Section 508 Refresh: ICT Requirements That Changed in 2017

The 2017 Section 508 Refresh: A Landmark Update

On January 18, 2017, the U.S. Access Board published the final rule updating Section 508 standards for the first time since 2001. Federal agencies were required to comply by January 18, 2018. The Refresh represents the most significant change to federal ICT accessibility requirements in nearly two decades, replacing technology-specific provisions with outcome-based, technology-neutral requirements aligned to internationally recognized standards.

WCAG 2.0 Level AA Incorporated by Reference

The most consequential technical change is the incorporation of WCAG 2.0 Level AA by reference as the standard for web content and software with user interfaces. An entity conforming to WCAG 2.0 AA for its web content satisfies the parallel Section 508 web requirements. It also means future WCAG updates (2.1, 2.2) do not automatically become Section 508 requirements — the Access Board must take additional rulemaking to incorporate them.

Software Requirements Under the Refresh

• 502 — Interoperability with Assistive Technology: software must use platform accessibility APIs
• 502.3 — Accessibility Services: all UI components must expose accessible name, role, and state
• 503 — Applications: user preferences for system accessibility settings must be honored
• 504 — Authoring Tools: must support accessible templates and not override accessible content

Hardware Requirements Under the Refresh

• 407.6 — Operation: input controls must not require simultaneous activation
• 409 — Status Indicators: must be indicated both visually and by touch or sound
• 410 — Color Coding: color cannot be the sole means of conveying information
• 412 — ICT with Two-Way Voice Communication: must support hearing aid coupling via T-coil

Electronic Content Standards Under the Refresh

Chapter 6 establishes accessibility requirements for all electronic content created, maintained, or used by federal agencies — including public-facing content (websites, PDFs, presentations) and non-public-facing content used internally. Public-facing electronic content must conform to WCAG 2.0 AA. Electronic documents (PDFs, Word, Excel, PowerPoint) are within scope as electronic content.