Section 508 Compliance Checklist: Easy Steps

Most Section 508 checklists you will find online are really WCAG checklists with a new title. That is not wrong, because Section 508 points at WCAG, but it skips the parts that are specific to 508 and it often names the wrong version of WCAG.

So before the checklist, let’s get two things straight that are worth it.

What version of WCAG does Section 508 actually require?

WCAG 2.0, Level A and Level AA. Not 2.1. The Revised 508 Standards have applied since 18 January 2018 and incorporate WCAG 2.0 by reference, and the Access Board has not updated that since. WCAG 2.1 Level AA is the standard in the Department of Justice’s 2024 ADA Title II rule, which covers state and local government. Different law, different deadline, different version.

Who Section 508 applies to

• Federal agencies, directly.
• Vendors and contractors selling information and communication technology to federal agencies, through procurement.
• Organizations receiving federal funding, depending on the terms of the award.

Note that Section 508 does not apply to private companies with no federal relationship. That is the ADA, and it works differently.

A note on “ICT”

Section 508 covers information and communication technology, shortened to ICT throughout the standards and used that way below. It is deliberately broad. It means websites and web apps, electronic documents like PDFs and Word files, software, hardware such as laptops, phones, printers, and kiosks, and the manuals, help desks, and support services that come with any of it. If your agency builds it, buys it, maintains it, or uses it to deliver information, it is probably ICT.

The Section 508 Compliance Checklist

Scope and inventory

1. Identify all ICT your agency develops, procures, maintains, or uses.
2. Separate it by category: web content, electronic documents, software, hardware, and support documentation and services.
3. Count your electronic documents. Most agencies cannot, and you cannot fix what you have not counted.
4. Flag which items are public-facing and which are internal. Both are covered.
5. Record which items are legacy ICT unchanged on or after January 2018, as those may fall under the safe harbor provision.

Web content

1. Conforms to WCAG 2.0 Level A and AA in full.
2. Images have text alternatives that convey the same information.
3. Video has captions, and audio has transcripts.
4. Color is not the only way information is conveyed.
5. Contrast meets 4.5 to 1 for normal text and 3 to 1 for large text.
6. Everything works by keyboard alone, with no traps.
7. Focus is visible wherever it lands.
8. Page titles describe the page.
9. Headings follow a logical order and describe the content under them.
10. Form fields have labels that are programmatically linked.
11. Errors are identified in text and suggest a fix.
12. Language of the page is set.

Electronic documents

This is where most agencies lose points, and documents conform at a lower rate than any other category in the governmentwide assessment.

1. Document is tagged. An untagged PDF fails before anything else is considered.
2. Reading order matches the visual order.
3. Headings use real heading tags, not just large bold text.
4. Images have alt text, and decorative images are marked as artifacts.
5. Charts and graphs have descriptions that explain what the data shows, not what the picture looks like.
6. Tables have header cells properly marked, including both row and column headers where needed.
7. Nested or merged cells are structured so relationships survive.
8. Lists use list tags.
9. Document title is set in the properties, not just on the first page.
10. Document language is set.
11. Scanned pages have a real text layer behind them, not just an image.
12. Form fields are tagged, labeled, and reachable in a sensible tab order.
13. Bookmarks exist for longer documents.

Software and applications

1. Conforms to WCAG 2.0 Level A and AA where it presents content.
2. Works with assistive technology through the platform accessibility services.
3. Does not disrupt platform accessibility features.
4. Keyboard access to all functionality.
5. User preferences for color, contrast, font size, and focus are respected.
6. Authoring tools can produce accessible output and prompt the author to supply what is missing.

Hardware

1. Operable without vision, without hearing, without fine motor control, and without speech.
2. Controls are reachable and distinguishable by touch.
3. Status indicators are perceivable by more than one sense.
4. Biometric identification is not the only option.

Support documentation and services

1. User guides are themselves accessible and describe the accessibility features of the product.
2. Help desks and support channels can accommodate users with disabilities.
3. Support documentation is available in an alternate format on request.

Procurement

1. Accessibility requirements appear in the solicitation, not after award.
2. Vendors supply an Accessibility Conformance Report, usually a VPAT, in the 508 edition.
3. Claims in the report are verified rather than accepted on trust.
4. Contracts include remedies if the delivered product does not conform.
5. Any exception claimed is documented with the specific provision and the reason.

Testing and documentation

1. Testing uses a repeatable method, and the DHS Trusted Tester process is the common federal baseline.
2. Automated checking is used for coverage, and manual testing for everything automated tools cannot judge.
3. Testing includes real assistive technology, not just a checker.
4. Results are recorded with dates, versions, and who tested.
5. A remediation plan exists with owners and target dates for what failed.
6. Retesting happens after remediation.

Program management

1. A named Section 508 program manager exists, with enough hours in the week to actually do the job.
2. Policy is written, current, and known to the people it applies to.
3. Training is available and, ideally, required for content authors.
4. Accessibility is checked at the point of authoring rather than only at publication.
5. The agency can report its conformance when asked, which most currently cannot.

Common failures worth checking first

If you want a fast read on where you stand, check these five. They are the defects that turn up most often in federal public documents.

• Missing text alternatives for images.
• Information and relationships that exist visually but are not tagged.
• Reading order that does not match the visual order.
• Missing page titles.
• Missing or inconsistent headings and labels.

A quick note on safe harbor

ICT that complied with the original 2001 standards and has not been altered on or after 18 January 2018 may be covered by the safe harbor provision. Alter any part of it and the revised standards apply to what you changed. This is narrower than people hope, and it is not a reason to leave a document library alone.

Where to check the actual rules

Nothing above replaces the standards themselves. The Access Board publishes the Revised 508 Standards, and GSA’s Section508.gov holds the practical guidance, testing methods, and reporting requirements agencies use. When something in this checklist conflicts with those, they win.