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Section 508 Compliance: A Guide to Federal Accessibility Requirements

This guide explains Section 508 Compliance: what it covers, who must comply, how it maps to WCAG, and the technical checks agencies and vendors should run. It includes a procurement checklist, a step-by-step remediation workflow, common mistakes and a quick review checklist.

Section 508 Compliance means federal electronic and information technology must be accessible to people with disabilities. Federal agencies must follow the Section 508 standards in procurement, development and maintenance of websites, software, documents and devices. This guide explains what falls under 508, how it links to WCAG, how to test and how to write procurement requirements that work.

What Section 508 covers

Section 508 is part of the Rehabilitation Act. It applies to federal executive agencies when they develop, procure, maintain or use electronic and information technology. Covered items include:

  • Websites and web apps
  • Desktop and mobile software
  • PDFs and other documents
  • Multimedia such as video and audio
  • Hardware where users interact with software

How Section 508 relates to WCAG and other laws

The refreshed Section 508 standards adopt success criteria from WCAG 2.0 at levels A and AA. WCAG provides specific testable rules such as text alternatives for images and keyboard operability. Section 508 is a federal requirement. Other laws such as the ADA may also apply to public-facing sites, but they use different legal tests and enforcement routes.

Who must comply

Primary responsibility sits with federal executive agencies. Vendors and contractors supplying technology to agencies usually must meet Section 508 requirements as part of contracts. Private websites not tied to federal agencies are not directly covered by Section 508 unless the site supports federal operations or funding.

Key technical requirements you will meet

Section 508 compliance is implemented through technical rules. Common practical requirements are:

  • Keyboard access: every function must be available without a mouse
  • Perceivable text: images must have text alternatives
  • Captions and transcripts: prerecorded and live media need captions or alternatives
  • Logical structure: headings, labels and form controls exposed to assistive tech
  • Contrast: text and important visuals must meet contrast ratios
  • Document accessibility: tagged PDFs, structured Word and Excel files

Common technical checks and how to run them

Use a mix of automated tools, manual review and user testing. Each method finds different issues.

Automated testing

  • Run a scanner that checks for common WCAG failures such as missing alt text and contrast.
  • Automated tools catch about 20 to 40 percent of issues. They do not replace manual checks.

manual review

  • Keyboard-only navigation across pages and app flows
  • Screen reader walkthroughs for key tasks using NVDA, VoiceOver or JAWS
  • Check semantic HTML: headings, ARIA only where needed

User testing

  • Test with people who use assistive technology for the tasks that matter most
  • Recruit at least two to three participants per major disability type where possible

Files and components often missed

Audit results often miss these items. They are easy to overlook but cause many real-world failures.

  • Scanned PDFs with no text layer
  • Interactive charts and maps with no keyboard or text alternatives
  • Complex forms that lack clear labels or error messages
  • Color-only instructions and insufficient contrast in UI states

Procurement: how to write Section 508 requirements

Write clear, testable requirements. Ask for a completed Voluntary Product Accessibility Template or an Accessibility Conformance Report. Include acceptance criteria and testing steps in the contract.

  • Require a VPAT and an ACR that maps product behavior to the Section 508 criteria and WCAG A and AA
  • Specify deliverables: accessibility test reports, remediation plan, and user test results
  • Include acceptance testing with agency staff and external users where applicable

Sample procurement checklist

Item Why it matters
Completed VPAT / ACR Shows vendor assessment against standards
Accessibility test report Demonstrates issues found and fixed
Remediation plan Timelines and responsibility for fixes
Contractual warranty Vendor obligation to maintain accessibility

Remediation workflow: step by step

  1. Scope the product and list critical user tasks
  2. Run automated scans and note high-impact failures
  3. Do manual keyboard and screen reader checks on critical tasks
  4. Prioritise fixes by impact and effort
  5. Implement fixes, update code and templates
  6. Repeat testing and validate with end users
  7. Create final Accessibility Conformance Report for procurement records

When equivalent facilitation applies

The rules allow agencies to provide an alternate method of access when strict conformance is not possible. That alternate must offer substantially equivalent access. Use equivalent facilitation only after you document attempts to meet the technical criteria and decide that an alternative best meets user needs.

Common mistakes and how to avoid them

  • Relying only on automated tools. Add manual checks and user testing
  • Treating accessibility as a one-off. Build checks into design, code review and CI pipelines
  • Accepting incomplete vendor VPATs. Require evidence and sample test results
  • Missing document workflows. Make PDF and Office file accessibility part of the content process

Quick checklist for a Section 508 review

  • Can every task be completed without a mouse?
  • Do images have meaningful alt text or descriptive captions?
  • Are video captions and audio transcripts available?
  • Do headings and labels match visible structure?
  • Do interactive controls have accessible names and states?
  • Are PDFs tagged and readable by a screen reader?
  • Does colour contrast meet readable levels for body text?

Records, documentation and ongoing governance

Keep a clear record of tests, VPATs, ACRs and user feedback. Make accessibility part of change control. That reduces risk when systems change or when new content is published.

Where to get help

Use internal accessibility leads or hire an external auditor for complex systems. For procurement use a vendor that provides a full VPAT with evidence. Train content authors and developers on accessible patterns, ARIA best practices and document tagging.

Section 508 Compliance is achievable. Start with the highest-impact tasks. Use a mix of automated checks, manual review and user testing. Require VPATs in procurement and keep accessibility in maintenance routines. That approach reduces risk and improves access for all users.