Producing a Section 508 compliance report

Section 508 of the Rehabilitation Act requires U.S. federal agencies to buy and use information and communication technology (ICT) that is accessible to people with disabilities. The Revised 508 Standards, in effect since 2018, adopt WCAG 2.0 Level A and AA for web content and software interfaces and add federal-specific requirements on top. For a vendor selling to government, the practical consequence is simple: you will be asked for a Section 508 ACR, and a contracting officer may not buy without one.

The Section 508 edition of VPAT 2.5 is larger than the WCAG edition because it carries extra chapters. The functional performance criteria (302) describe outcomes for users without vision, with limited vision, without hearing, without speech, with limited manipulation, and so on. The hardware chapter (402) applies to physical devices. The software chapter (502/503) covers interoperability with assistive technology and user preference handling. The support documentation chapter (602/603) requires that your manuals and help content are themselves accessible and that support staff can accommodate users with disabilities.

Because the Revised 508 Standards incorporate WCAG 2.0 by reference, the WCAG criteria tables in a 508 report are evaluated against the 2.0 baseline. WCAG 2.1 criteria (such as Reflow or Orientation) are not strictly required by 508, though reporting them is good practice and many buyers appreciate it. A clean 508 ACR states this clearly and uses Not Applicable accurately for chapters that do not fit your product — for example, the hardware chapter for a web-only application.

VPAT Studio's Section 508 edition includes the functional, hardware, software and documentation rows alongside the WCAG tables, so the report you export has the structure a federal reviewer is trained to read.

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Building a 508 ACR

  1. Select the Revised Section 508 edition so the functional, hardware, software and documentation chapters load.
  2. Evaluate the WCAG tables against the WCAG 2.0 A and AA baseline that 508 incorporates.
  3. Mark the hardware chapter (402) Not Applicable for web-only or software-only products, with a remark explaining why.
  4. Address support documentation (602/603): your help content and support services must be accessible too.
  5. Export and attach the ACR to your federal RFP or contract response.

Questions

Is Section 508 the same as WCAG?

No. Section 508 is U.S. federal law that incorporates WCAG 2.0 for web and software, then adds functional performance, hardware, software interoperability and documentation requirements. WCAG is the web content standard 508 builds on.

Does my web app need the hardware chapter?

If it has no hardware component, mark chapter 402 Not Applicable with a brief remark. The chapter still appears in the report; you simply document that it does not apply.

WCAG 2.0 or 2.1 for a 508 report?

The Revised 508 Standards incorporate WCAG 2.0 A and AA. Reporting 2.1 criteria as well is helpful and increasingly expected, but only 2.0 is strictly required by the regulation.

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