Section 508 Guide

A benefits notice, an application, a required training document. People rely on these materials to make decisions and take action. When a PDF is inaccessible, someone may have to ask another person to read private information or help complete a task they could otherwise handle independently.

Section 508 requires federal agencies to make covered technology and electronic content accessible to people with disabilities. If you create, purchase, or publish PDFs for an agency, understanding those requirements helps you deliver information people can use.

Braille Works helps federal agencies and contractors remediate PDFs, including scanned documents, complex tables, and fillable forms. Have a file ready? Get a custom quote for your PDF.

Jump to a section

• What is Section 508
• Who Section 508 protects
• Federal agencies and third-party providers
• How Section 508 differs from Section 504 and the ADA
• Technology and electronic documents covered by Section 508
• Section 508 and WCAG standards
• Creating accessible PDFs and other documents
• Testing and documenting accessibility
• Exceptions and continued access
• Consequences of failing to provide access
• Putting accessibility into practice

What is Section 508

Section 508 is part of the Rehabilitation Act of 1973. It requires federal agencies, including the U.S. Postal Service, to ensure that the information and communication technology (ICT) they develop, purchase, maintain, or use is accessible to people with disabilities in the same way it is for people without disabilities.

In 1998, Congress strengthened Section 508 by adding enforceable accessibility standards and mechanisms to hold federal agencies accountable. The U.S. Access Board then published revised standards in January 2017, and agencies were required to comply beginning January 18, 2018.

The U.S. General Services Administration (GSA) is responsible for helping agencies and vendors follow Section 508 requirements by providing technical assistance.

Who Section 508 protects

Section 508 protects federal employees and members of the public with disabilities who seek information or services from a federal agency. Section 508 requires agencies to provide equal access to and use of information comparable to what people without disabilities can access.

Providing accessible information helps uphold the civil rights of people with disabilities. It also supports their independence and ability to make well-informed decisions. A person may need to read a benefits notice, complete an application, or participate in required job training. An inaccessible document can prevent someone from completing the same task independently.

Did you know that accessibility goes beyond screen reader compatibility? Some people may need keyboard navigation, captions, high contrast, magnification, simplified text, or other ways to access and understand information to overcome communication barriers.

Federal agencies and third-party providers

Section 508 places the legal responsibility for compliance on the federal agency. Vendors and contractors have responsibilities when they supply covered technology or electronic content under the agency’s contract or procurement process. However, hiring another company does not transfer the agency’s obligation to provide access.

A contractor hired to produce a federal agency’s training materials must deliver materials that comply with the applicable accessibility requirements. The federal agency that contracted with the third party must ensure it is receiving 508-compliant materials.

This can be done by ensuring contracts specify the covered deliverables, applicable standards, testing requirements, and responsibility for addressing barriers. The GSA guidance for vendors explains how to meet and demonstrate federal accessibility requirements.

How Section 508 differs from Section 504 and the ADA

Section 508 focuses on federal information and communication technology. Section 504 prohibits disability discrimination in programs or activities receiving federal financial assistance, as well as in programs conducted by federal executive agencies or the U.S. Postal Service. The Americans with Disabilities Act provides separate protections, including those for state and local government services and private businesses.

Receiving federal funding does not, by itself, subject an organization to Section 508. A hospital, college, bank, or other private business should identify the applicable laws and contract terms for its services. However, state law, agency policy, or a contract may adopt Section 508 standards even when Section 508 does not directly apply.

Technology and electronic documents covered by Section 508

Section 508 goes beyond websites and PDFs. Covered ICT can include software, mobile applications, electronic forms, videos, kiosks, and office equipment. Support documentation and services also have accessibility requirements.

For electronic content, the revised standards cover public-facing information and specified categories of nonpublic official agency communication. Those categories include emergency notifications; decisions in administrative claims or proceedings; program or policy announcements; notices about benefits, eligibility, employment, or personnel actions; formal acknowledgments of receipt; surveys; templates and forms; educational or training materials; and intranet content designed as web pages. Please note, emails and attachments can fall within these categories.

Section 508 and WCAG standards

The Revised Section 508 Standards incorporate the Web Content Accessibility Guidelines (WCAG) version 2.0, including Level A and Level AA requirements for covered electronic content. They adapt those requirements for non-web documents, including exceptions for four criteria that do not apply.

WCAG 2.1 and WCAG 2.2 provide newer accessibility criteria, but they have not automatically replaced WCAG 2.0 in the federal Section 508 standards. An organization may choose a newer target or be required to follow one under another law, agency policy, or contract.

Section 508 also includes requirements for hardware, software, and support services. A WCAG review alone does not evaluate every Section 508 requirement. GSA explanation of applicability and conformance.

Creating accessible PDFs and other documents

A PDF can be accessible when you create and check it correctly. Saving a file as a PDF does not make it accessible, and an accessible website does not make every linked document accessible.

Start with the source document whenever possible. Use built-in headings and lists, meaningful link text, appropriate contrast, and descriptions for informative images. Tables need a structure that connects the data to the correct headers. Forms need understandable labels and a usable keyboard sequence.

For PDFs, review tags and reading order, document language, and the way assistive technology presents the information. A scanned image may need text recognition, followed by correction and accessibility support work. Searchable text alone does not make the document accessible.

The federal document testing guidance provides resources for reviewing PDFs, Word documents, spreadsheets, and presentations. Learn more about what makes a PDF accessible.

Testing and documenting accessibility

Automated tools can identify accessibility problems, but human review is still needed to determine that every requirement is met. A tool may detect alternative text without knowing whether it accurately describes the image. Human review is also needed for reading order, form instructions, maps, and graphs to make documents compliant.

Trained employees can perform accessibility testing. An outside specialist who is a certified Department of Homeland Security (DHS) Trusted Tester can provide additional expertise or capacity. What matters is that the review covers the applicable requirements and uses appropriate methods. Combine automated checks with manual review and, where appropriate, assistive technology and user testing.

Exceptions and continued access

The revised standards include limited exceptions. A document is not exempt simply because it is old. The legacy ICT provision applies to qualifying existing technology that met the earlier Section 508 standards and has not been altered since January 18, 2018.

An agency determination that an undue burden or fundamental alteration applies requires written justification from the responsible official. The agency must still provide an alternative means of access that meets the identified needs upon request. Similar documentation and alternative access requirements apply when fully conforming technology is not commercially available.

Related: Archiving Documents Does NOT Make You ADA Compliant

Consequences of failing to provide access

An inaccessible system or document can prevent someone from receiving information, meeting a deadline, or doing their job. Section 508 provides an administrative complaint process through the responsible federal agency and a route for civil actions, subject to the law’s enforcement provisions. This gives an affected person a clear way to report the barrier and obtain the information they need. The Department of Justice also oversees this, and penalties apply for noncompliance.

Putting accessibility into practice

Now that the responsibilities are outlined, what can your organization do? Start with the information people need to use your services, and make accessibility part of how you create and deliver it.

Identify the requirements before work begins

• Review the applicable laws, agency requirements, and contracts.
• Identify the documents and systems involved, their users, and how you will verify accessibility.
• Remember: if a person with a disability requests access, that item moves to the top of the queue.

Give staff a process they can follow

• Provide guidance, accessible templates, and training for those who create, purchase, review, and publish content.
• Delegate responsibility for requests and corrections to a decision-maker who can fulfill accommodation requests and follow up to confirm the accommodation was effective.
• Review updated materials to ensure the same barriers don’t reappear.

Choose a document accessibility partner carefully

• Ask about formats, testing methods, quality review, turnaround times, and secure handling of personal information.
• Agree on what will be delivered and how corrections will be handled.
• Investigate how long they have been in business and their reputation.

Braille Works provides more assistance on choosing a document accessibility partner.

Meet the needs of the person making the request

An accessible electronic document may not meet every individual’s communication needs. A person may also need braille, large print, or audio under applicable accommodation or effective communication requirements. The format must work for the person receiving it.