29 U.S.C. 794d; 36 CFR Part 1194
For technology suppliers to US federal agencies working out what Section 508 expects of their digital content and documents. This page covers what you need to know and ways to avoid running into issues.
What we've seen reported
Section 508 of the Rehabilitation Act, 29 U.S.C. 794d, covers the information and communication technology federal agencies develop, procure, maintain or use. The Access Board's refreshed standards for it, at 36 CFR Part 1194, apply from 2018.1,2
Last updated October 2026 · General information only, not legal advice. Sources.
What the rules cover
These are the kinds of ICT the Revised 508 Standards describe, according to the Access Board's text, and where each requirement is described as applying. ACRs come from GSA guidance, not the standards.2,3
| Requirement | Where it applies |
|---|---|
| Public-facing electronic content | Agencies: websites and other public-facing content conform to WCAG 2.0 Level A and AA. |
| Internal agency communications in nine categories | Agencies: official content such as emergency notices, forms, surveys and training materials. |
| Documents, such as PDFs and word processing files | Measured against WCAG 2.0 as well, with "document" read in place of "web page". |
| Software, including mobile apps | WCAG 2.0 where it holds content, plus the Chapter 5 software requirements. |
| Hardware | Chapter 4 covers ICT hardware, including devices with closed functionality such as kiosks. |
| Support documentation and services | Chapter 6: documentation describes accessibility features and is available in alternate formats. |
| Accessibility Conformance Reports (ACRs) | GSA's Section508.gov describes ACRs as how government buyers assess ICT in market research and proposals. |
| Existing (legacy) ICT | A safe harbor for unaltered ICT that met the original standards; alterations follow the revised ones. |
Where it goes wrong
One approved set of product information ends up in many channels, markets and languages. Along the way it gets shortened, translated and reworded, and some versions end up without the warnings or details these rules require.
Accessibility statement with a link to the current ACR
How Arbitr helps
Manually review everything? Or do what modern teams do and use AI to check that what you publish matches what you approved.
FAQ
In more places than the accessibility page. GSA's Section508.gov suggests linking each product's ACR from its product description page,3 and we usually find statements and ACR links in:
Treat the ACR link as approved wording that changes with every release. Section508.gov notes that a version change or bug fix may call for an updated ACR,4 and old links tend to survive in decks and proposal templates long after the product page moves on. When a new ACR is published, check every place the old one was linked, in every language. Arbitr checks that wording, not design choices such as color contrast or font size.
More than your accessibility lead. Product, documentation, marketing, sales and proposal teams all publish what agencies review, and so do resellers. A short briefing for each, using your own statements and ACRs, helps. Related rules are on our accessibility hub, including the European Accessibility Act for teams selling in the EU.
Keep one record per statement: the approved wording, which ACR and product version it points to, who approved it, and where it's published. When an agency asks, or a new ACR replaces the old one, you can trace every version. More on checking versions at scale is on our content checks page.
How it applies to a specific accessibility statement is a question for your legal adviser. Where that accessibility statement appears across your markets and languages is a question Arbitr answers.
From January 18, 2018, according to the Access Board's final rule, which was published a year earlier, on January 18, 2017. Under its safe harbor, legacy ICT that met the original standards and hasn't been altered since is not required to be upgraded.1
They're related but not the same. Section508.gov describes the VPAT as a template developed by the IT Industry Council, and the most common way of producing an ACR, the report agencies ask suppliers for.4
The Revised 508 Standards incorporate WCAG 2.0 Level A and Level AA success criteria by reference, according to their text, and apply them to web content, electronic documents and software.2
No. Your reviewers stop reading everything and read only what has been flagged, with the rule and the reason attached.
