508 Update, Update

A little more than a year ago, I wrote about the proposed update to the 508 accessibility standards. And about three weeks ago, the US Access Board published the final rule that contains updates to the 508 accessibility requirements for Information and Communication Technology (ICT). The rules had not previously been updated since 2001 and as such had greatly lagged behind modern web conventions.

It’s important to note that the 508 guidelines are intended to serve as a vehicle for guiding procurement, while at the same time applying to content created by a given group/agency. As such, the language isn’t always straightforward.

What’s new?

As I outlined in my previous post, a major purpose of the new rule is to move away from regulating types of devices and instead focus on functionality:


… one of the primary purposes of the final rule is to replace the current product-based approach with requirements based on functionality, and, thereby, ensure that accessibility for people with disabilities keeps pace with advances in ICT.


To that effect, one of the biggest change over the old standard is the adoption of WCAG 2.0 as the compliance level. The fundamental premise of WCAG compliance is that content is ‘perceivable, operable, and understandable’ — bottom line is that as developers, we should strive to make sure all of our content is usable for everyone across all devices. The adoption of WCAG allows the board to offload responsibility of making incremental changes as technology advances (so we don’t have to wait another 15 years for updates) and also aligns our standards in the United States with those used around the world.


Harmonization with international standards and guidelines creates a larger marketplace for accessibility solutions, thereby attracting more offerings and increasing the likelihood of commercial availability of accessible ICT options.


Another change has to do with making a wider variety of electronic content accessible, including internal documents. It will be interesting to see to what degree this part of the rule is followed by non-federal agencies.


The Revised 508 Standards specify that all types of public-facing content, as well as nine categories of non-public-facing content that communicate agency official business, have to be accessible, with “content” encompassing all forms of electronic information and data. The existing standards require Federal agencies to make electronic information and data accessible, but do not delineate clearly the scope of covered information and data. As a result, document accessibility has been inconsistent across Federal agencies. By focusing on public-facing content and certain types of agency official communications that are not public facing, the revised requirements bring needed clarity to the scope of electronic content covered by the 508 Standards and, thereby, help Federal agencies make electronic content accessible more consistently.


The new rules do not go into effect until January 2018. There’s also a ‘safe harbor’ clause that protects content that was created before this enforcement date, assuming it was in compliance with the old rules. However, if you update that content after January, you’ll need to make sure it complies with the new final rule.


Existing ICT, including content, that meets the original 508 Standards does not have to be upgraded to meet the refreshed standards unless it is altered. This “safe harbor” clause (E202.2) applies to any component or portion of ICT that complies with the existing 508 Standards and is not altered. Any component or portion of existing, compliant ICT that is altered after the compliance date (January 18, 2018) must conform to the updated 508 Standards.


So long story short, a year from now you should make sure all the content you’re creating meets the new compliance level.

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