Section 508 Compliance

What is Section 508 Compliance?

Section 508 compliance requires ICT to conform with WCAG 2.0 AA standards. Section 508 of the Rehabilitation Act requires federal agencies to make their information and communication technology (ICT) accessible to people with disabilities. Updated in 2017 through the Section 508 Refresh (the Revised 508 Standards), the rule harmonized U.S. requirements with the internationally recognized standards for website accessibility—the Web Content Accessibility Guidelines (WCAG 2.0) Level AA, and it added accessibility requirements for software, hardware, and electronic documents.

Importantly, the scope of Section 508 extends beyond federal agencies themselves. It also applies to any vendors, contractors, or organizations that provide digital products and services to the federal government. Whether it’s a website, mobile app, software platform, or PDF document, if it’s procured by a federal entity, it must meet accessibility standards.

Section 508 Compliance Requirements.

Who Section 508 applies To:

  • Federal agencies: Every federal department and agency is responsible for ensuring its ICT is accessible.
  • Vendors and contractors: Companies providing software, digital platforms, or ICT products to federal agencies must comply as well. 

What Section 508 applies To:

  • Websites and web applications
  • Mobile apps
  • Software and operating systems
  • Electronic documents (PDFs, Word, PowerPoint, Excel, etc.)
  • Multimedia content (videos, audio, webinars)
  • Hardware and IT systems (computers, kiosks, telecommunications equipment)

Required Standards for Section 508 Compliance.

The Revised 508 Standards establish WCAG 2.0 Level AA as the baseline for digital accessibility. They also include requirements specific to ICT, such as software interoperability with assistive technologies and hardware accessibility features. However, while WCAG 2.0 is the legal standard, many agencies now look to WCAG 2.1 or WCAG 2.2 Level AA. These later iterations of WCAG build upon earlier versions while accounting for improvements in technology and additional disabilities. Aligning with the more recent standards will improve usability and is a recommended best practice.

Section 508 and its Overlap with ADA Title II.

There is an important overlap between Section 508 and the ADA Title II Rulemaking. That rule establishes specific accessibility standards and requirements for state and local governments in the U.S.; however, it cites a later version of WCAG:

  • Federal agencies and vendors subject to Section 508 compliance are required to create and procure ICT that meets WCAG 2.0 AA standards.
  • State and local governments subject to ADA Title II are required to create and procure products and services that meet WCAG 2.1 AA.

For organizations that are subject to both laws—such as federal entities providing state-like services or multi-jurisdictional agencies—the safest and most efficient approach is to ensure all ICT created or produced conforms with  WCAG 2.1 AA or higher. WCAG 2.1 includes every success criterion from the earlier 2.0, while adding more specific guidelines for mobile accessibility and for uses with low vision and cognitive/ learning disabilities.

Similarly, for vendors selling products or services to both federal and state customers, aligning with WCAG 2.1 (or later versions) ensures that offerings satisfy both procurement requirements and minimizes the risk of being excluded from contracts.

Procurement Requirements under Section 508.

Procurement is central to Section 508. Federal agencies must buy, build, and maintain only ICT that conforms to the Revised 508 Standards—unless a documented exception applies.

Market research:

  • Accessibility must be evaluated early in the acquisition process. Solicitations and contracts should clearly include Section 508 requirements.

Vendor documentation:

  • Agencies evaluate Accessibility Conformance Reports (ACRs)—most often created using the VPAT® template—during market research and proposal evaluation.

Exception handling:

  • Agencies may procure a non-conforming product only if no accessible option exists, and they must document the justification. Where an exception is used, agencies must provide alternative means of access so individuals with disabilities can still use the system.

Ongoing responsibility:

  • Compliance isn’t just a box to check at purchase. Agencies are expected to ensure accessibility is maintained through updates, renewals, and integrations with other systems.

Deadlines for Section 508 Compliance.

There are no phased deadlines under Section 508. The Revised 508 Standards took effect on January 18, 2018, and all new or updated federal ICT must meet them.

Penalties and Consequences of Non-Compliance.

Administrative complaints and lawsuits:

  • Individuals can file complaints, and remedies align with Section 504 procedures, including injunctive relief and attorneys’ fees.

Procurement restrictions:

  • Agencies cannot buy non-conforming ICT unless a valid exception is documented.

Budget and program impacts:

  • Non-compliance can force re-procurements, delay projects, or require reallocation of funds to remediation.

Oversight and accountability:

  • Agencies are expected to strengthen their Section 508 programs, report annually on progress, and integrate accessibility into acquisition planning and management

How Allyant Helps with Section 508 Compliance.

Allyant supports hundreds of agencies and organizations subject to Section 508 compliance. Our solution set is uniquely suited to assist with creating—and procuring—ICT that conforms to the legal standards for accessibility:

Comprehensive digital audits and ongoing support:

VPAT creation (Accessibility Conformance Reports):

VPAT validation (third-party software testing):

Document accessibility strategy and remediation:

Training and capacity-building:

Monitoring and reporting:

Alternative format production:

  • Production of Braille, reflowed large print, accessible PDFs, and structured text to support effective communication.

Litigation and complaint support:

  • Support for agencies and vendors facing Section 508-related complaints, with expert analysis and documentation.

To begin your journey to Section 508 compliance, engage our team today.

Frequently Asked Questions.

Not directly. Section 508 applies to federal agencies and their vendors. However, many states have adopted Section 508 standards—or WCAG equivalents—into their own procurement rules.

Section 508 requires U.S. federal agencies, and those that do business with them, create and procure accessible ICT.

Section 504 prohibits discrimination in programs or activities receiving federal funding, including schools, hospitals, etc).

Yes. Vendors offering ICT to U.S. federal agencies are expected to provide an Accessibility Conformance Report (ACR), typically created using the VPAT.

No. The legal baseline is WCAG 2.0 AA; however, conformance with WCAG 2.1 or 2.2 AA is widely recognized as best practice.

Any ICT you provide to a U.S. federal agency must meet WCAG 2.0 AA under Section 508, while your public-facing websites and mobile apps must meet WCAG 2.1 AA under the ADA Title II rule. Following the higher standard (2.1 AA) can simplify compliance for both.

No. Automated scanners are useful for identifying common issues, but they cannot establish compliance on their own. When procuring accessible ICT, agencies commonly rely on ACRs backed by credible human testing.

A U.S. federal agency may purchase a non-conforming product only if no accessible option exists and the purchase is essential. The agency must document the exception and provide alternative means of access.

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