Section 508 Compliance Checklist for Federal Government Agencies


Federal governments are required to comply with Section 508 of the Rehabilitation Act of 1973. It requires federal agencies to create, buy and use Information and Communication Technology (ICT) that’s accessible to people with disabilities, including website pages, software, applications, intranet sites and tools, and electronic documents.

Failure to comply with Section 508 represents a legal risk not only to the federal agency, but also affects the profitability of the vendor selling to the federal government.

Origins of Section 508 and WCAG

Accessibility legislation dates back to the 1970s, but advancements in technology particularly the internet, have made it necessary to revisit those laws. This is where Section 508 that prohibits barriers in information technology and WCAG that sets web accessibility standards come into play.

History of Section 508

In 1998, the Congress amended the Rehabilitation Act of 1973 to include Section 508, a federal law requiring all federal agencies to make their government information and communications technology (ICT) accessible to people with disabilities in the same manner that it’s available to everyone else. This includes telephones, software, websites, and multimedia. The law mandated that not only must these technologies be accessible for federal employees, but they must be accessible to the general public, too.

Latest updates to Section 508

The latest updates apply to the full range of public-facing content, including websites, documents, media, blog posts, and social media content of all federal agencies. The rule also specifies that the following types of non-public-facing content must comply with the latest requirements:

  • Emergency notifications
  • Initial or final decisions adjudicating administrative claims or proceedings
  • Internal or external program or policy announcements
  • Notices of benefits
  • Program eligibility
  • Employment opportunities or personnel actions
  • Formal acknowledgements or receipts
  • Questionnaires or surveys
  • Templates or forms
  • Educational or training materials
  • Web-based intranets

WCAG Guidelines

WCAG is an acronym that stands for Web Content Accessibility Guidelines. It is backed by the World Wide Web Consortium (W3C), the primary international web standards organization and it represents the future direction for web accessibility standards in the United States.

WCAG represents a higher, more explicit level of accessibility than even Section 508. While there is some overlap in the recommended criteria outlined by both, they do offer separate recommendations and requirements.

WCAG 2.0 provides three levels of compliance: A, AA, and AAA. Each level outlines a layer of checkpoints that gets deeper in terms of complexity.

  • Level A outlines the basic, bare minimum accessibility requirements that a web page must meet. A Level A site will not meet all the needs of people with disabilities, but it’s considered beneficial to a wide range of visitors.
  • Level AA addresses some of the biggest challenges users with disabilities face. A Level AA site will accommodate the needs of most people.
  • Level AAA outlines the highest standards of accessibility, which cover more advanced barriers some people with disabilities face. As noted in the WCAG guidelines themselves, it’s not necessary for all web pages to follow these criteria because some elements aren’t possible to implement for all types of content.

In addition to the conformance levels, WCAG 2.0 has four principles of accessibility, known as POUR. If your website fails to incorporate these principles, it’s considered inaccessible. The four principles of WCAG 2.0 are as follows:

Perceivable: The elements on the page have to detectable to everyone. Examples may include adjustable font sizes and alt-text descriptions for images.

Operational: Everyone must be able to interact with the website regardless of disability.

Understandable: Users must be able to understand the content and the instructions on the site.

Robust: The content must be accessible on all kinds of devices. The website must be compatible with assistive technologies.

Section 508 Compliance Checklist

Perceivable – Web content is made available to the senses – sight, hearing, and/or touch.

Guidelines: Provide text alternatives for any non-text content such as images, form buttons, form input labels, embedded multimedia, transcripts for audio and video content, captions, etc.

Operable – Interface forms, controls, and navigation are operable.

Guidelines: Make the page functionality available to users with disabilities using the keyboard. The keyboard focus is never locked or trapped at one particular page element.

Understandable – Information and operation of user interface must be understandable.

Guidelines: Identify the language of the page using the correct HTML attribute. Provide expansion for unfamiliar abbreviations the first time it occurs on a page.

Robust – Content must be robust enough that it can be interpreted by a wide variety of user agents, including assistive technologies.

Guidelines: Provide correct reading order, identify the language, alt text for images, and semantic structure to give people with disabilities equal access to information.

Web accessibility checkers

Web accessibility checkers are web apps or browser add-ons that look for major barriers that could prevent someone with a disability from interacting with and understanding a website. These tools identify areas of improvement that would help make a website accessible to the greatest number of visitors.

A web accessibility checker will evaluate aspects of the web content against WCAG and Section 508. For example, WCAG contrast checkers determine if a website has the appropriate contrast levels; others search for audio descriptions, alt-text for images, and properly labelled headers, all of which make it easier for people with disabilities to navigate and consume web content.

The following are examples of some of the most popular website checkers, according to accessibility experts:

  • Axe helps prioritize the issues it finds and is considered one of the most in-depth tools.
  • Tota11y visually explains each violation, making it a prime beginner option.
  • Functional Accessibility Evaluator (FEA) provides a performance status on each issue it detects.
  • AChecker identifies known problems, likely problems, and potential problems.
  • WAVE evaluates the website from a technical perspective and is best suited for designers and developers.

Section 508 exceptions

To determine if a federal agency can claim an exemption, the ICT must fall under one of the following categories: legacy, national security system, federal contract, maintenance location, undue burden, or best meets exceptions.

Legacy ICT

ICT that met the standard as it was outlined before January 18, 2018, and that has not been subsequently changed in a way that affects interoperability or the user interface, is not required to meet the Revised 508 Standards.

National security system

If the ICT is part of a national security system as determined by 40 U.S.C. 11103(a), it may qualify as an exception. Examples include ICT involving intelligence activities and equipment associated with weapons systems.

Federal contract

This exception applies if a contractor or vendor is the owner of the ICT and is the only party accessing and interacting with it. If ownership switches to the federal government, or if the government procures it, then this exception doesn’t apply.

Functions located in maintenance or monitoring spaces

If the ICT is located in an environment that’s only serviced by maintenance or repair personnel, then it may meet this exception. The ICT must have physical controls (status indicators or operable parts) in order to qualify.

Undue burden

If adhering to the 508 standards would cause an undue burden or alter the nature of the ICT, compliance isn’t required. However, the U.S. General Services Administration recommends consulting with legal experts who have experience with undue burden claims.

Best meets

If a business requires ICT that may not be fully accessible, but there are no other commercially available options, then the technology must meet the 508 Revised Standards to the best of its ability.

If a federal agency believes its ICT falls under one of these exceptions, it may need formal approval from an agency representative to file a claim.

Tips to ensure full compliance with Section 508

Use clear visuals: Make sure to use clear visuals, whether those are images or documents. The image, for instance, should be easy to search and have all the proper elements such as alt text (especially useful for people who are colour blind)

Supplement your audio and video: For maximum accessibility, sync all captions, and make sure that the audio transcripts and video files include transcript elements.

Make sure you are keyboard-friendly: A website must be designed for easy navigation with the keyboard by including headings, lists, and other elements.

Provide accessible forms and files: Users with screen readers need to be given access to any form and be able to submit it on any federal agency website. The same applies to documents and PDFs, as well as any other form or file format which includes fulfilling.

“Skip Navigation” options: Repetitive elements can be sorted with “Skip Navigation” options in the menu, allowing users to get to the main content of the pages.

Create tables, lists, and fillable forms: Using tables, lists, and fillable forms need to be consistently done.

Optimize the background: No matter how great the website background is, it may hide the form for some people, not be accessible, or have too much contrast. Try to avoid text boxes and complex backgrounds with too much contrast.

Avoid encoding errors: Fonts that are not regular may trigger some special characters, which results in encoding errors on the site. Make sure to optimize this in each version and make it accessible for people with disabilities.

Keep it simple with special effects: If there are special effects applied to text, it will fail to meet standard 508 compliance. Make sure to eliminate any moving, flashing, or blinking text sections.

Use image alt text consistently: Alt text should be used in every graphic element, whether it’s an image, diagram, photo, etc.

Provide unique hyperlink labels: The text that links to another web page is known as hyperlinks. These links need to be quite descriptive (instead of “click here,” for example).

Avoid poor colour and contrast combinations: People suffering from colour blindness won’t be able to distinguish certain colors on a website. To achieve 508 compliance, use text and page background colors that have a significant level of brightness and contrast.

Create online fillable forms: Forms are always appreciated, especially when they are electronic and designed to be completed online.

codemantra’s accessibilityInsight™, is designed to assist state and local government agencies with their federal government mandated 508 compliance requirements. The AI-powered platform can help reduce the amount of time needed to attain 508 compliance and WCAG AA standards.

The multi-phase document accessibility program involves:

  1. Assess: Complete compliance assessment and detailed reporting.
  2. Plan: Prioritization of assets and determination of internal, external, or hybrid remediation approach.
  3. Document processing: Machine-learning and AI-assisted processing merged with human-assisted review and alt text writing.
  4. Report: Confirm PDF U/A and WCAG compliance and generate a compliance report.


Federal governments set the bar when they comply fully with Section 508 requirements. This means organizations have to follow suit and incorporate accessibility from the beginning to avoid the risk of lawsuits and hefty fines.