- Section 508 requires federal agencies and contractors to make EIT (websites, software, documents) accessible.
- The 2017 refresh updated Section 508 to incorporate WCAG 2.0 Level AA by reference.
- Private companies selling to the federal government must provide a valid VPAT/ACR.
- Organizations receiving federal grants that procure IT with those funds must meet Section 508.
- complyTech produces Section 508 VPAT/ACR documentation starting at $1,500.
What Is Section 508?
Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. § 794d), as amended in 1998 and comprehensively updated in 2017, requires federal agencies and their contractors to ensure that electronic and information technology (EIT) — including websites, software applications, hardware, and electronic documents — is accessible to employees and members of the public with disabilities.
The 2017 "Section 508 Refresh" updated the technical standards to incorporate the Web Content Accessibility Guidelines (WCAG) 2.0 Level AA by reference, aligning federal accessibility requirements with international web standards.
Who Must Comply with Section 508?
Federal Agencies
All executive branch agencies, independent agencies, and the legislative and judicial branches must comply with Section 508 when developing, procuring, maintaining, or using EIT.
Federal Contractors
Private companies that develop, supply, or maintain electronic products and services for the federal government must ensure those products meet Section 508 standards.
Grant Recipients
Organizations receiving federal grants that use those funds to develop or procure IT must comply with Section 508 requirements for the funded technology.
Private Businesses (ADA, Not 508)
Private businesses not contracting with the federal government are governed by the ADA Title III, not Section 508. The technical standards overlap significantly but are legally separate.
Section 508 vs. ADA — Key Differences
| Feature | Section 508 | ADA Title III |
|---|---|---|
| Who | Federal agencies and contractors | Private businesses (public accommodations) |
| WCAG Reference | WCAG 2.0 Level AA (incorporated 2017) | WCAG 2.1 Level AA (court standard, 2025) |
| Enforcement | Agency complaints, contractor requirements | Private lawsuits + DOJ enforcement |
| VPAT Required | Yes — for federal procurement | Not required; recommended for defense |
| Applies to Websites? | Yes (federal and contractor sites) | Yes (all public-facing websites) |
Frequently Asked Questions
Section 508 of the Rehabilitation Act requires U.S. federal agencies and their contractors to make electronic and information technology accessible to people with disabilities. The 2017 refresh updated Section 508 standards to incorporate WCAG 2.0 Level AA by reference, covering websites, software, documents, hardware, and other EIT.
Section 508 applies to: (1) all U.S. federal agencies developing, procuring, maintaining, or using EIT; (2) federal contractors (through FAR regulations); (3) organizations receiving federal funding that procure IT with those funds. State and local governments have parallel obligations through Section 504 and, in some states, digital accessibility legislation.
Section 508 covers federal agencies and contractors — it's a procurement requirement. ADA Title III covers private businesses as public accommodations — it's a civil rights statute. Both use WCAG: Section 508 formally references WCAG 2.0 AA; ADA courts apply WCAG 2.1 AA as the current benchmark. For private businesses selling to the federal government, both simultaneously apply.
Section 508 applies to private companies indirectly through federal contracting. If your organization sells software, websites, or digital services to a U.S. federal agency — or if you develop/maintain IT for a federal agency — your products must meet Section 508 standards. This is enforced through contract requirements and the FAR (Federal Acquisition Regulation).
A VPAT (Voluntary Product Accessibility Template) — completed as an ACR (Accessibility Conformance Report) — is required when selling IT products or services to federal agencies. Agencies cannot purchase products without a current, valid VPAT/ACR on file. The VPAT must honestly represent the product's conformance status; a false VPAT can disqualify your company from future federal contracting.