comparison
Section 508 vs EAA
Section 508 (Section 508 of the Rehabilitation Act, United States — federal government and federal contractors, 1998 (2017 Refresh)) and EAA (European Accessibility Act, European Union (all 27 member states), 2019) are two of the most-referenced accessibility frameworks in digital compliance. This guide compares them side by side — jurisdiction, scope, conformance approach, penalties, and how a single audit can cover both simultaneously.
What is Section 508?
Section 508 of the Rehabilitation Act requires US federal agencies, federal contractors, and recipients of federal funds to make their information and communications technology (ICT) accessible to people with disabilities, with conformance benchmarked against WCAG 2.0 Level AA via the 2017 Refresh.
Maintainer
US Access Board
Jurisdiction and enforcement
United States — federal government and federal contractors. GSA, agencies, US Court of Federal Claims.
What is EAA?
The European Accessibility Act (Directive (EU) 2019/882) is the EU's prescriptive accessibility law that takes effect 28 June 2025, requiring covered products and services — banking, e-commerce, transport, audiovisual media, ebooks and computer hardware — to meet harmonised accessibility requirements derived from EN 301 549 and WCAG 2.1 AA.
Maintainer
European Commission
Jurisdiction and enforcement
European Union (all 27 member states). Per member state, via national transpositions.
Section 508 vs EAA — the key differences
The principal difference is jurisdictional: Section 508 applies in United States — federal government and federal contractors, while EAA applies in European Union (all 27 member states). Section 508 is maintained by US Access Board; EAA is maintained by European Commission. The standards differ on scope, conformance grading, and penalty structure — but a well-designed accessibility programme can satisfy both simultaneously by adopting the strictest applicable requirement and cross-mapping findings.
Scope
Section 508 covers: Federal-agency websites and applications, Federal-contractor ICT, ICT procured with federal funds. EAA covers: Consumer banking services, E-commerce (B2C online sales), Air, rail, water, bus passenger transport, Audiovisual media services and devices, Electronic communications services, E-readers and ebooks, Self-service terminals (ATMs, ticket machines), Consumer computer hardware and operating systems.
Penalties
Section 508: Procurement disqualification. EAA: Germany: up to €100,000 administrative fine + suspension of service.
How to comply with both at once
Adopt the stricter applicable conformance level — typically WCAG 2.2 Level AA — as your engineering baseline. Audit against that baseline once, then cross-map findings to both Section 508 and EAA specific requirements. A single Accessibility Conformance Report (ACR) using VPAT 2.5 INT can document both.
When you might need just one
If you operate exclusively in United States — federal government and federal contractors and have no cross-border procurement exposure, you may only need Section 508. The same applies in reverse for EAA. For organisations selling cross-border, into the EU or US public sector, the safer default is to plan to both simultaneously.
Sources
- Section508.gov — GSA
- Section 508 Standards (ICT Refresh) — US Access Board
- Directive (EU) 2019/882 (European Accessibility Act) — European Union
- EN 301 549 v3.2.1 — ETSI
FAQ
Frequently asked questions
Cited answers. Sourced. Updated as standards and case law change.
Is Section 508 stricter than EAA?
Neither standard is uniformly "stricter" — they cover different regulatory domains. Section 508 is more prescriptive about federal-agency websites and applications; EAA about consumer banking services. For organisations exposed to both, a unified WCAG 2.2 AA baseline typically satisfies the technical requirements of both.
Can a single audit satisfy Section 508 and EAA?
Yes. Both standards ultimately reference WCAG-aligned criteria. A combined audit with cross-mapped findings can produce documentation acceptable to both regulators.
Which jurisdictions enforce Section 508?
United States — federal government and federal contractors. GSA, agencies, US Court of Federal Claims.
Which jurisdictions enforce EAA?
European Union (all 27 member states). Per member state, via national transpositions.
What happens if I am not compliant with Section 508?
Procurement disqualification Contract termination or modification Bid protests at GAO and US Court of Federal Claims Reputational and downstream civil-rights exposure under Sections 501 and 504
What happens if I am not compliant with EAA?
Germany: up to €100,000 administrative fine + suspension of service France: up to €75,000 + daily penalty up to €3,000 Italy: up to €40,000 + product/service withdrawal Ireland: up to €60,000 / 18 months imprisonment Spain: up to €1,000,000 for repeat serious infringements
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