AccessivePath

United States — federal government and federal contractors · 1998 (2017 Refresh)

Section 508 of the Rehabilitation Act (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.

What is Section 508?

Originally enacted 1998 and substantially refreshed 2017, Section 508 governs federal procurement of ICT. The Refresh harmonised Section 508 with WCAG 2.0 Level AA and EN 301 549, easing global procurement. Compliance is documented via a VPAT (Voluntary Product Accessibility Template) completed by the vendor.

Who does Section 508 apply to?

  • All US federal executive agencies
  • Federal contractors and subcontractors selling ICT
  • State and local entities receiving federal funds (some flows)
  • Universities receiving federal research funding (via grants)

Scope

  • Federal-agency websites and applications
  • Federal-contractor ICT
  • ICT procured with federal funds

Penalties for non-compliance

  • 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

How to comply with Section 508

  1. Complete a VPAT/ACR. Use the latest VPAT 2.5 template (or 2.5INT for international). Document conformance to WCAG 2.0 AA per chapter 5 of Section 508.
  2. Test against WCAG 2.0 AA. Combined automated + manual + assistive-technology testing. AT-required: NVDA, JAWS, VoiceOver, ZoomText.
  3. Cover all 508 surfaces. Web (chapter 5), software (chapter 4), hardware (chapter 4), and documentation/support.
  4. Update annually. Federal contracts require current VPATs. Re-test after any significant product change.

Comparisons

  • Section 508 vs ADA: 508 governs federal procurement. ADA governs everyone else (employment, public accommodations).
  • Section 508 vs WCAG 2.0: The 2017 Refresh harmonised 508 to WCAG 2.0 Level AA. They are now technically aligned.
  • Section 508 vs EN 301 549: 508 and EN 301 549 were intentionally aligned in 2017. A VPAT covers both for most ICT.

Authoritative sources

A note on widgets and overlays

Can an accessibility widget make your site compliant?

No. Widgets adjust how content renders for individual visitors — text size, contrast modes, dyslexia-friendly fonts. They do not remediate the underlying source code. WCAG conformance is graded at source level, and US federal courts (Murphy v. Eyebobs, Suarez v. Camping World, Hernandez v. Caesars) have repeatedly held that the presence of an overlay does not preclude ADA liability.

Our product produces an IAAP-format audit report with source-level remediation guidance. If you want a preferences panel for end users, ship one separately — opt-in, disclosed, and never marketed as a compliance solution.

See the Overlay Fact Sheet, signed by 900+ accessibility professionals.

FAQ

Section 508 — frequently asked questions

Cited answers. Sourced. Updated as standards and case law change.

  • What is a VPAT?

    Voluntary Product Accessibility Template — the standard form vendors use to disclose Section 508 conformance. Completed VPATs become Accessibility Conformance Reports (ACRs). Required for most federal procurement.

  • Who must comply with Section 508?

    US federal executive agencies must procure 508-conformant ICT. Vendors selling to federal buyers must provide a VPAT/ACR. Recipients of federal funds (universities, contractors) often inherit the obligation.

  • What WCAG level does Section 508 require?

    WCAG 2.0 Level AA per the 2017 Refresh. While WCAG 2.0 remains the formal Section 508 baseline, most federal RFPs now reference 2.1 or 2.2 AA as a practical matter.

  • Do private companies need Section 508?

    Only if you sell to the federal government, receive federal grants, or contract with federally funded entities. Private B2C companies are governed by the ADA, not Section 508.

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IAAP-format report. AccessivePath maps findings to Section 508 and every related standard simultaneously.

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