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What Is Section 508 Compliance?

The Law: Section 508 of the Rehabilitation Act

Section 508 was added to the Rehabilitation Act of 1973 in 1998. It requires federal agencies to develop, procure, maintain, and use electronic and information technology (EIT) that is accessible to people with disabilities — both employees and members of the public.

The Access Board issues and maintains the standards. In January 2018, the Access Board issued a major update (the "Refresh") that aligned Section 508 with WCAG 2.0 Level AA for web and software content.

Who Must Comply With Section 508?

• All federal agencies — covered directly by the law
• Federal contractors — when delivering ICT products or services to a federal agency
• Organizations receiving federal funding — universities, hospitals, and nonprofits with federal grants often interpret Section 508 as applying to them through grant conditions
• State agencies receiving federal funds — many states have their own 508-equivalent laws that apply to state contractors as well

Section 508 vs ADA: Key Differences

What Section 508 Covers Beyond Websites

Unlike ADA, which primarily targets public-facing websites, Section 508 covers a much broader range of ICT:

• Web content — all public and internal websites (WCAG 2.0 AA)
• Software applications — desktop apps, web apps, mobile apps
• Electronic documents — PDFs, Word documents, PowerPoint presentations
• Video and audio — must have captions and audio descriptions
• Telecommunications — phones, video conferencing tools
• Hardware — kiosks, copiers, ATMs in federal buildings
• Authoring tools — software used to create content must support accessible output

The VPAT: Voluntary Product Accessibility Template

When federal agencies procure technology, vendors are often required to provide a VPAT — a document that describes how their product conforms to Section 508 criteria. If your company sells software or services to federal agencies, you likely need a current VPAT.

The VPAT2 format maps your product against each WCAG 2.1 criterion and Section 508 provision with one of four conformance levels: Supports, Partially Supports, Does Not Support, Not Applicable.

Enforcement

Section 508 complaints go to the relevant agency's internal 508 coordinator first. Federal employees can file complaints with the EEOC for employment-related barriers. Members of the public can file complaints with the agency or pursue civil action in federal court.

Major enforcement actions have resulted in DOJ settlements requiring agencies to remediate entire websites, train staff, and appoint 508 coordinators with ongoing monitoring obligations.

Practical Steps for 508 Compliance

1. Audit all web properties against WCAG 2.0/2.1 AA (use Accessalyze)
2. Tag and remediate all PDFs for accessibility
3. Add captions to all video content
4. Test software with JAWS and NVDA screen readers
5. Include 508 requirements in procurement contracts
6. Appoint a Section 508 coordinator
7. Publish and maintain a Section 508 conformance page

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