Section 508

Section 508 of the Rehabilitation Act requires that all information and communication technology (ICT) developed, procured, maintained, or used by federal agencies be accessible to people with disabilities. This guide provides a plain English, detailed breakdown of the key elements and requirements of Section 508.

Purpose and Scope

Purpose

Section 508 was enacted to ensure that federal employees and members of the public with disabilities have access to and use of information and data that is comparable to that available to others. This includes ensuring that all ICT is accessible.

Scope

The standards apply to all federal agencies’ ICT, including but not limited to:

  • Computers and related hardware
  • Websites and web-based applications
  • Multimedia and video content
  • Electronic documents and publications
  • Telecommunications equipment
  • Software applications

These standards are categorized into several chapters, each focusing on different aspects of accessibility.

Key Terms

Information and Communication Technology (ICT)

ICT encompasses a wide range of technologies and services, such as:

  • Computers, including desktops, laptops, and tablets
  • Information kiosks and transaction machines
  • Telecommunications equipment, such as telephones and VoIP systems
  • Multifunction office machines like printers and copiers
  • Software, including operating systems and applications
  • Websites and web applications
  • Electronic documents, such as PDFs and Word files

Federal Agency

A federal agency includes any executive department, military department, government corporation, government-controlled corporation, or other establishment in the executive branch of the U.S. government. Examples of federal agencies include:

  • Department of Defense (DoD): Responsible for military forces and national security.
  • Department of Health and Human Services (HHS): Manages public health, welfare, and health policy.
  • Social Security Administration (SSA): Oversees social security benefits and services.
  • Environmental Protection Agency (EPA): Protects human health and the environment.

In 2024, the HHS issued a new rule updating regulation to Section 504 of the Rehabilitation Act. This new rule added several new provisions including digital accessibility requirements that mirrored the new web accessibility rule under Title II of the Americans with Disabilities Act. Read about the new HHS web accessibility requirements.

Accessibility

The design and functionality of ICT that ensure usability by individuals with disabilities, providing them with comparable access and opportunities.

General Requirements

Chapter 1: Application and Administration

Purpose

Chapter 1 provides the foundational principles and definitions that guide the implementation of Section 508 standards. It sets the stage for understanding the scope and application of the regulations.

Key Elements

  • Definitions: Clear definitions of terms such as “information and communication technology” and “accessibility” to ensure consistent understanding.
  • Application: Explains how the standards apply to various ICT products and services within federal agencies.
  • Administration: Details the responsibilities of federal agencies in implementing and enforcing the standards.

Practical Information

  • Roles and Responsibilities: Defines who is responsible for ensuring compliance within an agency, typically the CIO or a designated accessibility coordinator.
  • Training Requirements: Outlines the need for training programs to educate staff on accessibility requirements and best practices.

Chapter 2: Scoping Requirements

Purpose

Chapter 2 specifies which ICT components must comply with the standards and how compliance should be determined. It provides the scope of applicability, ensuring that all relevant ICT is covered.

Key Elements

  • Scoping: Identifies the ICT products and services that need to comply with the standards.
  • Exceptions: Lists specific situations where exceptions to the standards may apply, such as national security systems or cases of undue burden.
  • Compliance Methods: Details the methods for evaluating and documenting compliance.

Practical Information

  • Project Planning: Encourages incorporating accessibility considerations at the planning stage of ICT projects to ensure compliance from the outset.
  • Periodic Reviews: Recommends regular reviews and updates of ICT to maintain compliance as technology and standards evolve.

Equivalent Facilitation

Overview

Agencies are permitted to use alternative designs or technologies if they provide substantially equivalent or greater accessibility and usability for people with disabilities. This provision encourages innovation while maintaining high accessibility standards.

Practical Examples

  • Voice-Activated Assistants: Using voice-activated assistants to provide information to users who cannot interact with traditional input devices.
  • Mobile Applications: Developing mobile applications that offer the same functionality as a desktop website, ensuring that all features are accessible on multiple platforms.
  • Customized Interfaces: Creating customized user interfaces that cater to specific disabilities, such as a simplified interface for users with cognitive impairments.

Specific Requirements

Functional Performance Criteria (Chapter 3)

When specific technical requirements do not address one or more features of ICT, the functional performance criteria ensure that ICT remains accessible. These criteria include:

  • Vision: Ensuring that ICT is operable without relying on visual perception. This may include providing text-to-speech capabilities or ensuring screen reader compatibility.
  • Hearing: Ensuring that ICT is operable without relying on auditory perception. This may include providing captions for videos and audio descriptions for visual content.
  • Speech: Ensuring that ICT is operable without relying on speech. This may include offering alternative input methods for voice-controlled technologies.
  • Motor Skills: Ensuring that ICT is operable with limited manipulation, reach, or strength. This may include designing interfaces that can be navigated with a single switch or using alternative input devices.

Hardware (Chapter 4)

Requirements for hardware focus on ensuring that physical components are accessible. Key considerations include:

  • Keyboards and Input Devices: Must be operable with one hand, and alternatives should be provided for users who cannot use standard keyboards.
  • Touchscreens and Displays: Must provide alternative input methods, such as voice commands or switch controls.
  • Physical Reach and Strength: Controls and inputs should be within accessible reach ranges and operable with limited strength.

Software (Chapter 5)

Software must be designed to be accessible to users with disabilities. Key requirements include:

  • Text Alternatives: Providing text alternatives for all non-text content, such as images and multimedia.
  • Keyboard Navigation: Ensuring that all functionalities can be operated through a keyboard interface.
  • Assistive Technology Compatibility: Ensuring compatibility with assistive technologies, such as screen readers, magnifiers, and voice recognition software.

Support Documentation and Services (Chapter 6)

All support documentation and services provided for ICT must be accessible. This includes:

  • Help Desks and Technical Support: Ensuring that support services are accessible, offering options such as TTY (text telephone) and real-time text support.
  • User Manuals and Guides: Providing documentation in accessible formats, such as large print, Braille, and electronic formats compatible with screen readers.

Electronic Content (Chapter 7)

Electronic content, such as documents and web pages, must be accessible. This includes ensuring:

  • Accessible Formats: Documents must be available in formats that can be read by screen readers and other assistive technologies.
  • Structure and Navigation: Content must be organized with clear headings, lists, and logical reading order to facilitate navigation by users with disabilities.
  • Multimedia Accessibility: Videos and multimedia presentations must include captions, audio descriptions, and transcripts.

Incorporation of WCAG 2.0

Overview of WCAG 2.0

The Web Content Accessibility Guidelines (WCAG) 2.0 are a globally recognized set of guidelines designed to make web content more accessible to people with disabilities. Section 508 incorporates WCAG 2.0 to ensure that web content, non-web documents, and software meet accessibility standards.

Key Principles of WCAG 2.0

WCAG 2.0 is based on four main principles:

  • Perceivable: Information and user interface components must be presentable to users in ways they can perceive. This includes providing text alternatives for non-text content and ensuring that web pages are designed so they can be read by screen readers.
  • Operable: User interface components and navigation must be operable. This means that users must be able to navigate the interface and interact with it using different input methods, such as keyboard or voice commands.
  • Understandable: Information and the operation of the user interface must be understandable. This includes making text readable and understandable and ensuring that web pages operate in predictable ways.
  • Robust: Content must be robust enough to be interpreted reliably by a wide variety of user agents, including assistive technologies. This means ensuring compatibility with current and future user tools.

Conformance Levels

WCAG 2.0 guidelines are organized into three levels of conformance:

  • Level A: The most basic, foundational web accessibility features. These are the minimum requirements that web assets should meet as a starting point.
  • Level AA: Provides a more comprehensive level of accessibility and eliminates any notable barriers. Conformance level AA addresses a wider range of accessibility issues.
  • Level AAA: The highest and most complex level of web accessibility. AAA conformance will make content accessible to the maximum number of people.

While Section 508 only incorporates WCAG 2.0 AA, the World Wide Web Consortium’s (W3C) Web Accessibility Initiative (WAI) has since published two more versions: WCAG 2.1 and WCAG 2.2. These more recent versions add 12 and 6 new success criteria for AA conformance, respectively.

Read our checklists and download the Accessible.org WCAG guides on our WCAG resource page.

Application to Section 508

Section 508 requires federal agencies to ensure that all web and non-web content, as well as software, conforms to WCAG 2.0 Level A and Level AA success criteria and conformance requirements. This ensures a high standard of accessibility across all digital content and technologies used by federal agencies.

VPATs and ACRs

Overview

A Voluntary Product Accessibility Template (VPAT) is a template document that, when filled in, explains how an ICT product or service conforms to Section 508 standards. An Accessibility Conformance Report (ACR) is generated from the completed VPAT and provides a detailed account of the product’s accessibility features and compliance status.

Purpose

VPATs and ACRs help federal agencies evaluate the accessibility of ICT products and services before procurement. They provide:

  • Transparency: Clear information about the accessibility features and limitations of a product.
  • Comparability: A standardized format that allows agencies to compare the accessibility of different products.
  • Documentation: Evidence of compliance efforts that can be reviewed and audited.

Practical Information

  • Creating a VPAT: Vendors should fill out a VPAT template, detailing how their product meets each criterion of the Section 508 standards.
  • Using an ACR: Agencies should review ACRs to assess the accessibility of products and make informed procurement decisions.
  • Ensuring Accuracy: Vendors should ensure that VPATs and ACRs are accurate and up-to-date, reflecting any changes or updates to the product.

Our digital accessibility services page includes our VPAT / ACR services and you can visit our pricing page to find a cost expectation. Our ACR creation service follows an audit and we charge a discounted fee because the primary work involves our audit.

Documentation of Efforts

Importance

Documenting efforts to comply with Section 508 is crucial for several reasons:

  • Accountability: Ensures that agencies are held accountable for their accessibility efforts.
  • Transparency: Provides a clear record of actions taken to achieve compliance.
  • Continuous Improvement: Helps identify areas for improvement and track progress over time.

Practical Steps

  • Compliance Records: Keep detailed records of all accessibility assessments, decisions, and actions taken.
  • Undue Burden Justifications: Document any instances where compliance is not possible due to undue burden, including the reasons and alternative measures provided.
  • Regular Reviews: Conduct periodic reviews of documentation to ensure accuracy and completeness.

Equivalent Facilitation

Overview

Equivalent facilitation allows agencies to use alternative designs or technologies if they provide substantially equivalent or greater accessibility and usability for people with disabilities. This provision encourages innovation while maintaining high accessibility standards.

Practical Examples

  • Voice-Activated Assistants: Using voice-activated assistants to provide information to users who cannot interact with traditional input devices.
  • Mobile Applications: Developing mobile applications that offer the same functionality as a desktop website, ensuring that all features are accessible on multiple platforms.
  • Customized Interfaces: Creating customized user interfaces that cater to specific disabilities, such as a simplified interface for users with cognitive impairments.

Training

Importance

Training is essential to ensure that all federal employees understand the requirements of Section 508 and are equipped to implement and maintain accessible ICT.

Key Areas

  • General Awareness: Educating all employees about the importance of accessibility and their role in ensuring compliance.
  • Technical Training: Providing in-depth training for IT staff, developers, and content creators on how to design and develop accessible ICT.
  • Procurement Training: Ensuring that procurement officers understand how to evaluate VPATs and ACRs to make informed purchasing decisions.

Practical Information

  • Training Programs: Agencies should establish regular training programs, including workshops, webinars, and online courses.
  • Resources: Providing access to resources, such as guidelines, checklists, and best practices for creating accessible ICT.
  • Assessment: Conducting regular assessments to ensure employees understand and can apply the knowledge gained from training.

Learn more about our WCAG training workshops and programs.

Certification

Overview

Certification programs validate the knowledge and skills of individuals in accessibility standards and practices. These programs help ensure that personnel responsible for accessibility compliance are qualified.

Key Certifications

  • Certified Professional in Accessibility Core Competencies (CPACC): A certification that covers foundational knowledge of accessibility.
  • Web Accessibility Specialist (WAS): Focuses on technical skills and knowledge required to implement and evaluate web accessibility.
  • Certified Accessible Document Specialist (CADS): Specializes in creating and assessing accessible documents.

Practical Benefits

  • Credibility: Certification adds credibility and demonstrates a commitment to accessibility.
  • Expertise: Ensures that certified individuals have the necessary expertise to implement and maintain accessible ICT.
  • Continuous Learning: Certification often requires ongoing education, keeping professionals updated on the latest accessibility standards and practices.

Trusted Testers

Program Overview

The Trusted Tester Program, developed by the Department of Homeland Security, provides a standardized approach to accessibility testing. Trusted Testers are trained and certified to evaluate ICT products for compliance with Section 508 standards.

Key Elements

  • Training: Individuals undergo extensive training on accessibility testing methodologies and tools.
  • Certification: After training, individuals must pass an exam to become certified Trusted Testers.
  • Testing Protocols: Trusted Testers follow specific protocols and use standardized tools to ensure consistent and accurate testing results.

Practical Information

  • Testing Tools: Trusted Testers use approved tools, such as screen readers and automated testing software, to evaluate accessibility.
  • Standardized Reports: Testers provide standardized reports that detail the accessibility issues found and recommendations for remediation.
  • Quality Assurance: Trusted Tester certification ensures a high level of quality and consistency in accessibility testing across federal agencies.

User Testing

Importance

User testing involves real users with disabilities interacting with ICT products to identify accessibility issues that may not be evident through automated testing or technical evaluations.

Key Elements

  • Diverse Participants: Include users with a wide range of disabilities to get comprehensive feedback.
  • Real-World Scenarios: Test products in scenarios that mimic real-world use to identify practical accessibility challenges.
  • Feedback Collection: Collect detailed feedback from participants to understand their experiences and identify areas for improvement.

Practical Steps

  • Recruitment: Identify and recruit a diverse group of participants with varying disabilities.
  • Test Design: Develop test scenarios that reflect real-world usage of the ICT product.
  • Analysis: Analyze feedback to identify common issues and prioritize remediation efforts.

Auditing

Importance

Regular audits ensure ongoing compliance with Section 508 standards and help identify new accessibility issues as ICT products evolve.

Key Elements

  • Comprehensive Review: Conduct thorough reviews of all ICT products and services to ensure compliance.
  • Documentation: Maintain detailed records of audit findings and remediation actions.
  • Continuous Improvement: Use audit results to inform ongoing accessibility improvements and updates.

Practical Steps

  • Audit Schedule: Establish a regular schedule for conducting accessibility audits.
  • Checklist: Develop a comprehensive checklist based on Section 508 standards to guide the audit process.
  • Reporting: Generate detailed reports of audit findings, including recommendations for remediation.

The Access Board

Overview

The United States Access Board is an independent federal agency that promotes equality for people with disabilities through leadership in accessible design and the development of accessibility guidelines and standards.

Role

  • Standards Development: The Access Board is responsible for developing and updating accessibility standards for ICT under Section 508.
  • Technical Assistance: Provides guidance and support to federal agencies and the public on how to comply with Section 508 standards.
  • Enforcement: Works with other federal agencies to enforce accessibility standards and ensure compliance.

Resources

  • Guidelines and Standards: Publishes comprehensive guidelines and standards for ICT accessibility.
  • Training and Webinars: Offers training sessions and webinars to educate stakeholders on accessibility requirements.
  • Technical Support: Provides technical assistance through various channels, including email, phone, and online resources.

Conclusion

Section 508 is essential for ensuring that federal ICT is accessible to all individuals, including those with disabilities. By following these standards, federal agencies can provide equitable access to information and technology, fostering an inclusive environment for employees and the public.