Section 508 Compliance Checklist

Section 508 of the Rehabilitation Act requires federal agencies and organizations receiving federal funding to make their information and communication technology (ICT) accessible to people with disabilities. Since the 2017 refresh, Section 508 has been aligned with WCAG 2.0 Level AA, but it goes further -- covering software, hardware, and procurement in addition to web content.

What Section 508 Covers

Unlike the ADA, which is a broad civil rights law, Section 508 is a specific set of technical requirements. It applies to:

• Web content and applications -- Public-facing and internal websites, web apps, intranets
• Electronic documents -- PDFs, Word documents, presentations, spreadsheets
• Software applications -- Desktop and mobile software
• Hardware -- Kiosks, copiers, and other physical ICT
• Multimedia -- Video and audio content

Who Must Comply

• Federal agencies (all three branches of government)
• Federal contractors and subcontractors
• Organizations receiving federal funding
• State agencies receiving federal financial assistance

The 2017 Refresh

The Section 508 Standards were updated in January 2018 to incorporate WCAG 2.0 Level AA. This means that for web and electronic content, the requirements are functionally identical to WCAG 2.0 AA success criteria. The key changes were:

• Adoption of WCAG 2.0 AA as the baseline for web and electronic content
• Functional performance criteria for situations where WCAG alone is insufficient
• Updated Voluntary Product Accessibility Template (VPAT) format

Document Accessibility Checklist

Structure and Navigation

• Document has a descriptive title in the metadata
• Document language is specified (e.g., English)
• Headings are used and follow a logical hierarchy (H1, H2, H3) without skipping levels
• Reading order matches the visual layout when accessed by assistive technology
• Table of contents or bookmarks are provided for documents longer than 5 pages
• Page numbers are present and accurate

Images and Media

• All images have meaningful alternative text
• Decorative images are marked as artifacts (not read by screen readers)
• Complex images (charts, diagrams) have extended descriptions
• Color is not the only means of conveying information
• Sufficient color contrast (4.5:1 for normal text, 3:1 for large text)

Tables

• Data tables have header rows and/or columns identified
• Table headers use scope attributes (row or column)
• Tables are not used for layout purposes
• Complex tables include a summary or caption

Forms

• All form fields have associated labels
• Required fields are clearly indicated (not by color alone)
• Error messages are descriptive and programmatically associated with the field
• Tab order follows a logical sequence
• Form instructions are provided before the form, not only after

Multimedia

• Videos have accurate captions
• Audio content has transcripts
• Video descriptions (audio descriptions) are provided for visual-only content
• Media players are keyboard accessible

Links and Navigation

• Link text is descriptive (no "click here" or "read more" without context)
• Links are visually distinguishable from surrounding text (not by color alone)
• Skip navigation links are provided where applicable

Procurement: VPATs and ACRs

When purchasing ICT products, federal agencies must evaluate accessibility. The primary tool for this is the Voluntary Product Accessibility Template (VPAT), which vendors complete to produce an Accessibility Conformance Report (ACR).

Evaluating a VPAT

A VPAT is only as good as its accuracy. When reviewing one:

1. Check the date -- VPATs older than 12 months may not reflect the current product
2. Look for specifics -- Vague claims like "partially supports" without explanation are a red flag
3. Verify claims -- Test critical functionality with a screen reader
4. Check which version -- Ensure the VPAT covers the specific version you are procuring

Writing Accessibility Requirements

Include accessibility requirements in your procurement language:

• Reference the Revised Section 508 Standards
• Specify WCAG 2.0 AA (or 2.1 AA) conformance
• Require a current VPAT/ACR
• Include accessibility testing in acceptance criteria
• Define remediation timelines for identified issues

Enforcement and Consequences

Section 508 compliance is enforced through:

• Agency self-assessment -- Agencies must report on their compliance
• Complaints -- Individuals can file complaints with the agency
• Lawsuits -- Federal employees and members of the public can sue agencies for non-compliance
• GSA oversight -- The General Services Administration monitors government-wide compliance

Non-compliance can result in legal action, loss of contracts, and reputational damage.

Getting Started

1. Audit your existing content -- Use automated tools to identify the biggest issues
2. Prioritize public-facing content -- External websites and documents are the highest risk
3. Train your team -- Everyone who creates content should understand the basics
4. Build accessibility into your process -- It is far cheaper to create accessible content from the start than to remediate it later
5. Use Adaline -- Upload your documents to get an instant compliance score and auto-remediation

The most important thing is to start. Perfect compliance is a journey, not a destination.