Section 508
A US federal procurement requirement (29 U.S.C. § 794d): federal agencies can only buy ICT — websites, software, hardware — that conforms to accessibility standards. The current standard (2018 Refresh) wraps WCAG 2.0 AA.
Section 508 of the US Rehabilitation Act (originally added in 1986 and substantially overhauled in 1998 and again in 2017) is a US federal procurement requirement. It does not mandate that anyone build accessible products — only that the federal government cannot buy ICT that fails the standards.
What “ICT” covers
Section 508’s scope reaches far beyond websites. The current standards (codified at 36 CFR Part 1194, the “Revised 508 Standards” that took effect in January 2018) apply to:
- Websites and web applications.
- Software (desktop, mobile, embedded).
- Hardware (computers, displays, peripherals).
- Telecommunications equipment.
- Self-contained closed products (kiosks, ATMs operated for federal programmes).
- Documentation and support services.
The 2018 Refresh harmonised US standards with international ones by incorporating WCAG 2.0 Level AA by reference for web content. EN 301 549 (Europe) and Section 508 are now mutually consistent for the overlapping subject matter.
VPATs
The procurement workflow runs through VPATs — Voluntary Product Accessibility Templates. A vendor responding to a federal RFP fills out a VPAT documenting, success criterion by success criterion, how their product meets the standards. The current template, VPAT 2.5, has three flavours (Section 508 only, EN 301 549 only, WCAG only) plus a combined “Worldwide” variant.
A useful VPAT distinguishes:
- Supports — meets the criterion.
- Partially supports — meets it for some content, fails for others (with details).
- Does not support — fails outright.
- Not applicable — the criterion doesn’t apply to this product.
- Not evaluated — the vendor didn’t test (AAA criteria only).
Vendors that mark every line “Supports” without explanation are typically hiding failures. Procurement reviewers are trained to spot it.
Enforcement
Section 508 is enforced primarily through the procurement process — a non-compliant product loses the bid. Complaints under the Act can be filed by federal employees or members of the public, with administrative remedies through the Department of Justice and the agency’s own accessibility office.
The General Services Administration runs Section508.gov as the operational hub: training, sample contract language, an accessibility buying guide, and a regularly-updated standards refresh changelog.
Why it matters outside government
A surprising number of state and local procurement contracts cite Section 508 directly (or via state IT accessibility laws that copy its framework). Many large enterprise buyers (Fortune 500 IT departments buying SaaS) also ask for VPATs as a matter of policy, even though Section 508 itself doesn’t apply to them. A current VPAT is a near-table-stakes artefact for any B2B software product targeting US enterprise customers.