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Glossary · Accessibility term

Section 508

Section 508 is the US law requiring federal departments and agencies, plus the Postal Service, to make their digital products accessible. Of its own force it reaches nobody else. It does not follow federal funding, which is Section 504's job, and it does not bind suppliers directly either. It reaches them through purchasing, so if you want government contracts, procurement will ask for proof, usually a completed VPAT. The thing worth knowing about the standard itself is its age. Section 508 has incorporated WCAG 2.0 Level A and AA since January 2018 and still does, while the ADA Title II rule and the health department's Section 504 rule both name WCAG 2.1 AA. A vendor selling to a federal agency and a state agency is testing against two versions of the same standard for two arms of the same government.

In practice

The obligation lands on the agency rather than on you. It has to buy, build and maintain accessible technology, and the standard behind that incorporates WCAG 2.0 Level A and AA by reference rather than paraphrasing it. So the criteria are the ones you already know, at a version that stopped moving in January 2018.

Sell software or a digital service to a federal agency and procurement will ask for an Accessibility Conformance Report. The Revised Section 508 edition of the template is the obvious one to complete, and the International edition carries those same standards alongside the European and WCAG ones, so it answers this question too. Taking federal money does not pull you into Section 508 either. Section 504 is the provision that follows funding, and each agency writes its own rule under it. The health department's names WCAG 2.1 AA, which binds the recipients that department funds rather than everyone who takes a federal dollar.

Documents and desktop software get a genuine carve-out that almost nobody knows about. Non-web documents and non-web software are excused from four criteria outright. Bypass blocks, multiple ways, consistent navigation and consistent identification. That is the answer to whether a federal agency's PDF needs a skip mechanism. It does not. The rest of the standard still applies, through a substitution rule that swaps the word document or software for web page throughout. That is how a specification written for web pages ends up governing a kiosk.

If you maintain federal systems, the sequencing trap is worth knowing before you plan. Existing technology that met the earlier Section 508 standards and has not been altered on or since January 18, 2018 does not have to be brought up to the current standard. Alteration has a meaning here rather than covering any edit. It is a change affecting interoperability, the user interface, or access to information and data, so correcting a typo is not one and the components you did change are what comes in.

There is an escape route, and it costs something. Undue burden and fundamental alteration are both available, and both require the responsible official to document the basis in writing and to provide access by some alternative means. Where nothing on the market conforms, the agency buys the product that best meets the standards, judged against its own business needs, and it documents why and supplies access another way.

Why it matters

It is the reason VPATs exist, and it is a large part of why accessibility comes up in enterprise sales at all. Its influence runs well past the agencies it binds, through state statutes modeled on it and through the accessibility condition attached to federal assistive-technology grants. It also matters to anybody in the public who is stuck. Any individual with a disability may file an administrative complaint that a federal department or agency is not complying, and the statute's civil action route is written around procurement rather than around every failing. That right is not limited to federal employees, which is the part most often assumed and wrong.

The version gap, in practice

A vendor selling the same product to a federal agency and to a state government is reporting against WCAG 2.0 for one and WCAG 2.1 for the other. Test to 2.2, because W3C states that content conforming to it also conforms to both, and answer either question from one body of work rather than running two. One row still needs its own thought. 2.2 dropped the parsing criterion, so a report written against an older obligation may need to say something about it separately.

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