as the accessibility standard.

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Section 508

Section 508 of the Rehabilitation Act of 1973, as amended in 1998, requires US federal agencies to ensure that information and communication technology (ICT) they develop, procure, maintain, or use is accessible to employees and members of the public with disabilities. The 2017 ICT Standards and Guidelines Refresh (effective 18 January 2018) substantially revised the technical requirements, replacing the original 1998 technology-specific standards with a functional performance criteria approach aligned with WCAG 2.0 AA (Chapters 1 and 2 of the Revised 508 Standards) and EN 301 549 (international harmonization). WCAG 2.0 Level A and AA success criteria are incorporated by reference, making Section 508 web requirements equivalent to WCAG 2.0 AA in practice.

Status

US Access Board

In force

2017 (Refresh)

Auto coverage

~35 %

Detailed coverage

What ScanAccess detects on Section 508

E205Electronic content (web + software) — WCAG 2.0 AAAuto
E206Authoring tools — accessibilityManual
E207Support documentationManual
E301Functional performance criteria — Without visionManual
E302Functional performance criteria — Limited visionAuto
E303Functional performance criteria — Without color perceptionAuto
E304Functional performance criteria — Without hearingAuto
E401Platform accessibility featuresManual
E402Accessibility servicesManual
E501Hardware — Operable partsManual

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