Section 508 of the Rehabilitation Act requires federal agencies and their contractors to ensure electronic and information technology is accessible to people with disabilities. The current formal baseline is WCAG 2.0 Level AA. The Section 508 Refresh Act (introduced July 2024, not yet law) would update the baseline to WCAG 2.2 and expand coverage. Coverage from Section508.gov, Level Access, and Vispero.
Who Section 508 applies to
- Federal agencies and departments
- Organizations developing, procuring, maintaining, or using ICT on behalf of federal government
- Federal contractors when they develop, sell, or maintain ICT for federal use
- Federal grant recipients (depending on award terms)
- State agencies administering federally-funded programs
What WCAG 2.2 (proposed Refresh) would add
WCAG 2.2 adds 9 success criteria over WCAG 2.0, including:
- Focus appearance and visibility
- Dragging movements (alternatives required)
- Target size minimums
- Consistent help availability
- Redundant entry prevention
- Accessible authentication
The compliance gap is real
GSA's third annual Section 508 federal compliance report acknowledged the federal government continues to fall short of statutory accessibility obligations. Audit findings on federal websites are common.
What contractors should do
- For new builds: target WCAG 2.2 Level AA even though the formal baseline is still 2.0 (it's the likely future standard)
- For existing systems: include accessibility audits in modernization roadmaps
- For procurement docs: VPAT (Voluntary Product Accessibility Template) is the standard contractor accessibility self-attestation
- Watch the Refresh Act's progress — it'll reset baselines if/when enacted