Section 508 Compliance Explained

As federal agencies and their technology partners increasingly rely on digital tools to deliver services, the importance of accessibility has never been greater. Section 508 of the Rehabilitation Act requires federal organizations and any vendors developing technology for them to ensure equal access to information and communication technologies (ICT) for people with disabilities. This includes everything from websites and mobile apps to PDFs, training videos, kiosks, and enterprise applications. Because accessibility is now an essential expectation rather than a nice-to-have, teams must verify that their digital products work for users with a wide range of abilities. This is where Accessibility Testing becomes crucial. It helps ensure that people who rely on assistive technologies such as screen readers, magnifiers, voice navigation tools, or switch devices can navigate, understand, and use digital content without barriers.

However, many teams still find Section 508 and accessibility requirements overwhelming. They may be unsure which standards apply, which tools to use, or how to identify issues that automated scans alone cannot detect. Accessibility also requires collaboration across design, development, QA, procurement, and management, making it necessary to embed accessibility into every stage of the digital lifecycle rather than treating it as a last-minute task. Fortunately, Section 508 compliance becomes far more manageable with a clear, structured approach. This guide explains what the standards require, how to test effectively, and how to build a sustainable accessibility process that supports long-term digital inclusiveness.

What Is Section 508?

Section 508 of the Rehabilitation Act requires federal agencies and organizations working with them to ensure that their electronic and information technology (EIT) is accessible to people with disabilities. This includes users with visual, auditory, cognitive, neurological, or mobility impairments. The standard ensures that digital content is perceivable, operable, understandable, and robust, four core principles borrowed from WCAG.

The 2018 “Section 508 Refresh” aligned U.S. federal accessibility requirements with WCAG 2.0 Level A and AA, though many organizations now aim for WCAG 2.1 or 2.2 for better future readiness.

What Section 508 Compliance Covers (Expanded)

Websites and web applications: This includes all public-facing sites, intranet portals, login-based dashboards, and SaaS tools used by federal employees or citizens. Each must provide accessible navigation, content, forms, and interactive elements.

PDFs and digital documents: Common formats like PDF, Word, PowerPoint, and Excel must include tagging, correct reading order, accessible tables, alt text for images, and proper structured headings.

Software applications: Desktop, mobile, and enterprise software must support keyboard navigation, screen reader compatibility, logical focus order, and textual equivalents for all visual elements.

Multimedia content: Videos, webinars, animations, and audio recordings must include synchronized captions, transcripts, and audio descriptions where needed.

Hardware and kiosks: Physical devices such as kiosks, ATMs, and digital signage must provide tactile access, audio output, clear instructions, and predictable controls designed for users with diverse abilities.

Why Test for Section 508 Compliance?

Testing for Section 508 compliance is essential not only for meeting legal requirements but also for enhancing digital experiences for all users. Below are expanded explanations of the key reasons:

1. Prevent legal challenges and costly litigation

Ensuring accessibility early in development reduces the risk of complaints, investigations, and remediation orders that can delay launches and strain budgets. Compliance minimizes organizational risk and demonstrates a proactive commitment to inclusion.

2. Improve user experience for people with disabilities

Accessible design ensures that users with visual, auditory, cognitive, or mobility impairments can fully interact with digital tools. For instance, alt text helps blind users understand images, while keyboard operability allows people who cannot use a mouse to navigate interfaces effectively.

3. Enhance usability and SEO for all users

Many accessibility improvements, such as structured headings, descriptive link labels, or optimized keyboard navigation, benefit everyone, including users on mobile devices, people multitasking, or those with temporary impairments.

4. Reach broader audiences

Accessible content allows organizations to serve a more diverse population. This is particularly important for public-sector organizations that interact with millions of citizens, including elderly users and people with varying abilities.

5. Ensure consistent user-centered design

Accessibility encourages design practices that emphasize clarity, simplicity, and reliability, qualities that improve overall digital experience and reduce friction for all users.

Key Components of Section 508 Testing

1. Automated Accessibility Testing

Automated tools quickly scan large volumes of pages and documents to detect common accessibility barriers. While they do not catch every issue, they help teams identify recurring patterns and reduce the manual testing workload.

What automated tools typically detect:

• Missing alt text: Tools flag images without alternative text that screen reader users rely on to understand visual content. Automation highlights both missing and suspiciously short alt text for further review.
• Low color contrast: Automated tests measure whether text meets WCAG contrast ratios. Poor contrast makes reading difficult for users with low vision or color vision deficiencies.
• Invalid HTML markup: Errors like missing end tags or duplicated IDs can confuse assistive technologies and disrupt navigation for screen reader users.
• Improper heading structure: Tools can detect skipped levels or illogical heading orders, which disrupt comprehension and navigation for AT users.
• ARIA misuse: Automation identifies incorrect use of ARIA attributes that may mislead assistive technologies or create inconsistent user experiences.

Automated testing is fast and broad, making it an ideal first layer of accessibility evaluation. However, it must be paired with manual and assistive technology testing to ensure full Section 508 compliance.

2. Manual Accessibility Testing

Manual testing validates whether digital tools align with WCAG, Section 508, and real-world usability expectations. Because automation catches only a portion of accessibility issues, manual reviewers fill the gaps.

What manual testing includes:

• Keyboard-only navigation: Testers verify that every interactive element, including buttons, menus, forms, and pop-ups, can be accessed and activated using only the keyboard. This ensures users who cannot use a mouse can fully navigate the interface.
• Logical reading order: Manual testers confirm that content flows in a sensible order across different screen sizes and orientations. This is essential for both visual comprehension and screen reader accuracy.
• Screen reader compatibility: Reviewers check whether labels, instructions, headings, and interactive components are announced properly by tools like NVDA, JAWS, and VoiceOver.
• Proper link descriptions and form labels: Manual testing ensures that links make sense out of context and form fields have clear labels, so users with disabilities understand the purpose of each control.

Manual testing is especially important for dynamic, custom, or interactive components like modals, dropdowns, and complex form areas where automated tests fall short.

3. Assistive Technology (AT) Testing

AT testing verifies whether digital content works effectively with the tools many people with disabilities rely on.

Tools used for AT testing:

• Screen readers: These tools convert digital text into speech or Braille output. Testing ensures that all elements, menus, images, and form controls are accessible and properly announced.
• Screen magnifiers: Magnifiers help users with low vision enlarge content. Testers check whether interfaces remain usable and readable when magnified.
• Voice navigation tools: Systems like Dragon NaturallySpeaking allow users to control computers using voice commands, so interfaces must respond to verbal actions clearly and consistently.
• Switch devices: These tools support users with limited mobility by enabling navigation with single-switch inputs. AT testing ensures interfaces do not require complex physical actions.

AT testing is critical because it reveals how real users interact with digital products, exposing barriers that automation and manual review alone may overlook.

4. Document Accessibility Testing

Digital documents are among the most overlooked areas of Section 508 compliance. Many PDFs and Microsoft Office files remain inaccessible due to formatting issues.

Document accessibility requirements (expanded):

• Tags and proper structure: Documents must include semantic tags for headings, paragraphs, lists, and tables so screen readers can interpret them correctly.
• Accessible tables and lists: Tables require clear header rows and properly associated cells, and lists must use correct structural markup to convey hierarchy.
• Descriptive image alt text: Images that convey meaning must include descriptions that allow users with visual impairments to understand their purpose.
• Correct reading order: The reading order must match the visual order so screen readers present content logically.
• Bookmarks: Long PDFs require bookmarks to help users navigate large amounts of information quickly and efficiently.
• Accessible form fields: Interactive forms need labels, instructions, and error messages that work seamlessly with assistive technologies.
• OCR for scanned documents: Any scanned image of text must be converted into searchable, selectable text to ensure users with visual disabilities can read it.

5. Manual Keyboard Navigation Testing

Keyboard accessibility is a core requirement of Section 508 compliance. Many users rely solely on keyboards or assistive alternatives for navigation.

Key focus areas (expanded):

• Logical tab order: The tab sequence should follow the natural reading order from left to right and top to bottom so users can predict where focus will move next.
• Visible focus indicators: As users tab through controls, the active element must always remain visually identifiable with clear outlines or highlights.
• No keyboard traps: Users must never become stuck on any interactive component. They should always be able to move forward, backward, or exit a component easily.
• Keyboard support for interactive elements: Components like dropdowns, sliders, modals, and pop-ups must support keyboard interactions, such as arrow keys, Escape, and Enter.
• Complete form support: Every field, checkbox, and button must be accessible without a mouse, ensuring smooth form completion for users of all abilities.

6. Screen Reader Testing

Screen readers translate digital content into speech or Braille for users who are blind or have low vision.

Tools commonly used:

• NVDA (Windows, free) – A popular, community-supported screen reader ideal for testing web content.
• JAWS (Windows, commercial) – Widely used in professional and government settings; essential for ensuring compatibility.
• VoiceOver (Mac/iOS) – Built into Apple devices and used by millions of mobile users.
• TalkBack (Android) – Android’s native screen reader for mobile accessibility.
• ChromeVox (Chromebook) – A useful option for ChromeOS-based environments.

What to test:

• Proper reading order: Ensures content reads logically and predictably.
• Correct labeling of links and controls: Allows users to understand exactly what each element does.
• Logical heading structure: Helps users jump between sections efficiently.
• Accessible alternative text: Provides meaningful descriptions of images, icons, and visual components.
• Accurate ARIA roles: Ensures that interactive elements announce correctly and do not create confusion.
• Clear error messages: Users must receive understandable explanations and guidance when mistakes occur in forms.

7. Multimedia Accessibility Testing

Multimedia content must support multiple types of disabilities, especially hearing and visual impairments.

Requirements include:

• Closed captions: Provide text for spoken content so users who are deaf or hard of hearing can understand the material.
• Audio descriptions: Narrate key visual events for videos where visual context is essential.
• Transcripts: Offer a text-based alternative for audio or video content.
• Accessible controls: Players must support keyboard navigation, screen reader labels, and clear visual focus indicators.
• Synchronized captioning for webinars: Live content must include accurate, real-time captioning to ensure equity.

8. Mobile & Responsive Accessibility Testing

Mobile accessibility extends Section 508 requirements to apps and responsive websites.

Areas to test:

• Touch target size: Buttons and controls must be large enough to activate without precision.
• Orientation flexibility: Users should be able to navigate in both portrait and landscape modes.
• Zoom support: Content should reflow when zoomed without causing horizontal scrolling.
• Compatibility with screen readers and switch access: Ensures full usability for mobile AT users.
• Logical focus order: Mobile interfaces must maintain predictable navigation patterns as layouts change.

Best Practices for Sustainable Section 508 Compliance (Expanded)

• Train all development, procurement, and management teams: Ongoing accessibility education ensures everyone understands requirements and can implement them consistently across projects.
• Involve users with disabilities in testing: Direct feedback from real users reveals barriers that automated and manual tests might miss.
• Use both automated and manual testing: A hybrid approach provides accuracy, speed, and depth across diverse content types.
• Stay updated with evolving standards: Accessibility guidelines and tools evolve each year, so teams must remain current to maintain compliance.
• Maintain an Accessibility Conformance Report (ACR) using VPAT: This formal documentation demonstrates compliance, supports procurement, and helps agencies evaluate digital products.
• Establish internal accessibility policies: Clear guidelines ensure consistent implementation and define roles, responsibilities, and expectations.
• Assign accessibility owners and remediation timelines: Accountability accelerates fixes and maintains long-term accessibility maturity.

Conclusion

Section 508 compliance testing is essential for organizations developing or providing technology for federal use. By expanding testing beyond simple automated scans and incorporating manual evaluation, assistive technology testing, accessible document creation, mobile support, and strong organizational processes, you can create inclusive digital experiences that meet legal standards and serve all users effectively. With a structured approach, continuous improvement, and the right tools, your organization can remain compliant while delivering high-quality, future-ready digital solutions across every platform.

Frequently Asked Questions