US federal accessibility standard

Section 508

The 2017 Refresh of Section 508 of the Rehabilitation Act (36 CFR Part 1194) requires US federal agencies and their contractors to make ICT products and services accessible. The 2017 ICT Refresh harmonizes Section 508 with WCAG 2.0 AA and with EN 301 549, adopting a common global technical baseline.

ActiveUS Access Board2017 (Refresh)

What is 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.

Section 508 applies directly to: (1) all US federal executive agencies (cabinet departments, independent agencies, military branches); (2) federal contractors and vendors supplying ICT to federal agencies — a large market exceeding $90 billion annually in federal IT procurement; (3) recipients of federal financial assistance in some contexts. Section 508 does not apply to private sector companies unless they contract with the federal government. However, the ADA Title II final rule (April 2024) adopted WCAG 2.1 AA for state and local government web content, effectively parallel to Section 508 obligations.

Section 508 enforcement is handled by the Access Board (rulemaking) and individual agencies (internal compliance). Federal agencies must use VPAT (Voluntary Product Accessibility Template, maintained by ITI) to document contractor product conformance. Non-compliant procurements can be challenged under the Administrative Procedure Act or reported to the agency's Section 508 coordinator. The General Services Administration (GSA) maintains Section508.gov as the central resource. There is no private right of action under Section 508 itself, but Rehabilitation Act §501 and §504 claims may be available for federal employees.

Key criteria

The 10 requirements most frequently flagged in automated audits by scan-access.com.

E205
Electronic content (web + software) — WCAG 2.0 AA
All electronic content and software produced by federal agencies must conform to WCAG 2.0 Level A and AA success criteria. This is the core web requirement of the 2017 Refresh.
Official spec →WCAG 1.1.1–4.1.2
E206
Authoring tools — accessibility
Authoring tools (CMS, web builders) used by federal agencies must support the creation of accessible content, including features that generate correct ARIA and alt text.
Official spec →
E207
Support documentation
Documentation provided with ICT products must itself be accessible and must describe the accessibility features of the product.
Official spec →
E301
Functional performance criteria — Without vision
At least one mode of operation must not require vision. Content must be operable via screen reader or audio output.
Official spec →
E302
Functional performance criteria — Limited vision
At least one mode must support low-vision users, including text resizing up to 200% without loss of content or functionality.
Official spec →WCAG 1.4.4
E303
Functional performance criteria — Without color perception
Information conveyed by color alone must also be available without color distinction.
Official spec →WCAG 1.4.1
E304
Functional performance criteria — Without hearing
At least one mode must not require hearing. Captions and transcripts required for audio/video content.
Official spec →WCAG 1.2.1
E401
Platform accessibility features
ICT that is a platform must support the accessibility features of the operating system or platform, such as high-contrast mode, sticky keys, and system font scaling.
Official spec →
E402
Accessibility services
Platform software must expose accessibility services to assistive technologies (screen readers, magnifiers) via documented APIs.
Official spec →
E501
Hardware — Operable parts
Physical controls and operable parts must be reachable and usable without fine motor control. Hardware sold to federal agencies must meet reach and force requirements.
Official spec →

scan-access.com coverage

scan-access.com covers Section 508 web requirements (E205 / WCAG 2.0 AA)

Section 508 E205 requires federal agency web content to conform to WCAG 2.0 Level A and AA. scan-access.com's axe-core engine covers the same set of criteria with approximately 35% automated detection — contrast, alt text, form labels, keyboard accessibility, and ARIA correctness. For federal contractor VPAT preparation, scan-access.com provides per-criterion results that can be referenced directly in the Accessibility Conformance Report (ACR) sections for Web (WCAG 2.0 Level A and AA tables). The timestamped legal-defense PDF serves as audit evidence for agency procurement officers.

35% automated

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Frequently asked questions

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.