Accessible documents: Section 508, the ADA rule, and WCAG

Do these rules apply to an organization like ours?

Two different rules cover two different sets of organizations. Section 508 came from a 1998 amendment to the Rehabilitation Act of 1973 requiring federal agencies to make their electronic and information technology accessible to people with disabilities. It applies, in the government's own summary, "to all federal agencies when they develop, procure, maintain, or use electronic and information technology."¹

Procurement is one of the four covered activities named there, which is how a private supplier meets Section 508 without being subject to it directly. The obligation belongs to the agency buying the material, and it arrives in the contract.

State and local governments are covered by a separate Department of Justice rule under Title II of the Americans with Disabilities Act. That rule reaches all state and local governments, special purpose districts, and Amtrak and other commuter authorities.²

Companies with neither a federal customer nor a public-sector one are outside both rules. Many adopt the same technical standard anyway, because it is the only widely published specification for the job.

What counts as a document under these rules?

Ordinary office files. The Justice Department's fact sheet on the Title II rule defines a conventional electronic document as one of four kinds: "The documents are word processing, presentation, PDF, or spreadsheet files."² That definition sits inside a narrow exception for preexisting documents, and documents still used to apply for or access a service are not excepted.²

Section 508 divides electronic content by where it goes rather than by file type. Public-facing content is covered in full. Content that is not public-facing is covered when it is an official communication, a category that includes emergency notifications, administrative decisions, policy announcements, benefits notices, employment opportunities, training materials, and intranet pages.³

The standards then borrow the web guidelines and adapt them. Electronic content has to meet Level A and Level AA of WCAG 2.0. Four criteria are excepted for documents that are not web pages, and the word "document" is substituted wherever the guidelines say "web page."³

Which version of WCAG applies, 2.0 or 2.1?

It depends which rule you are under. The Revised 508 Standards point at WCAG 2.0, Levels A and AA.³ The Justice Department's Title II rule adopts WCAG 2.1 Level AA as its technical standard.⁴

An organization that produces material for a federal agency and for a state agency is therefore working to two specifications at once. The two overlap heavily, since WCAG 2.1 contains all of WCAG 2.0. The later version adds criteria the earlier one does not have, so a document built to 2.1 will normally satisfy 2.0 as well.

Confirming which standard a particular contract names is worth doing before drafting rather than after. The answer changes what a reviewer will check for, and it occasionally changes the template a document has to be poured into.

The version question also decides which published checklist is the right one to work from. A checklist written against WCAG 2.0 will not mention the criteria added later, and a reviewer working from the newer list will find them missing.

When do the Title II deadlines fall?

They moved in April 2026. The Justice Department published an extension of the compliance dates on April 20, 2026, at 91 FR 20902.⁴

Under the revised schedule, public entities serving a population of 50,000 or more comply beginning April 26, 2027. Entities serving fewer than 50,000 people, and special district governments of any size, comply beginning April 26, 2028.⁴ The dates that rule replaced were April 24, 2026 and April 26, 2027.

An extension of roughly a year is not as much room as it sounds for an organization with a large back catalog. Documents already in a queue for release after those dates are the ones worth looking at first, because remediation after publication costs more than drafting with the standard in view.

Suppliers to those entities tend to hear about the dates through a contract rather than through the Federal Register. A requirement that appears in a statement of work is the same requirement, arriving by a different route.

Which parts of this are an editing job rather than a software setting?

Several of the criteria are questions about language. Success criterion 2.4.6, at Level AA, reads in full: "Headings and labels describe topic or purpose."⁵ Applying a heading style in a word processor is a setting. Whether the heading names what the section is about is a judgment about the words.

Link text is the same kind of problem. Criterion 2.4.4, at Level A, asks that "the purpose of each link can be determined from the link text alone or from the link text together with its programmatically determined link context."⁵ A document with eleven links all reading "click here" has a wording fault rather than a coding fault.

Criterion 3.1.1 requires that the default language of the page be programmatically determined.⁵ Setting it is mechanical. Noticing that four paragraphs of a manual switch into another language, so that those passages need marking, is proofreading.

Does a proofread make a document accessible?

No, and treating the two as the same job produces a document that fails review while reading well. A proofread checks surface correctness in the text as laid out. Conformance covers structure, tagging, contrast, reading order, and the file's behavior in assistive technology, none of which a proofreading pass examines.

Where the two jobs meet is in wording. Headings, link text, table headers, captions, and alternative text are all language, and an editor works on them. The same pass catches a heading that has been styled as body text and a table whose header row is a row of bold words rather than a header row.

What we do not do is decide what an image conveys. That belongs to whoever created it and to the reviewers who know the subject, and the description arrives with the copy.

What does an editor need from your side before starting?

Which standard the document is being held to, which template it has to live in, and who has authority over wording that a compliance reviewer has already approved. Documents produced under a contract often carry approved language nobody may touch, and marking that language before the edit saves an argument later.

The source file helps more than an export of it. A tagged PDF generated from a Word document is best corrected in the Word document, since fixing the export leaves the next export carrying the same faults.

Alternative text and table structure decisions come from your subject specialists rather than from us. Where an image has no description yet, we mark it as missing rather than inventing one. Every document a client sends us is treated in confidence.

Can an editor certify that a document conforms?

We do not, and a service that offers to is worth a second question. Conformance is a claim about the whole file, and it rests on testing with assistive technology and validation tools rather than on reading.

The General Services Administration, which runs Section508.gov, notes on its own document guidance that much of the agency-developed material in circulation predates the Revised 508 Standards.⁶ Guidance written against an older specification is one reason organizations discover a gap late.

What an editor delivers is the language half of the problem: headings that describe their sections, link text that survives being read out of context, consistent terminology, and captions that match what they caption. Those are the items a checking tool cannot settle, because a tool can see that a heading exists and not whether it says anything.

The conformance claim itself stays with the people who test the file.