Section 508 of the Rehabilitation Act (29 U.S.C. § 794d) requires federal agencies to ensure that the information and communication technology (ICT) they develop, procure, maintain, or use is accessible to employees and members of the public with disabilities. The 2017 "Revised Section 508 Standards" aligned the technical requirements with WCAG 2.0 Level AA, effectively making WCAG 2.0 AA the federal ICT accessibility standard.
Who must comply
Direct compliance requirements fall on federal executive agencies. However, contractors and vendors that supply ICT products or services to federal agencies are expected to meet 508 requirements as a condition of procurement. Agencies are required to include 508 compliance in solicitations and contracts for ICT. If you sell software, SaaS, or technology services to the federal government, 508 compliance is effectively a procurement requirement.
What the Revised 508 Standards cover
The Revised Standards cover six categories of ICT:
- Web content — websites and web applications (incorporates WCAG 2.0 AA by reference)
- Electronic documents — PDFs, Word, PowerPoint, spreadsheets
- Software — native applications and authoring tools
- Telecommunications — phones and video conferencing equipment
- Hardware — computers, printers, kiosks, and copiers
- Support documentation and services — help desks and user manuals
VPATs and Accessibility Conformance Reports
The Voluntary Product Accessibility Template (VPAT) is the standardized document contractors use to disclose the accessibility status of their ICT. A completed VPAT produces an Accessibility Conformance Report (ACR). Agencies use ACRs during procurement to evaluate whether a product meets their accessibility requirements. VPATs are not certifications — they are self-attested disclosures. Fabricating or overstating VPAT data creates significant legal risk.
Tip
Use the latest VPAT template (VPAT 2.5 as of 2024) which includes columns for WCAG 2.1 and EN 301 549 in addition to Section 508. This gives you international coverage in a single document.