Section 508 — Federal Electronic and Information Technology Accessibility

In this tutorial, you will learn about Section 508. We cover key concepts, practical examples, and best practices to help you master this topic.

Section 508 of the Rehabilitation Act requires US federal agencies to procure, develop, maintain, and use accessible electronic and information technology, updated in 2018 to incorporate WCAG 2.0 Level AA as the technical standard.

What You'll Learn

You will learn what Section 508 requires, who it applies to, how it relates to WCAG, and what you need to do if you sell technology products to the US government.

Why It Matters

If you sell to the US government or work for a federal agency, Section 508 Compliance is mandatory. Even if you do not sell directly to the government, your customers may require Section 508 compliance for their own procurement.

Real-World Use

DodaTech maintains a current VPAT (Voluntary Product Accessibility Template) for Durga Antivirus Pro that documents Section 508 compliance. This VPAT is required for every government procurement opportunity.

flowchart TD
  A[Section 508] --> B[Applies to]
  A --> C[Requirements]
  A --> D[Enforcement]
  B --> E[Federal agencies]
  B --> F[Federal contractors]
  B --> G[Organizations receiving federal funds]
  C --> H[WCAG 2.0 Level AA]
  C --> I[VPAT documentation]
  C --> J[Accessible procurement]
  D --> K[Agency 508 coordinator]
  D --> L[Complaint process]
  D --> M[Contract cancellation]

What Is Section 508?

Section 508 is an amendment to the Rehabilitation Act of 1973. It requires federal agencies to ensure that their electronic and information technology (EIT) is accessible to people with disabilities, including employees and members of the public.

The 2018 Refresh

In 2018, the US Access Board updated the Section 508 standards to incorporate WCAG 2.0 Level AA as the technical standard. This refresh aligned Section 508 with international standards and made compliance more straightforward.

What Changed

Before 2018, Section 508 had its own technical standards that differed from WCAG. After 2018, Section 508 references WCAG 2.0 AA, making it easier for organizations to comply with both standards simultaneously.

Who Must Comply

Federal agencies must comply with Section 508 for their own technology. Organizations that receive federal funding or sell technology products to the government must also comply.

VPAT Requirements

The VPAT (Voluntary Product Accessibility Template) is the standard format for documenting Section 508 compliance. The current VPAT 2.4 template covers Section 508, EN 301 549, and WCAG in a single document.

function checkSection508Requirements(productType, customers) {
  const requirements = [];
  if (customers.includes('federal-agency') || customers.includes('federal-contractor')) {
    requirements.push('WCAG 2.0 Level AA compliance');
    requirements.push('Current VPAT 2.4 documentation');
    requirements.push('Accessible procurement documentation');
    requirements.push('Section 508 conformance statement');
  }
  if (customers.includes('state-government')) {
    requirements.push('State-level accessibility requirements may apply');
  }
  return requirements;
}

console.log(checkSection508Requirements('software', ['federal-agency', 'enterprise']));

Expected output:

['WCAG 2.0 Level AA compliance', 'Current VPAT 2.4 documentation', 'Accessible procurement documentation', 'Section 508 conformance statement']

Enforcement

Each federal agency has a Section 508 coordinator. Complaints can be filed with the agency. The US Department of Justice can investigate and pursue remedies. Contract remedies include contract cancellation and debarment from future contracts.

Common Mistakes

1. Assuming Section 508 Is Optional for Contractors

If you sell to the federal government, Section 508 compliance is mandatory. It is written into procurement contracts.

2. Using an Outdated VPAT

VPAT 2.4 is the current version. Using VPAT 2.3 or older may result in rejection of your procurement proposal.

3. Confusing Section 508 with ADA

Section 508 applies to federal agencies and contractors. ADA applies to private businesses. Both reference WCAG but apply to different entities.

4. Not Updating VPAT Annually

A VPAT more than 12 months old may be considered outdated. Update it at least annually or with each product release.

5. Ignoring State-Level Requirements

Many states have their own accessibility requirements that exceed Section 508. Check state-specific rules if you sell to state governments.

6. Treating 508 Compliance as a Technical Issue

Section 508 includes procurement, documentation, and management requirements. It is not just about code.

7. Not Training Staff on 508

Agencies must train their staff on Section 508. Contractors should also train their teams on accessibility requirements.

Practice Questions

1. What WCAG version does Section 508 reference?

WCAG 2.0 Level AA, as updated in the 2018 refresh.

2. What document is used to demonstrate Section 508 compliance?

The VPAT (Voluntary Product Accessibility Template), currently version 2.4.

3. Who enforces Section 508?

Each federal agency has a Section 508 coordinator. The DOJ can also investigate complaints.

4. Does Section 508 apply to mobile apps?

Yes. Section 508 covers electronic and information technology including mobile applications.

5. Challenge: Download the VPAT 2.4 template and evaluate one of your products against Section 508 criteria. Document your findings.

FAQ

Mini Project

Create a Section 508 compliance checklist for your organization. Include VPAT documentation, WCAG compliance testing, staff training, and procurement policies. Mark each item with a status.

What's Next

Learn about WCAG in Legal Context to understand how courts interpret WCAG in litigation. Then explore EAA / EN 301 549 for European requirements.