Section 508 of the Rehabilitation Act of 1973:
Complete Compliance Guide

Section 508 of the Rehabilitation Act of 1973 (29 U.S.C § 794d), as amended, is a federal law that mandates federal agencies ensure their electronic and information communication technology (ICT) is accessible to people with disabilities. Access must be comparable to that available to individuals without disabilities—whether they are federal employees or members of the public.

The electronic and information communication technology subject to Section 508 includes websites, web applications, software, digital documents, multimedia content, and hardware such as kiosks and telecommunications equipment.

What Is Section 508 Compliance?

Section 508 compliance means that federal agencies must develop, procure, maintain, and use ICT that meets specific accessibility standards. The law ensures that people with disabilities can access the same information and perform the same tasks as people without disabilities when using government technology.

The 2018 Section 508 Refresh

In 2018, the U.S. Access Board issued a major refresh to Section 508 standards, making compliance clearer and more aligned with international standards. Key changes included:

• Harmonization with WCAG — The refresh adopted the Web Content Accessibility Guidelines (WCAG) 2.0 Level A and AA as the technical standard for web content
• Expanded scope — Requirements now explicitly cover public-facing content and specific categories of non-public-facing content used for official agency business
• ICT alignment — Standards harmonized with international accessibility requirements, making it easier for government-wide procurement of accessible technology
• Functional performance criteria — Updated requirements for how technology must work with assistive technologies

Current Technical Standards

Under the 2018 refresh, all electronic content—including web content, software, and digital documents—must conform to WCAG 2.0 Level A and AA. WCAG 2.2 is now the latest published version of the guidelines, and a legislative proposal to update Section 508's technical standard to WCAG 2.2 was introduced in 2024, though it did not advance.

Until Section 508 is formally amended, WCAG 2.0 Level A and AA remains the official requirement. However, agencies are increasingly encouraged to target WCAG 2.1 or 2.2 as best practice, since these newer versions address mobile accessibility, cognitive disabilities, and other accessibility-related gaps not fully covered in WCAG 2.0.

Who Must Comply With Section 508?

Section 508 applies specifically to federal agencies in the United States—it does not directly affect private organizations or other countries. However, the law's reach extends beyond federal departments themselves.

Direct Compliance Requirements

The following must comply with Section 508:

• All federal executive branch agencies
• Independent federal agencies
• The U.S. Postal Service
• Federal contractors developing ICT for government use
• Organizations receiving federal funding (under related Section 504 requirements)

Indirect Impact: Government Purchasing Power

The US government has enormous purchasing power, so many companies and organizations around the globe strive to be Section 508 compliant to qualify for federal contracts. Third-party vendors selling technology to federal agencies must demonstrate their products meet accessibility standards through formal documentation.

Even when Section 508 does not directly apply, websites in the United States may still be subject to other regulations like the ADA (Americans with Disabilities Act).

Section 508 vs. ADA: What's the Difference?

Both Section 508 and the ADA are US laws that enforce accessibility for people with disabilities, but they apply to different areas of society.

Section 508 is a federal procurement and technology law governing how federal agencies develop, buy, and use electronic and information technology. It applies only to federal agencies and their contractors.

The ADA is a civil rights law that prohibits discrimination against people with disabilities across various fields, including places of public accommodation (which courts have expanded to include websites). The ADA affects state and local governments, non-profit organizations, and private businesses.

Key Distinctions

• Scope: Section 508 covers federal agencies; ADA Title II covers state/local governments; ADA Title III covers private businesses
• Technical standards: Section 508 explicitly requires WCAG 2.0 Level AA; the ADA references WCAG in enforcement but hasn't codified a specific version for private businesses
• Enforcement: Section 508 uses administrative complaints and procurement requirements; the ADA primarily uses private lawsuits and DOJ enforcement

Section 504 vs. Section 508

There is another section under the Rehabilitation Act of 1973 that references accessibility: Section 504. Understanding the relationship between these laws helps organizations receiving federal funding.

Section 504 requires organizations that receive federal funding to provide people with disabilities equal access to participate in their programs and use their services. This includes higher education institutions, non-profits, schools, hospitals, mental health centers, and more.

While Section 504 does not expressly reference web accessibility, it specifies that agencies must provide auxiliary aids—such as braille, content with enlarged print, video captions, and other accommodations—to make information available to people with disabilities. The Section508.gov blog has clarified that accessibility for communications such as websites does fall under Section 504's requirements.

Section 508 Compliance Checklist

While Section 508 follows WCAG 2.0 standards, agencies need a practical framework for implementation. This checklist covers the basics of an accessible site—missing any of these elements signals potential non-compliance.

Perceivable Content

Provide alternatives for time-based media — Audio and video content must include captions, subtitles, audio descriptions, sign language interpretation, or transcripts. Live multimedia requires synchronized captions.

Include alternative text on images — All meaningful images need descriptive alt text that conveys the image's purpose and content. Decorative images should have null alt text (alt="") so screen readers skip them.

Include alternative text on video — Embedded videos need text descriptions explaining visual content not conveyed through audio.

Use accessible colors and contrast — WCAG 2.0 Level AA requires a contrast ratio of at least 4.5:1 for normal text and 3:1 for large text. Poor color combinations make content difficult for people with color blindness and low vision.

Operable Interfaces

Ensure keyboard navigation — All functionality must be accessible using only a keyboard. This is essential for people with motor disabilities who cannot use a mouse.

Provide skip navigation links — Enable users to bypass repetitive elements like navigation menus and jump directly to main content.

Avoid screen flickers — Content that flashes between 3 and 50 times per second can trigger photosensitive epilepsy. Avoid animations and videos with rapid flashing.

Avoid time limits on content — People with certain disabilities need more time to read, process information, and complete actions. If time limits are necessary, provide options to extend or disable them.

Understandable Content

Use clear language and instructions — Content should be readable and understandable by the target audience, with clear error messages and form labels.

Ensure predictable operation — Navigation and interactive elements should behave consistently across the site.

Robust Technology

Build websites to support assistive technology — Websites must work with screen readers, voice recognition software, and other assistive technologies. This requires proper HTML structure, ARIA labels, and semantic markup.

Ensure accessible data tables — Complex data tables need proper header associations so screen readers can convey relationships between cells. This is a common compliance gap agencies overlook.

Content Types Subject to Section 508

The following content must meet Section 508 accessibility requirements:

• Website content — All public-facing web pages and applications
• Non-public-facing content — Internal content used for official agency business, including intranet sites and internal applications
• Software — Desktop and mobile applications developed or procured by agencies
• Documents — PDFs, Word documents, presentations, and spreadsheets
• Multimedia — Video and audio content, including training materials
• Hardware — Self-service kiosks, telecommunications equipment, and other ICT devices

How to Test for Section 508 Compliance

There are several approaches to testing your agency's website and ICT against Section 508 standards:

Automated Testing

Automated testing tools like Acquia Web Governance validate websites against WCAG requirements efficiently and at scale. These tools can scan entire sites, identify machine-testable issues, and generate reports showing compliance status.

However, automated tools have limitations—they typically catch only 30-40% of accessibility issues and may generate false positives. Automated testing cannot evaluate human subjectivity, such as whether alt text is truly meaningful or whether content is understandable.

Manual Testing

Manual testing uses documented, consistent, repeatable processes based on testing methods outlined by Section508.gov. Manual testing catches issues automation misses:

• Testing with actual screen readers (JAWS, NVDA, VoiceOver)
• Keyboard-only navigation testing
• Evaluating the quality of alt text and captions
• Verifying logical reading order and content structure

Hybrid Testing

Hybrid testing combines automated and manual approaches—the most effective method for large, content-heavy websites. Automated testing uncovers errors at scale, while manual testing focuses on new content, high-priority pages, and issues requiring human judgment.

VPAT Documentation and Procurement

The Voluntary Product Accessibility Template (VPAT) is a critical document for Section 508 compliance, particularly in federal procurement.

What Is a VPAT?

A VPAT is a standardized document where vendors report how their product conforms to accessibility standards. Completed VPATs become Accessibility Conformance Reports (ACRs) that federal agencies use during procurement to evaluate whether third-party products meet Section 508 requirements.

Why VPATs Matter

Federal agencies must consider accessibility when procuring ICT. Vendors without current VPATs may be excluded from government contracts. A well-documented VPAT demonstrates:

• Which WCAG success criteria the product meets
• Any known accessibility limitations
• Planned remediation for non-conformant features

Organizations selling to the federal government should maintain up-to-date VPATs for all products and services.

How Much Does Section 508 Compliance Cost?

Compliance costs vary significantly based on the size and complexity of your digital presence, current accessibility status, and internal capabilities.

Typical Cost Factors

Initial audit costs — Professional accessibility audits range from $5,000 to $50,000+ depending on site size and depth of evaluation.

Remediation costs — Fixing identified issues may require developer time, content updates, and potentially redesigning inaccessible components. Complex sites may require $50,000 to $500,000+ in remediation work.

Ongoing monitoring — Annual accessibility monitoring and testing typically costs $10,000 to $50,000 for enterprise-level organizations.

Training — Accessibility training for content creators, developers, and procurement staff ranges from $2,000 to $20,000 depending on team size and depth.

Cost-Effective Approaches

Building accessibility into projects from the start is significantly more cost-effective than retrofitting existing systems. Agencies that integrate accessibility requirements into procurement, development workflows, and content creation processes avoid expensive remediation later.

Building a Section 508 Accessibility Program

Beyond auditing websites and ICT, agencies should build a comprehensive accessibility program to drive and maintain compliance. The Access Board and Section508.gov recommend agencies:

• Appoint a program manager — Designate someone to lead accessibility initiatives across the organization
• Develop an accessibility policy — Create documented standards and procedures for maintaining compliance
• Audit existing ICT — Assess current accessibility levels across all technology
• Provide training — Ensure teams understand accessibility requirements relevant to their roles
• Establish testing processes — Implement continuous testing and validation of accessibility
• Maintain documentation — Keep VPATs, audit reports, and compliance records current

Learn more about how to build a Section 508 accessibility program at Section508.gov.

Consequences of Non-Compliance

Failure to comply with Section 508 can result in:

• Administrative complaints — Individuals can file complaints with the agency or with oversight bodies
• Lawsuits — Legal action against agencies for discrimination
• Procurement delays — Technology investments may be delayed if accessibility requirements aren't met
• Contract issues — Vendors may lose federal contracts if products don't meet standards
• Brand and reputation damage — Non-compliance signals that an agency isn't serving all constituents equally

How Acquia Can Help

Acquia Web Governance's Web Accessibility Module audits your entire site for accessibility against WCAG 2.0, 2.1, and 2.2 (and subsequent updates to the guidelines).

Each audit scans your site for machine-testable issues, provides detailed reports for reviewing errors, gives targeted recommendations based on the guidelines, and shows compliance status across Levels A, AA, and AAA. Track and prove your accessibility compliance progress via reports in the History Center.

We also offer accessibility training to ensure your team is well-versed in both automated and manual remediation methods, enabling efficient and consistent improvement of your website's accessibility.

Acquia Web Governance provides free tools to complement your accessibility efforts:

• Color Contrast Checker — Test compliant color combinations for web design
• Accessibility Statement Generator — Create a public statement declaring your commitment to web accessibility