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While the wheels of the legislative branch turn slowly, it is recommended that federal agencies and their vendors start getting to know WCAG 2.0 and developing their remediation plans so they are already well on their way to compliance by the day the Refresh is official.

Where do you start?

Where you start depends on where your organization stands currently when it comes to digital accessibility:

New to Accessibility

The best place to start is with an audit, which will give your leadership team a high-level overview of your level of compliance with WCAG 2.0 A and AA and your development team a list of violations that need to be remedied. After an audit, your development team can prioritize the most visible violations—that is, those that are likely to cause an immediate accessibility problem for users with disabilities—and work their way down the priority list.

Already Section 508 Compliant

If you’re already Section 508 compliant and wondering what it will take to bring you into compliance with the new regulations in the Refresh, the US Access Board provides a table comparing the current Section 508 WCAG 2 A/AA.

According to the Access Board, 22 of the 38 WCAG 2.0 Success Criteria are substantially equivalent to current Section 508 standards. This leaves 16 criteria that are new or substantially changed. Some agencies have already been going above and beyond the original Section 508 requirements and may have even fewer items on their to-do list.

Already WCAG 2.0 A or AA Compliant

If you do not know whether you are Section 508 compliant, but have already tested for WCAG 2 A and AA, you are in better shape for the Refresh than most organizations. Here are some of the gaps that we have identified:

  • The current Section 508 has a twice per second flashing limit while WCAG specifies three times per second and also allows for small areas to contain flashing content. Section 508 also allows for flashing in the range from 56-59 times per seconds while WCAG does not allow for this.
  • WCAG does not require that documents are readable without style sheets, only that content is in a meaningful sequence. Section 508 indicates that documents be readable without an associated style sheet.
  • The current Section 508 requires that embedded and linked non-HTML media provide a link to an accessible plug-in.
  • The current Section 508 requires that alternative pages are not used unless absolutely necessary, while WCAG allows for alternative pages to be used. WCAG has no bar for determining when they are not allowed.
  • In our experience, most US federal agencies require that link text is meaningful when taken out of context, rather than WCAG AA’s allowance for it to be understood in context. This isn’t an explicit current Section 508 requirement, but it is our experience that most agencies require this and test for it.

While there is still time before the Section 508 Refresh is official, you don’t want to wait to get on board with the changes now.

  • Government agencies will want to achieve compliance with the Section 508 Refresh before the complaint window opens.
  • To avoid loss of contracts, vendors should strive to meet the refreshed standards as soon as possible.

Since the majority of the changes in the Refresh are known and technology firms like SSB BART Group already have tools to bring your websites and apps into compliance with WCAG 2.0 A and AA, it’s best to start the auditing process immediately. This allows you the time to take things and a more leisurely pace and avoids the staffing costs of having to remediate on an abbreviated timeline.