Comprehensive Analysis of Section 508 Compliance Requirements

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Learn everything about Section 508 compliance, accessibility 508 standards, requirements, testing and certification. Discover practical strategies, VPAT reports, and tools to make your digital content accessible and legally compliant with federal guidelines.

Introduction

According to the US Access Board (2023), Section 508 compliance requires that every federal agency ensure its technology can be used by people with disabilities. The guidelines apply to websites and software to multimedia content and electronic documents. It ensures equal opportunity to access the same information and services.

This article breaks down the legal framework of Section 508 along with practical steps for making digital content truly accessible. This research-backed guide helps you understand what compliance really means and how it can be implemented in the real world.

Understanding Section 508

What does it mean to be Section 508 compliant?

Being Section 508 compliant means that any digital tool or technology used by a federal agency can be accessed and used by people with disabilities. This ensures everyone has equal access regardless of their abilities. In practice, it involves following standards that make content readable by screen readers, navigable by keyboard, and understandable for all users (Educause, 2017).

Historical Context

Enacted in 1998, Section 508 was a significant amendment to the Rehabilitation Act of 1973. Its primary objective was to eliminate barriers in information technology. (U.S. General Services Administration, n.d.). It provided new opportunities for people with disabilities and encouraged the development of technologies that will help achieve these goals.

How can organizations make their digital tools accessible and fair for everyone?

Section 508 is all about making sure everyone can use websites, apps and digital content. But following all the rules can be tricky. Therefore, organizations trusted ADACP. We check your digital tools, fix accessibility issues, and train your team so everything meets Section 508 accessibility standards.  

Legal Framework and Standards

U.S. Access Board's Role

The U.S. Access Board (n.d.) is responsible for developing and maintaining accessibility standards for ICT. On January 18, 2017, the Access Board issued a final rule updating accessibility requirements covered by Section 508. These updated standards went into effect on January 18, 2018. Now Section 508 guidelines align more closely with international standards and technological advancements.

Key Standards and Guidelines

The Section 508 compliance standards are codified in 36 CFR Part 1194 and cover various aspects of ICT accessibility:

1194.21: Software applications and operating systems

1194.22: Web-based intranet and internet information and applications

1194.24: Video and multimedia products

These standards ensure accessibility of ICT to individuals. These guidelines provide aid accessible for design, development, and procurement processes.

Recent Trends in Section 508 Compliance

Section 508 compliance continues to develop with technology and user needs. Some key trends include:

• VPAT adoption: As of April 2025, vendors are increasingly providing detailed VPAT 2.5 reports. They facilitate easier accessibility evaluations for agencies aligning with updated standards like WCAG 2.2. For more information on the VPAT 2.5 update, you can refer to the News Section of ADACP about VPAT 2.5 Update: the Latest Accessibility Template.
• WCAG 2.2 influence: Many Section 508 updates now align with WCAG 2.2. The new updates introduced new success criteria to enhance accessibility to low vision users and individuals with cognitive impairments. New compliance rules even expand accessibility coverage for mobile devices.
• AI and automated testing tools: Emerging AI-powered tools can scan websites and applications for accessibility issues faster than traditional methods. This way organizations can stay compliant efficiently. Read more about the benefits of achieving 508 compliance testing in this blog [What is 508 Compliance Testing and Why does it matter?]

Following these updates makes sure your organization meets the rules and provides digital tools that are easy to use.

Conformance and Exceptions

Conformance Requirements

To achieve Section 508 compliance, agencies must ensure that their ICT meets the applicable standards. This involves:

• Conducting 508 Compliance Testing: Regular evaluations to identify and address accessibility barriers.
• Providing Accessible Alternatives: When full conformance is not feasible, agencies must provide accessible alternatives that offer equivalent access to information.

Exceptions to Compliance

Section 508 outlines specific exceptions where compliance may not be required:

• Undue Burden: If meeting the standards imposes significant difficulty or expense, compliance may be waived.
• National Security: Certain national security systems may be exempt from compliance requirements.

These exceptions are detailed in Section 508 §1194.3 and require thorough documentation and justification.

How do federal agencies test digital content for Section 508 compliance?

Federal agencies don’t usually test every website or application themselves. Instead, they rely on vendors to provide Section 508 compliance certification. This often comes in the form of accessibility reports, like a Voluntary Product Accessibility Template (VPAT®), which shows how a product meets the required standards.

Read more about VPATs and Section 508 compliance reporting in our detailed blog here:  [Do I Need a VPAT Accessibility Conformance Report for Section 508 Compliance?]

Benefits of Section 508 Compliance

Meeting Section 508 standards brings real benefits to organizations and their users.

1. Compliance ensures that all digital content is accessible.
2. Compliance promotes inclusivity and demonstrates a commitment to equal opportunity.
3. Accessible digital tools also improve the user experience for everyone.
4. Compliance lessens legal risks and reduces accessibility complaints by 50%.
5. Section 508 compliance keeps your organization legally protected while making your content accessible to everyone.

Practical Implementation Strategies

Policy Development

Agencies should develop and update policies to reflect the revised Section 508 standards. This includes:

• Incorporating Accessibility into Procurement: Make accessibility a priority from the very start. Include accessibility requirements clearly when drafting contracts or procurement documents. Make sure that every product or service purchased is usable by everyone. This approach ensures that accessibility is built in and not added later. Make your digital tools inclusive from day one.
• Training Staff: Empower your team to make accessibility a natural part of everything they do. ADACP offers hands-on Section 508 training for anyone involved in buying or maintaining digital tools. When your staff understand accessibility standards, they can build technology that works for everyone. Schedule a free consultation with us to get started on instructor-led accessibility training and 508 compliance testing.

Tools and Resources

Several tools are available to assist in achieving Section 508 compliance:

• Accessibility Requirements Tool (ART): According to Section508.gov (n.d.), the Accessibility Requirements Tool (ART) assists in identifying applicable Section 508 requirements for procurement documentation.
• VPAT (Voluntary Product Accessibility Template): Section508.gov (n.d.) states that the Voluntary Product Accessibility Template (VPAT®) is a document that provides information on how a product or service conforms to accessibility standards.

These resources are essential for agencies to assess and enhance the accessibility of their ICT.

Frequently Asked Questions About 508 compliance requirements

1. Who is responsible for ensuring Section 508 compliance?

Responsibility lies with federal agencies, which must ensure that their ICT is accessible to individuals with disabilities. This includes all levels of agency personnel involved in the development, procurement and maintenance of ICT.

2. What are the consequences of non-compliance?

Non-compliance can lead to legal challenges, delays in procurement processes, and potential loss of federal funding. It also undermines the agency's commitment to inclusivity and equal access.

3. How can agencies assess their ICT for accessibility?

Agencies can use tools like the Accessibility Requirements Tool (ART) and conduct regular accessibility assessments to evaluate their ICT. Additionally, they should review and update their policies to align with the revised Section 508 standards.

Conclusion

What many people see as just a legal requirement is actually much deeper. That’s why it’s better to learn everything about Section 508 and use it to grow your business safely and confidently.

If you want to become the preferred vendor in the industry then choose ADACP to be your accessibility partner. We have 13 years of experience helping organizations achieve compliance. Book a free consultation and you will see for yourself why we are the right choice for making your digital content Section 508 compliant.

References

U.S. Access Board. (2023). About the ICT Accessibility 508 Standards and 255 Guidelines. Retrieved from https://www.access-board.gov/ict/

U.S. General Services Administration. (n.d.). Section 508 of the Rehabilitation Act of 1973. Retrieved from https://www.section508.gov/manage/laws-and-policies/section-508-law

U.S. Access Board. (n.d.). Information and communication technology (ICT) standards and guidelines. Retrieved from https://www.access-board.gov/ict/

Section508.gov. (n.d.). Accessibility Requirements Tool (ART). Retrieved August 15, 2025, from https://www.section508.gov/art/

Section508.gov. (n.d.). Voluntary Product Accessibility Template (VPAT®). Retrieved August 15, 2025, from https://www.section508.gov/sell/vpat

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