What Does Section 508 Require of Federal Agencies?

Section 508 of the Rehabilitation Act requires each federal agency that develops, procures, maintains or uses information and communication technology (ICT) to make sure that federal employees and members of the public with disabilities have access to and use of it comparable to people without disabilities, unless that would impose an undue burden on the agency (29 U.S.C. 794d(a)(1)(A)). When an undue burden applies, the agency must provide the information and data through an alternative means of access (29 U.S.C. 794d(a)(1)(B)).

The standards. The U.S. Access Board issues the Section 508 standards at 36 CFR Part 1194. The requirements are in Appendices A, C and D to the part (36 CFR 1194.1), and compliance is mandatory for federal agencies.

Web content and documents. Electronic content, software and websites must conform to Level A and Level AA Success Criteria of the Web Content Accessibility Guidelines (WCAG) 2.0 (E205.4 and the related software and authoring tool provisions). For electronic content, this applies to public-facing content (E205.2) and to non-public-facing content that is official agency business communicated through one of the channels listed in E205.3.

Exceptions. The standards include limited exceptions:

• Legacy ICT that met the earlier standards and has not been altered on or after January 18, 2018.
• ICT used in national security systems.
• ICT a contractor acquires incidentally to a contract.
• ICT functions located in maintenance or monitoring spaces (E202.5).
• Undue burden or fundamental alteration, as determined by the agency under E202.6, with an alternative means of access provided.

Who it reaches. Section 508 applies to federal agencies, including the U.S. Postal Service.

Related topics. The FAQ on what compliance training is covers how training is documented. The news post on the Access Board's online complaint form renewal describes how the Board receives accessibility complaints.

The FAQ on what the U.S. Access Board is explains the agency's broader role.