Section 508 Compliance: A Guide for Government Contractors

Section 508 of the Rehabilitation Act requires federal agencies to make their electronic and information technology (ICT) accessible to people with disabilities. If you sell to or contract with the federal government, Section 508 compliance is not optional.

The current Section 508 standards (updated in 2018) incorporate WCAG 2.0 Level AA for web-based content. This alignment means that meeting WCAG 2.0 AA for your web content largely satisfies the Section 508 web requirements. However, Section 508 extends beyond websites to cover software, hardware, telecommunications, and electronic documents.

A Voluntary Product Accessibility Template (VPAT) is the standard document used to communicate your product's conformance with Section 508. Procurement officers review VPATs when evaluating technology purchases. An accurate, detailed VPAT can be the difference between winning and losing a government contract.

The VPAT should document conformance with the Revised Section 508 Standards, which include: WCAG 2.0 Level A and AA criteria (for web and software), functional performance criteria (for users with various disabilities), and hardware-specific requirements (if applicable).

Common areas where products fail Section 508 testing include: forms without proper labels, images without alt text, PDFs generated without accessibility structure, video content without captions, and custom widgets lacking keyboard support and ARIA attributes.

Enforcement happens through procurement, complaints, and lawsuits. Federal agencies can reject products that fail to meet Section 508 standards. The Access Board investigates complaints, and individuals can file lawsuits under the Rehabilitation Act. Recent enforcement actions have increased scrutiny on both agencies and their vendors.