What Section 508 covers
Section 508 applies to federal agencies’ information and communication technology. Procurement requirements can make it relevant to suppliers. Public-facing electronic content and specified categories of agency communications are covered by the Revised Section 508 Standards.
The Revised Section 508 Standards
The revised standards became enforceable in January 2018. For covered electronic content, E205.4 incorporates WCAG 2.0 Level A and AA success criteria and conformance requirements. Non-web documents have four specified exceptions: Bypass Blocks, Multiple Ways, Consistent Navigation, and Consistent Identification.
PDF content and PDF authoring tools have different requirements
PDF content: assess the document against the applicable WCAG 2.0 A and AA requirements. PDF/UA can support that assessment but is not an alternative general conformance standard for PDF content under Section 508.
Authoring tools: section 504.2.2 requires tools capable of exporting PDF 1.7 to also support PDF/UA-1 export. This is the specific PDF/UA reference; it should not be presented as a blanket rule that PDF/UA alone establishes Section 508 conformance.
Document review includes structure, meaningful sequence, text alternatives, visual presentation, forms, keyboard access, language, and navigation as applicable.
Keep document reports and procurement reports distinct
A completed Voluntary Product Accessibility Template (VPAT) is an Accessibility Conformance Report (ACR). It describes a product’s conformance against a defined set of requirements. A per-PDF test report is evidence about one document; it does not replace a product-wide ACR.
Confirm the solicitation’s evidence requirements with the buyer. Retain the remediated PDF, its version, test results, and relevant review notes.
Section 508 and ADA Title II
Section 508 addresses federal ICT. ADA Title II addresses state and local government services, with WCAG 2.1 AA specified in its web rule. These have different scopes and technical baselines. See the Title II guide for that context.
Questions before you start
Does a passing PDF/UA report establish Section 508 conformance?
No. Use it as supporting PDF-specific evidence, then evaluate the applicable WCAG 2.0 A and AA requirements and the agency’s acceptance criteria.
What should a contractor retain?
Keep the reviewed deliverable and its testing record together. Agree with the agency on any additional review, exceptions, or product-level procurement documentation.