Section 508 compliance checklist

Section 508 of the Rehabilitation Act requires US federal agencies to buy, build, and use accessible information technology. For vendors, that makes 508 conformance a procurement gate: bids without credible accessibility documentation lose to bids with it.

Since the 2018 refresh, the Revised 508 Standards incorporate WCAG 2.0 Level AA by reference, and agencies increasingly expect WCAG 2.1 AA in practice. This checklist covers what to verify and what paperwork buyers expect.

Who actually needs this

Directly: federal agencies. Practically: every company selling them technology, from SaaS platforms to document tooling, plus federally funded programs whose grants flow down the requirement. Many states mirror 508 in their own procurement (often called "little 508" laws), so conformance opens state and education markets too.

Documents count, not just websites

508 covers electronic documents, and PDF accessibility failures are among the most common findings in agency reviews: scanned pages with no text layer, missing tags, no reading order, forms without labels. If your deliverables include PDFs, they need the same attention as your web UI.

The paperwork buyers expect

A current VPAT/ACR (see our VPAT guide), an accessibility statement, and evidence that testing actually happened: what was tested, with which methods and assistive technologies, and when. Procurement reviewers are pattern-matched to spot unsupported "Supports" claims; dated scan records and specific remarks are what make your submission credible.

Compliance checklist

  • Confirm which standard your buyer cites (Revised 508 / WCAG 2.0 AA minimum; target 2.1 AA)
  • Run automated WCAG scans across representative product screens and key user flows
  • Manually test keyboard-only operation and screen-reader compatibility (NVDA or JAWS, plus VoiceOver)
  • Check electronic documents, especially PDFs: tags, reading order, text layer, form labels
  • Complete a VPAT/ACR with honest Supports / Partially Supports ratings and specific remarks
  • Publish an accessibility statement with a contact route for issues
  • Keep dated testing records; refresh the ACR after major releases and at least annually

Frequently asked questions

Does Section 508 apply to private companies?
Not directly, but it binds anyone selling ICT to federal agencies, and the requirement flows down through contracts and federal funding. If government or education revenue is on your roadmap, 508 conformance is a sales asset with a deadline: the RFP due date.
Is Section 508 the same as WCAG?
The Revised 508 Standards incorporate WCAG 2.0 Level AA by reference for web and software, and add requirements for hardware, documents, and support services. Meeting WCAG 2.1 AA comfortably covers the web portion.
What happens if a product is not 508 compliant?
Usually nothing dramatic and public; you just lose. Agencies choose conformant alternatives, and non-conformant incumbents get displaced at renewal. Complaints can also be filed against agencies, which then pressure their vendors.