Legal & Compliance

Section 508: Accessibility Requirements for US Federal Agencies

Section 508 of the Rehabilitation Act of 1973 (as amended) requires US federal agencies to make their electronic and information technology accessible to people with disabilities — covering federal agency websites, software, and digital services, and extending to technology federal agencies procure from vendors.

How Section 508 differs from ADA Title II and III

ADA Title II covers state and local government; ADA Title III covers private businesses. Section 508 covers a third category entirely: the federal government itself, as both a service provider and as a purchaser of technology. Its Revised 508 Standards (updated in 2017 to modernize the requirement) explicitly incorporate WCAG success criteria at Level A and AA by reference — meaning meeting WCAG AA substantively satisfies Section 508's core technical requirement.

Why this matters beyond federal agencies directly

Section 508's reach extends further than just federal agencies' own websites: any vendor selling technology products or services to a federal agency is typically required to demonstrate Section 508 conformance as part of the procurement process. This means companies with no direct legal obligation under Title II or III may still need to meet the same WCAG AA bar simply to be eligible to sell to federal government customers.

VPATs: how Section 508 compliance gets documented in procurement

Section 508 procurement is where the VPAT (Voluntary Product Accessibility Template) originated and is used most formally — a standardized document where a vendor states, criterion by criterion, how their product conforms to the relevant accessibility standards. See VPAT Explained for what a VPAT actually contains and how it's used; VPATs that started as a Section 508 procurement artifact are now commonly requested well beyond federal purchasing, including by private enterprise customers doing their own vendor due diligence.

Enforcement mechanism

Unlike ADA Title III's private-lawsuit-driven enforcement, Section 508 compliance is primarily enforced through the federal procurement and internal-agency-complaint process rather than broad private litigation — an individual with a Section 508 grievance against a federal agency generally files an administrative complaint with that agency (or, in limited cases, in federal court), a different mechanism than the demand-letter-and-lawsuit pattern common under Title III.

Practical takeaway

If your organization sells (or wants to sell) software or digital services to any part of the US federal government, Section 508 conformance — documented via a VPAT, benchmarked against WCAG 2.0/2.1/2.2 AA — is very likely to come up as a procurement requirement regardless of whether any other accessibility law directly applies to your business.

Common questions

What is Section 508?

A US federal law requiring federal agencies to make their electronic and information technology accessible to people with disabilities — covering agency websites, software, digital services, and the technology they procure from vendors.

What WCAG level does Section 508 require?

The Revised 508 Standards incorporate WCAG success criteria at Levels A and AA by reference, so conforming to WCAG AA substantively satisfies Section 508's core technical requirement.

Does Section 508 apply to private companies?

Not directly, but any vendor selling technology to a federal agency typically must demonstrate Section 508 conformance — often via a VPAT — as a procurement requirement.