WebBuilding

Laws and standards

Section 508

Summary

Section 508 is the part of the U.S. Rehabilitation Act of 1973 that requires federal agencies to make the electronic and information technology they develop, buy, maintain or use accessible to people with disabilities. Added in 1986 and rewritten on August 7, 1998, it works through standards from the U.S. Access Board, first published on December 21, 2000 and refreshed on January 18, 2017 to use WCAG 2.0 Levels A and AA. It covers federal websites and the technology agencies buy, not private companies' own websites.

What Section 508 is

Section 508 is one section of the Rehabilitation Act of 1973, a U.S. federal disability rights law. It is codified, meaning placed in the official U.S. Code, at 29 U.S.C. 794d under the heading “Electronic and information technology.”1

The law applies to federal departments and agencies, including the U.S. Postal Service. When they develop, procure, maintain or use electronic and information technology, they must give federal employees and members of the public who have disabilities access comparable to what people without disabilities get, unless that would impose an “undue burden.”1

Even when meeting the standards would be an undue burden, the agency still has to provide the information by another means that the person can use.1 National security systems are outside the law.1

On the web, this covers federal websites, online forms, documents, videos and web applications. It stops at the government’s edge. The U.S. Access Board, the federal agency that writes the technical standards, says of the law: “It does not apply to web pages of private industry.”2

The rules that spell out what “accessible” means are federal regulations at 36 CFR part 1194.3 Since a 2017 update they use the W3C‘s Web Content Accessibility Guidelines (WCAG) 2.0, Levels A and AA, for web pages and electronic documents.4

Several agencies share the work. The Access Board issues the standards. The General Services Administration (GSA) and the Access Board give technical help to agencies and the public. The Attorney General reports to the President and Congress on how well agencies comply.1

From 1973 to the 1998 rewrite

The Rehabilitation Act, Public Law 93-112, is dated September 26, 1973. Its Title V, headed “Miscellaneous,” ran from Section 500 to Section 504. Those sections covered federal employment of people with disabilities, the Architectural and Transportation Barriers Compliance Board (today’s U.S. Access Board), employment under federal contracts and nondiscrimination under federal grants.5

Section 504 is the broader civil rights rule. It bars disability discrimination in “any program or activity receiving Federal financial assistance” and in programs run by federal agencies or the Postal Service.6 Section 508 is narrower: it covers the technology the federal government itself builds, buys and uses.1

Section 508 was added to the act on October 21, 1986, by Public Law 99-506.1 In its early form it dealt with accessibility guidelines for electronic equipment.1 A 1992 amendment rewrote the section, with provisions that had the GSA adopt guidelines for federal purchasing of electronic equipment.1

The version in force today began on August 7, 1998, when the President signed the Workforce Investment Act of 1998, which included the Rehabilitation Act Amendments of 1998.7 That law replaced the whole section. It told the Access Board to issue enforceable standards within 18 months, required agencies to evaluate their own technology, and created a right to file complaints.1

A 2000 amendment changed the starting point for enforcement. Complaints could be filed from six months after the Access Board published final standards, and only about technology bought at least six months after that publication.1

The first standards, 2000 to 2001

The Access Board convened a 27-member advisory committee, the Electronic and Information Technology Access Advisory Committee, in September 1998. It issued a proposed rule on March 31, 2000, and took public comments until May 30, 2000.7

The final Electronic and Information Technology Accessibility Standards appeared in the Federal Register on December 21, 2000, as 36 CFR part 1194, with an effective date of February 20, 2001.7 The rule said complaints and lawsuits could be filed six months after its publication.7

The rule had separate sections for different kinds of technology. One covered software and operating systems. Another, Section 1194.22, covered “web-based intranet and internet information and applications” in 16 lettered provisions, (a) to (p).7

The board based those web provisions on WCAG 1.0 without adopting it outright. Provisions (a) to (i) used wording recommended by the W3C’s Web Accessibility Initiative or did not differ in substance from WCAG 1.0. Provisions (l) to (p) differed and generally asked for more. The board left out four of WCAG 1.0’s priority one checkpoints.7

The Federal Acquisition Regulation (FAR), the rulebook for federal purchasing, was amended to match on April 25, 2001. The change took effect on June 25, 2001, and applied to contracts awarded on or after that date.8 The Justice Department later wrote that Section 508 “became enforceable” in late June 2001.9

The 2017 refresh

The statute tells the Access Board to review its standards from time to time and amend them as technology changes.1 The board organized an advisory committee, known as TEITAC, on July 6, 2006, to help update them, and issued a proposed rule on February 27, 2015.4

The final rule was published on January 18, 2017. It updated the Section 508 standards together with the guidelines for Section 255 of the Communications Act, which covers telephones and other telecommunications equipment, and combined both in 36 CFR part 1194.34

The board said the change would “replace the current product-based approach with requirements based on functionality.”3 It also aligned the rules with EN 301 549, the European standard for accessible information and communication technology, where possible, so that products can meet both without conflict.3

The rule became effective on March 20, 2017, and agencies had to comply with the revised Section 508 standards from January 18, 2018.3 Section508.gov, the GSA’s site for federal accessibility staff, gives January 18, 2018 as the date the rule “went into effect,” which matches the compliance date rather than the Federal Register’s effective date.10

The refresh replaced the old term “electronic and information technology” (EIT) with “information and communication technology” (ICT). The FAR switched to the new term in 2021.11 ICT is defined broadly, with examples that include computers, kiosks, software, websites, videos and electronic documents.12

The board’s cost analysis, in 2017 dollars over 2018 to 2027 with a 7% discount rate, estimated under its expected scenario annualized costs of $172.8 million for federal agencies and annualized benefits of $72.4 million for federal agencies and some members of the public.3 On January 22, 2018, the board issued a correction that restored provisions on access for TTYs, or text telephones.4

What the rules require of web content

All public-facing electronic content must conform.12 Content that is not public facing has to conform only when it is official agency business in one of nine categories:12

  • emergency notifications;
  • initial or final decisions on administrative claims or proceedings;
  • internal or external program or policy announcements;
  • notices of benefits, program eligibility, employment opportunities or personnel actions;
  • formal acknowledgements of receipt;
  • survey questionnaires;
  • templates and forms;
  • educational or training materials; and
  • intranet content designed as a web page.

Covered content must meet the “Level A and Level AA Success Criteria and Conformance Requirements in WCAG 2.0.”12 Non-web documents, such as a word processing file or a PDF, are excused from four WCAG 2.0 criteria written for sets of web pages: Bypass Blocks, Multiple Ways, Consistent Navigation and Consistent Identification.12

WCAG 2.0 is the W3C Recommendation dated December 11, 2008.4 The W3C has since published WCAG 2.1 and 2.2, and states that “content that conforms to WCAG 2.2 also conforms to WCAG 2.0 and WCAG 2.1.”13 As of October 2026, the eCFR text of part 1194 still names WCAG 2.0.12

Where the technical rules do not address a feature, functional performance criteria apply. They are also used to judge an alternative design.3 The criteria describe nine groups of users: people without vision, with limited vision, without perception of color, without hearing, with limited hearing, without speech, with limited manipulation, with limited reach and strength, and with limited language, cognitive and learning abilities.4

The standards list general exceptions:12

  • Legacy ICT. Existing technology that met the earlier standard and has not been altered since January 18, 2018 does not have to be updated.
  • National security systems. These are outside the standards.
  • Incidental contractor items. Technology a contractor acquires only to carry out a contract does not have to conform.
  • Maintenance spaces. Controls in spaces used only by service staff are exempt.
  • Undue burden or fundamental alteration. The agency must document the reason in writing and offer an alternative means of access.
  • Best meets. When no conforming product is on the market, the agency buys the one that best meets the standards and documents its market research.

Buying technology: the FAR and conformance reports

The statute requires the FAR Council to update the FAR, and agencies to update their purchasing policies, within six months after the standards are published or revised.1 The FAR rule for the refreshed standards, FAR Case 2017-011, was published on August 11, 2021 and took effect on September 10, 2021.11

The 2021 rule points purchasing requirements to the standards at 36 CFR 1194.1, requires acquisition plans to name the standards that apply and any exceptions, and carries over the legacy rule for technology bought on or before January 18, 2018. It adds no new contract clause.11

The rule applies to contractors and subcontractors of every size. The agencies estimated that about 22,809 contractors supply ICT subject to Section 508, about 12,845 of them small businesses. The requirements also apply to purchases at or below the simplified acquisition threshold and to commercial items.11

To show how a product measures up, vendors commonly fill in the Voluntary Product Accessibility Template (VPAT), a free form published by the Information Technology Industry Council (ITI). It comes in four editions: one for the Revised Section 508 standards, one for EN 301 549, one for WCAG, and an international edition that combines all three.14

ITI’s words: “Once completed, the VPAT with documented testing results is referred to as an Accessibility Conformance Report (ACR).” As of October 2026, the current version is VPAT 2.5Rev, dated April 2025.14

Enforcement and how agencies measure up

A person with a disability can file a complaint with the agency that is said to be out of compliance. The agency handles it under the complaint procedures it uses for Section 504 in federally conducted programs.1 Under the heading for civil actions, the law also applies the remedies, procedures and rights of 29 U.S.C. 794a(a)(2) and 794a(b) to people who file complaints.1

The 1998 law asked the Attorney General for reports every two years on agency compliance.1 The Justice Department’s September 2012 report, based on fiscal year 2010 data, found that 70% of agency components had accessibility policies for website development and that nearly 58% routinely evaluated and fixed their websites.9

A new reporting duty arrived on December 29, 2022, in Section 752 of the Consolidated Appropriations Act, 2023, codified at 29 U.S.C. 794d-1. It requires the Office of Management and Budget (OMB) to set evaluation criteria, agencies to test and report, and the GSA to send Congress an annual compliance report that is also posted publicly.15

The first of these, the FY 23 Governmentwide Section 508 Assessment, came out in December 2023. It drew on self-reported data from 249 entities that the GSA did not verify. Of the 119 entities that submitted results for their ten most viewed public internet pages, 22% of those pages fully conformed. For the top ten intranet pages, reported by 91 entities, the figure was 25%.16

OMB followed with memorandum M-24-08 on December 21, 2023, signed by OMB Director Shalanda D. Young.17 It rescinded four earlier OMB memos, from 2005, 2007, 2010 and 2013.17 Its main requirements:17

  • every agency runs a Section 508 program with a named program manager;
  • agencies post or update an accessibility statement on all agency websites within 90 days, with a way for the public to report problems;
  • HTML is the default format for online content, with PDF and DOCX files discouraged;
  • agencies use automated testing tools in combination with targeted manual testing, such as the Trusted Tester process; and
  • agencies validate vendors’ Section 508 conformance documentation, such as accessibility conformance reports, before buying.

As of October 2026, Section508.gov still lists M-24-08 among current OMB policies.10 The site points agencies to the ICT Testing Baseline and to the Trusted Tester training and certification program for consistent test results.18

On March 5, 2026, the Access Board announced that the GSA had published its third annual report, the FY 2025 assessment.19 It used responses from 212 agencies, parent agencies and components, and found an average conformance score of 1.96 on a 5-point scale. Fewer than half of agencies’ most viewed or used ICT assets fully conformed, about half of agencies did not routinely test for accessibility, and fewer than 30% almost always verified ICT deliverables for Section 508 conformance.20

The GSA says FY 2025 “establishes a new baseline” because of significant changes to the assessment criteria, which OMB developed.21 The Access Board summarized the finding that the federal government “continues to fall short of its legal and statutory obligations.”19 The report asks Congress to align the reporting duties in 29 U.S.C. 794d and 794d-1.20

Timeline

  1. Access Board announces the GSA's FY 2025 Governmentwide Section 508 Assessment19
  2. OMB issues memorandum M-24-08 on digital accessibility and Section 50817
  3. GSA sends Congress the first annual Governmentwide Section 508 Assessment16
  4. Section 752 of the Consolidated Appropriations Act, 2023 requires annual compliance reports15
  5. FAR rule adopts the refreshed standards for federal purchasing, effective September 10, 202111
  6. Access Board issues a correction restoring TTY access provisions4
  7. Agencies must comply with the revised Section 508 standards3
  8. Access Board publishes the refreshed ICT standards, based on WCAG 2.0 A and AA3
  9. Access Board issues the proposed rule to refresh the standards4
  10. Access Board organizes the TEITAC advisory committee to update the standards4
  11. FAR rule takes effect for contracts awarded on or after this date8
  12. First Section 508 standards published as 36 CFR part 11947
  13. Workforce Investment Act of 1998 rewrites Section 5087
  14. Public Law 99-506 adds Section 508 to the Rehabilitation Act1
  15. Rehabilitation Act of 1973, Public Law 93-1125

What it means for your website

This section is general information, not legal advice. For a decision about your own site or contract, talk to a lawyer who works on accessibility law.

  • A private business website is not a Section 508 site. The Access Board says the law does not apply to private industry’s web pages.2 Other laws may still reach your site, most often the Americans with Disabilities Act. Our guide to U.S. website laws covers the main ones.
  • Selling to federal agencies changes that. If you sell software, a web app, hosted services, documents or training videos to an agency, the FAR’s Section 508 rules apply to contractors of every size.11 Expect to be asked for an Accessibility Conformance Report, usually built on the VPAT 508 edition.14 OMB tells agencies to validate vendor conformance documentation before buying.17
  • Building for an agency, consider WCAG 2.2 AA. The legal floor is WCAG 2.0 Level A and AA, and the W3C says WCAG 2.2 conformance also covers 2.0.1213 Count the PDFs, forms and training files too: the standards apply to them, not only to web pages.12
  • Federal grants are usually a Section 504 question. Section 504 covers programs that receive federal financial assistance.6 If your organization gets a grant, ask the funding agency which accessibility rules come with it.
  • Test with people and tools. OMB tells agencies to combine automated scans with manual testing.17 Try every page with a keyboard alone, check CSS color contrast, and test menus and forms built with JavaScript in more than one web browser.
  • Check your platform. On a website builder, confirm that you can set alt text, form labels and heading levels. We build on WordPress every week: WordPress expects its core software and official plugins to meet WCAG 2.2 Level AA, but that promise does not cover every theme or plugin you add, so test them.22

If you also sell in Europe, the European Accessibility Act is a separate law with its own rules. Our glossary entry on web accessibility explains the basic terms, and our WordPress review covers what to check before you pick a theme.

See also

References

  1. 29 U.S.C. 794d: Electronic and information technology (United States Code, 2023 edition). U.S. Government Publishing Office, govinfo.gov. accessed October 22, 2026.
  2. Rehabilitation Act of 1973. U.S. Access Board. accessed October 22, 2026.
  3. Information and Communication Technology (ICT) Standards and Guidelines, final rule, 82 FR 5790. Architectural and Transportation Barriers Compliance Board, Federal Register. 2017-01-18. accessed October 22, 2026.
  4. Information and Communication Technology (Revised 508 Standards and 255 Guidelines). U.S. Access Board. accessed October 22, 2026.
  5. Public Law 93-112, Rehabilitation Act of 1973, 87 Stat. 355. U.S. Government Publishing Office, govinfo.gov. 1973-09-26. accessed October 22, 2026.
  6. 29 U.S.C. 794: Nondiscrimination under Federal grants and programs (United States Code, 2023 edition). U.S. Government Publishing Office, govinfo.gov. accessed October 22, 2026.
  7. Electronic and Information Technology Accessibility Standards, final rule, 65 FR 80500. Architectural and Transportation Barriers Compliance Board, Federal Register. 2000-12-21. accessed October 22, 2026.
  8. Federal Acquisition Regulations; Electronic and Information Technology Accessibility (FAR Case 1999-607), 66 FR 20894. Department of Defense, General Services Administration and NASA, Federal Register. 2001-04-25. accessed October 22, 2026.
  9. Section 508 Report to the President and Congress: Accessibility of Federal Electronic and Information Technology. U.S. Department of Justice, Civil Rights Division. 2012-09. accessed October 22, 2026.
  10. IT Accessibility Laws and Policies. General Services Administration, Section508.gov. 2026-10. accessed October 22, 2026.
  11. Federal Acquisition Regulation: Section 508-Based Standards in Information and Communication Technology (FAR Case 2017-011), 86 FR 44229. Department of Defense, General Services Administration and NASA, Federal Register. 2021-08-11. accessed October 22, 2026.
  12. 36 CFR Part 1194: Information and Communication Technology Standards and Guidelines. Electronic Code of Federal Regulations, ecfr.gov. accessed October 22, 2026.
  13. Web Content Accessibility Guidelines (WCAG) 2.2. World Wide Web Consortium (W3C). 2024-12-12. accessed October 22, 2026.
  14. Voluntary Product Accessibility Template (VPAT). Information Technology Industry Council (ITI). accessed October 22, 2026.
  15. 29 U.S.C. 794d-1: Reports on accessibility of electronic information to individuals with disabilities (United States Code, 2023 edition). U.S. Government Publishing Office, govinfo.gov. accessed October 22, 2026.
  16. FY 23 Governmentwide Section 508 Assessment. General Services Administration, Section508.gov. 2023-12. accessed October 22, 2026.
  17. M-24-08: Strengthening Digital Accessibility and the Management of Section 508 of the Rehabilitation Act. Office of Management and Budget, The White House. 2023-12-21. accessed October 22, 2026.
  18. Test for Accessibility. General Services Administration, Section508.gov. accessed October 22, 2026.
  19. General Services Administration Publishes Annual Governmentwide Section 508 Assessment. U.S. Access Board. 2026-03-05. accessed October 22, 2026.
  20. FY 2025 Governmentwide Section 508 Assessment: Executive summary. General Services Administration, Section508.gov. 2026-03. accessed October 22, 2026.
  21. Understanding Federal ICT Accessibility Outcomes: Key Findings from the FY25 Governmentwide Section 508 Assessment. General Services Administration, Section508.gov. 2026-03. accessed October 22, 2026.
  22. Accessibility Coding Standards. WordPress Developer Resources, WordPress.org. accessed October 22, 2026.

Web Building Encyclopedia. First published October 22, 2026. Last reviewed October 22, 2026. Every fact on this page is linked to a source we opened. Spotted an error? Write to [email protected].