This blog has been updated to reflect the release of WCAG version 2.2 in October of 2023.

If you’re part of a federal government agency, or you’re doing business with one, your organization is required to comply with Section 508 of the U.S. Rehabilitation Act of 1973. But what does this look like in practice?In this article, you’ll find a guide to Section 508 testing. Learn about:

  • What Section 508 is and why it matters
  • The standards you’ll use when testing your web content
  • The most common accessibility considerations for Section 508 compliance
  • How an accessibility partner can provide a holistic approach to implementing your Section 508 testing results

Section 508 compliance: What it is & why it matters

Section 508 is an amendment to the Rehabilitation Act of 1973, a U.S. federal accessibility law. It is essentially a federal government procurement tool written to ensure that all information and communications technology (ICT) developed, procured, maintained, or used by federal agencies is accessible for people with disabilities. Section 508 thus applies to all federal agencies and departments, as well as organizations doing business with federal agencies.

What counts as ICT?

When Section 508 mentions ICT, it refers to software and websites, electronic documents (for example, PDFs), multimedia content, phones, call centers, and more. ICT is basically any kind of electronic or web asset that people may use in order to access federal services.

Why Section 508 compliance matters

Making web content accessible to everyone is the ethical thing to do for any organization, whether Section 508 applies. Of course, it’s also a smart business move. Non-compliance with Section 508 can result in hefty fines for covered entities. Non-compliance also puts private companies’ government contracts at risk, since any ICT they sell to or provide for government agencies must be Section 508 compliant.Learn more about proving accessibility for procurement processes. That’s where Section 508 testing comes in. To get your organization in shape for compliance, you’ll need to test your ICT against the success criteria described by the global gold standards for web accessibility: the Web Content Accessibility Guidelines (WCAG) 2.0.

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Section 508 testing is WCAG conformance testing

WCAG itself is not a legal requirement, like Section 508. Instead, it is a set of standards created by the Web Accessibility Initiative (WAI), which is part of the World Wide Web Consortium (W3C). The aim of WAI in creating WCAG was to create a global gold standard for accessible web content.The latest version, WCAG 2.2 builds on previous versions and was released in October 2023. So, in performing Section 508 testing, both automated tools and accessibility evaluation partners will evaluate your ICT according to WCAG criteria.

WCAG versions and levels

WCAG has different conformance levels that do not all necessarily apply to all organizations. So, which version and level should you test for?Section 508 currently cites conformance to WCAG 2.0 Level AA as its compliance standard. So, if your ICT meets all WCAG 2.0 AA criteria, it effectively meets Section 508 requirements. Level AA is the second of three conformance levels (A, AA, and AAA) and represents a strong level of accessibility.As for version 2.0, recall that this is not the most updated version of WCAG. However, we do anticipate Section 508, and other laws, will eventually adopt the most recent version of WCAG. That’s why we recommend working toward conformance with WCAG 2.2. Learn more about the differences between WCAG versions and levels in our blog on the subject.

What to focus on when testing for Section 508 compliance

Types of ICT

The aim of Section 508 testing is identifying and solving any accessibility barriers that exist in ICT used by employees and patrons of your organization. Below are some of the most common digital experiences that should be tested for Section 508 compliance, at the very least:

  • Websites (internet and intranet)
  • Mobile applications
  • Program application platforms, or software and operating systems (web-based and stand-alone)
  • PDF documents
  • E-learning courses (for example, online training)
  • Support documentation (for example, user guides for software and tools)

For a full list of the types of ICT you may need to test, consult the GSA’s guide to inventorying your ICT for the purpose of Section 508 testing.

Accessibility considerations

Section 508 testing should ensure that ICT is accessible from the point of view of a user with any number of disabilities that affect how they interact with technology.For example, ICT must be able to properly interact with various assistive technologies, such as screen readers and voice recognition software. Similarly, it should be able to support keyboard-only users. Websites should be designed with sufficient color contrast for users with low contrast sensitivity, and online forms should include proper input labels. Finally, WCAG standards should be followed for all of the ICT your organization uses – including all formats and file types, internal training materials, job listings, and more.These are just a few examples from a long list of potential considerations, which is why it’s important to use testing tools and methods that will detect the full range of potential barriers.

How to carry out Section 508 testing

So, what does Section 508 testing actually consist of? The process typically involves testing against WCAG success criteria via one or both of the following:

  • Automated testing: There are many accessibility automated testing tools – sometimes called web scanners – available to scan your ICT and generate a list of barriers that need to be fixed. One popular example is WAVE. Note that automated tools have limitations. Web scanners typically only identify problems, but do not fix them. They may also miss accessibility barriers that could lead to non-compliance fines or lawsuits.
  • Manual testing: To get a clearer picture of the state of accessibility of your ICT, you can use screen readers and other common assistive technologies to test your ICT manually – if you have access to them.

Though some organizations do choose to use just one of these methods, the best approach is a holistic one. Section 508 testing is complex, and using a combination of methods allows you to cover more bases.

Does your website meet accessibility guidelines?

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How an accessibility partner can help

Section 508 testing is a complex process with high stakes for your business and your users. Deciding to take a holistic approach is a great first step, but it still takes a lot of expertise, time, and resources to execute this approach. As demonstrated in the General Services Administration’s guide to testing, even identifying the right automation tools to use requires knowledge and experience, and then there’s the expertise required to run the tests, interpret results, and fix the problems identified, prioritizing those that will make the most critical impact, first.Often, the best solution is to turn to the experts. An accessibility partner like Level Accesss has the expertise and experience to not only guide you through a holistic approach to section 508 testing, but also remove barriers and prevent future problems.Specifically, an accessibility partner would:

  • Use a combination of automated accessibility testing tools and manual evaluations for individual web pages, documents, and applications.
  • Have users (including people with disabilities) of assistive technologies, such as screen readers like JAWS, test for inaccessibility.
  • Test individual website functionalities such as online forms or flows such as product purchases, among others.
  • Produce an in-depth report that not only gives an overall rating of the level of Section 508 compliance, but also identifies, explains and provides code-level solutions for individual violations of accessibility guidelines.
  • Ensure reports are jargon-free so they can be understood, and provide personal interaction with experts who can discuss the reports and answer questions.
  • Offer remediation recommendations, including periodic monitoring, and provide status reports as improvements are made.
  • Help completing a Voluntary Product Accessibility Template (VPAT), providing a full Accessibility Conformance Report (ACR) for proof of conformance with accessibility requirements.
  • Provide accessibility training to ensure accessibility is sustained throughout your organization’s future.

Section 508 compliance is a complex but necessary step in the journey toward accessibility for all. With eA, your organization doesn’t have to go it alone. If you’re interested in how we can help bring your organization into compliance with Section 508, get in touch with us today.