GSA Government-wide Section 508 Accessibility Program

Instructions - Revised 508 Standards Applicability Checklist

The Revised 508 Standards apply to all information and communication technology (ICT) Federal agencies buy, build, maintain or use.  As a best practice, use the Revised 508 Standards Applicability Checklist to determine how the Standards specifically apply to each item that contains ICT (ICT item), particularly when developing or procuring new ICT.

These instructions will help you correctly determine which standards and exceptions apply to your ICT item. Compliance is required as of January 18, 2018, but feel free to adopt the Revised 508 Standards now, particularly where they meet or exceed the Original 508 Standards.

Process Overview

Step 1: Inventory Your ICT

Review the business requirements of your project or acquisition to identify which major components contain ICT. ICT items include such things as software, hardware, electronic content, support documentation & services. When conducting a procurement, review the Revised 508 Standards Applicability Checklist for each ICT item. (Note, GSA is currently developing a new tool to automate this checklist.)

  • ICT items may be comprised of:
    • Commercial-off-the shelf (COTS)
    • Government-off-the shelf (GOTS)
    • Custom-developed products
    • Configuration, installation, integration, maintenance, and hosting services for COTS, GOTS, and custom-developed products
  • Each ICT item will fall under at least one of four categories:
    • Electronic Content
    • Software
    • Hardware
    • Support Documentation & Services
  • In some cases, an ICT item may fall under more than one category (e.g., products and services that have multiple ICT features and functions combined into one solution).

ICT Examples - Electronic Content

  • Websites and web-based content (e.g., internet and intranet sites, web pages, applications)
  • Enterprise, web, and client applications (e.g., time and attendance software, office productivity applications, web forms/applications, call center or customer rep workflow applications, electronic fillable forms)
  • ICT software infrastructure (e.g., document repositories, content management systems, systems/network administration software, operating systems)
  • Training materials (e.g., online training materials, tests, online surveys)
  • Multimedia (video/audio)
  • Digital content (e.g., documents, templates, forms, reports, surveys)
  • Interactive maps
  • Electronic emergency notifications
  • Subscription services (e.g., news feeds, alert services, professional journals)

ICT Examples - Software

  • Software as a Service (SaaS)
  • Platform as a Service (PaaS)
  • Infrastructure as a Service (IaaS))
  • Desktop and server-based software applications
  • Cloud hosted software applications
  • Mobile applications
  • Operating systems
  • Open source software
  • Content management systems
  • Online collaboration tools
  • Document management systems
  • Authoring tools (e.g., Microsoft Office, PDF converters, Adobe Acrobat Professional)
  • Remote access software
  • User authentication software
  • Virtual meeting tools (e.g., VOIP, text messages, screen shares, remote meetings)
  • Learning management systems
  • Other software infrastructure

ICT Examples - Hardware

  • Computers & laptops
  • Servers
  • Tablets
  • Printers and copiers
  • Document scanners
  • Multi-function office machines
  • Peripheral equipment (e.g.,  keyboards, mice)
  • Information kiosks and transaction machines
  • Mobile phones

ICT Examples - Support Documentation and Services

  • Training Services
  • Help Desk or call center
  • Automated self-service & technical support
  • Product documentation

Considerations for Complex Solicitations

Use the chart below to figure out which ICT items will need a checklist, for solicitations that include multiple ICT products, services, or components. (Note, the GSA Accessibility Requirements Tool (ART) (in development) will generate a list of accessibility requirements for each ICT item, and compile them into one requirements listing, broken out by ICT Item.)

Type of ICT Item

Checklists Needed

Single commercial off-the-shelf (COTS) item

Prepare one checklist for the item, including required support services and electronic documentation.

Multiple commercial off-the-shelf (COTS) items

Prepare a separate checklist for each COTS item, including required support services and electronic documentation.

Single custom developed, configured, or installed item that contains ICT

Prepare one checklist for the item, including all ICT components, as well as required support services and electronic documentation.

Multiple custom developed, configured, or installed items that each contain ICT

Prepare a separate checklist for each item, including required support services and electronic documentation.

ICT support services only

Prepare one checklist for the support services and documentation only.

Step 2: Determine Exceptions

A full list of exceptions is detailed in the Standards under E202 General Exceptions. Refer to your agency’s Accessibility policy to identify when formal approval by an agency representative is required to claim any of the following exceptions:

E202.2 Legacy ICT Exception

Agencies may claim a “Safe Harbor” for existing ICT that was accessible and compliant with the earlier standard on or before January 18, 2018 and has not been subsequently changed to affect interoperability, the user interface, or access to information or data. This safe harbor applies on a component basis (each component or portion of existing ICT must be assessed separately). For federal government ICT, this exception can only be claimed by federal agencies and components.

If all these conditions apply, legacy ICT components do not need to be remediated to conform to the Revised 508 Standards:

  • The legacy ICT was deployed, altered, or procured within the government on or before January 18, 2018;
  • The legacy ICT conformed to the Electronic and Information Technology Accessibility Standards as originally published on December 21, 2000, or qualified for an exception under these Standards before January 18, 2018;
  • No changes were made to the legacy ICT affecting interoperability, the user interface, or access to information or data after January 18, 2018.

Decision Questions

If the answer to all questions is “yes”, this exception applies.

  1. Did your agency deploy, maintain, or use the ICT on or before January 18, 2018?
  2. Is the ICT known to have conformed to the Electronic and Information Technology Accessibility Standards as originally published, prior to January 18, 2018?
  3. Since January 18, 2018, has the ICT remained unchanged regarding interoperability, the user interface, or access to information and data?

E202.3 National Security Systems Exception

This exception applies to ICT operated by agencies as part of a national security system, as defined by 40 U.S.C. 11103(a). For federal government ICT, this exception can only be claimed by federal agencies and components. This exception cannot be claimed by vendors and contractors.

Decision Questions

If any of the following apply, your ICT may qualify for this exception:

  1. Involves intelligence activities;
  2. Involves cryptologic activities related to national security;
  3. Involves command and control of military forces;
  4. Involves equipment that is an integral part of a weapon or weapons system; or
  5. Is critical to the direct fulfillment of military or intelligence missions (does not include routine administrative and business applications such as payroll, finance, logistics, and personnel management).

E202.4 Federal Contracts Exception

This exception applies to ICT acquired by a contractor incidental to a contract. For federal government ICT, this exception can only be claimed by federal agencies and components.

This exception does not apply, IF:

  • The ICT will revert to government ownership;
  • The government directly procures the ICT; or
  • Members of the public or government employees use the ICT.

Decision Questions

If the answer to all questions is “yes”, this exception applies.

  1. Is the vendor or contractor procuring the ICT?
  2. Will ONLY vendor or contractor personnel access or use the ICT?
  3. Will ownership of the ICT remain with the vendor or contractor upon completion of the contract?

E202.5 ICT Functions Located in Maintenance or Monitoring Spaces Exception

This exception applies to status indicators and operable parts for ICT functions located in spaces that are frequented only by service personnel for maintenance, repair, or occasional equipment monitoring. (Similar to the “Back Office Exception” allowed under the original 508 Standards, but scope is more limited.) For federal government ICT, this exception can only be claimed by federal agencies and components.

Decision Questions

If the answer to all questions is “yes”, this exception applies.

  1. Does the ICT have status indicators or operable parts (i.e., physical controls)?
  2. Is the ICT located in spaces that are frequented only by service personnel for maintenance, repair, or occasional monitoring of equipment (i.e., on a rack mounted in a wiring closet)?

E202.6 Undue Burden or Fundamental Alteration Exception

Conformance to the Revised 508 Standards is required only when it does not impose an undue burden, or result in a fundamental alteration in the nature of the ICT. This exception is available only to federal agencies and components.

  • E202.6.1 Basis for a Determination of Undue Burden - Consider the extent to which conformance would impose significant difficulty or expense, including availability of resources.
  • E202.6.2 Required Documentation - Document in writing an explanation of why and to what extent it’s an undue burden on the agency, or would result in a fundamental alteration in the nature of the ICT.
  • E202.6.3 Alternative Means - Provide individuals with disabilities access to, and use of, information and data by an alternative means that meet identified needs.

Evaluating Undue Burden

Use this exception only in rare circumstances, where the cost to make ICT fully conform with the Standards would consume a significant amount of available program resources, or when conformance would present substantial difficulty.

When acquiring, developing or customizing ICT, evaluate for applicability of this exception:

  • Off-the-shelf (COTS/GOTS) ICT products, services or upgrades - After performing market research to understand the applicability of the Standards and alternatives available.
  • Custom designed ICT - After the business needs for the new functionality and features are defined.

The undue burden exception applies only to the specific features or functions of the ICT that cannot be made to conform to the Revised 508 Standards without imposing an undue burden on the agency or component.

  • To claim this exception for the entire ICT item, you must determine that ALL features and functions of the ICT product or service cannot conform to the Revised 508 Standards without imposing an undue burden (significant difficulty or expense).
  • If only SOME features and functions of the ICT product or service would impose an undue burden (significant difficulty or expense), you can only claim the exception for those features and functions. You must support compliance for the remaining items.

The federal agency or component that owns (or will own) the ICT product or service must:

  • Decide that conformance to the Standards would impose an undue burden;
  • Assess costs relative to resources if claiming the exception based on expense; and
  • Assess the difficulties in achieving conformance to claim the exception based on difficulty.

Contact the US Access Board for guidance on how to evaluate the applicability of an exception for undue burden. You may also want to consult with legal staff who are familiar with case law involving Undue Burden claims under Section 508 or related civil rights laws. For federal government ICT, this exception can only be claimed by federal agencies and components.

Decision Questions

If the answer to all questions is “yes”, your ICT may warrant this exception.

  1. Have you determined that conformance for some or all features and functions of the ICT item would result in an undue burden on your agency or component?
  2. Have you quantified the resources available to the program or component for which the ICT is to be procured, developed, maintained, or used?
  3. Has the responsible agency official documented in writing how the difficulty or expense is significant, relative to the resources available? For example:
    1. What % of the expense equals total budget available?
    2. Explain exactly what is significantly difficult, and why.
  4. Does your documentation address whether the exception is being claimed for the entire ICT Item, or only specific features and functions?
  5. Will the agency provide an alternative means for users with disabilities for the features and functions for which you are claiming this exception?

Evaluating Fundamental Alteration

Use this exception only when conformance to the Revised 508 Standards would alter the inherent design of the ICT to the extent that it no longer adequately meets the agency’s business need.

When acquiring, developing or customizing ICT, evaluate for applicability of this exception:

  • Off-the-shelf (COTS/GOTS) ICT products, services or upgrades - After performing market research to understand the alternatives available.
  • Custom designed ICT - After outlining the intended purpose of the ICT and developing the preliminary design.

The exception for fundamental alteration applies only to the specific features or functions of the ICT that cannot conform to the Revised 508 Standards without fundamentally altering the nature of the ICT. For federal government ICT, this exception can only be claimed by federal agencies and components.

  • In order to claim the fundamental alteration exception for the entire ICT you must determine that ALL the features and functions of the ICT cannot conform to the Revised 508 Standards without fundamentally altering the nature of the ICT.
  • If only SOME features and functions cannot conform without fundamentally altering the nature of the ICT, you can only claim the exception for those features and functions that would be fundamentally altered. You must support compliance for the remaining items.

Decision Questions

If the answer to all questions is “yes”, your ICT may warrant this exception.

  1. Have you determined that conformance to the Standards would fundamentally alter some or all of the features and functions, such that the ICT would not meet the agency’s business needs?
  2. Has the responsible agency official documented in writing the basis for determining that conformance would result in a fundamental alteration in the nature of the ICT?
  3. Does your documentation address whether the exception is being claimed for the entire ICT, or only specific features and functions of the ICT?
  4. Will the agency provide an alternative means for users with disabilities for the features and functions for which you are claiming this exception?

E202.7 Best Meets Exception

When ICT that fully conforms to the Revised 508 Standards is not commercially available, procure ICT that conforms best with the Standards, consistent with meeting the agency’s business needs. For federal government ICT, this exception can only be claimed by federal agencies and components.  

  • E202.7.1 Required Documentation - The responsible agency official must document in writing:
    • The non-availability of ICT that fully conforms to the Standards, including a description of market research performed and which provisions cannot be met; and
    • The basis for determining that the ICT to be procured best meets the Standards consistent with meeting agency business needs.
  • E202.7.2 Alternative Means - Provide individuals with disabilities access to and use of information and data by an alternative means that meets identified needs.

The best meets exception provides a mechanism to help agencies balance business needs and obligations to procure ICT Items that conform to the Revised 508 Standards when an alternative that fully conforms is not available. Similar to “commercial non availability” in the original 508 Standards, but now formally addressed as an exception.

In determining best meets, consider the use of an equivalent design or technology to address the Standards when assessing overall conformance.  Refer to E101.2 of the Revised Standards to learn how to assess the role of equivalent facilitation.

  • During a technical evaluation:
    • If one or more alternatives fully conform to the Revised 508 Standards, select one of these alternatives when making selection(s) for award.
    • If no alternative fully conforms, select the alternative that best meets the Standards when making an award; the best meets determination is based on the relative degree of conformance of the ICT item offered.
  • Where multiple ICT products, services, or components are bundled into a single ICT item, a best meets determination should compare one combined solution or item with another, unless the agency can select individual ICT products, services, or components from separate offers. Refer to considerations for complex solicitations above.
  • When selecting an alternative that only partially conforms, the responsible agency official must:
    • Document the basis for the determination, including market research conducted and why the selected ICT best meets the Revised 508 Standards. Provide information on:
      • What ICT alternatives were evaluated;
      • The lack of a fully conforming solution that meets the business needs;
      • The degree of 508 conformance of the ICT selected, as compared to the degree of conformance of the ICT that were not selected; and,
      • The steps taken to evaluate the degree of conformance (e.g., 508 expert VPAT review, vendor 508 test results, or vendor test results)
    • Provide an alternative means that meets the identified needs of people with disabilities not supported by the ICT Item(s).
  • For “brand name or equivalent” COTS or GOTS solicitations, the supporting documentation used to justify the acquisition may be sufficient to fulfil the documentation requirements. If the “brand name” ICT item does not fully support the Revised 508 Standards, the agency is still responsible for providing individuals with disabilities access to the non-conforming functions and features of the ICT Item through an alternative means that meets their identified needs.

Decision Questions

If the answer to all questions is “yes”, your ICT item may warrant this exception.

  1. Have you completed market research addressing Section 508 compliance for the ICT Item?
  2. Did you evaluate Accessibility Conformance Reports or test results to validate 508 conformance claims?
  3. Did you document the market research performed to validate 508 conformance claims?
  4. Of the ICT items which met business needs, were there no options that fully conformed to the Revised 508 Standards?
  5. Are you purchasing the ICT Item that best meets the Revised 508 Standards?
  6. Will the agency provide an alternative means for users with disabilities for the features and functions that do not conform to the Revised 508 Standards?

Step 3: Determine Which Standards Apply

Follow the steps below to identify which Standards apply to each ICT item:

  • Select the type of ICT, then answer the questions
  • If your ICT item falls under a single category:
    • Select the category that best fits, and only answer those questions
  • If your ICT item spans multiple categories (e.g., a VOIP IP solution that includes both hardware and software):
    • Answer the questions under each relevant category
  • Record your responses in the Revised 508 Standards Applicability Checklist

Note, this step is not required if your entire ICT item is eligible for any of the exceptions, except the Best Meets exception. If only some components of the ICT item qualify for an exception, the applicability of the Standards must be determined for the remaining components.

ICT Type - Electronic Content

Question 1 - Is the content comprised of records maintained by the National Archives and Records Administration (NARA) pursuant to Federal recordkeeping statutes?

  • If Yes, the electronic content component of the ICT item does not have to conform to the Revised 508 Standards.
    • If the ICT contains hardware or software components, proceed below to those sections, below.
  • If No, proceed to Question 2

Question 2 - Will the content be public-facing?

  • If Yes, proceed to Question 4
  • If No, proceed to Question 3

All public facing electronic content must be accessible. The standards define “public facing” as content made available by an agency to members of the general public. Section E205 of the Revised 508 Standards specifies which electronic content, including web, software, multimedia and electronic documents, must conform to the technical requirements. Usually, public facing content is published on the web (for example, on an agency website, blog, form, or social media page). However, public facing content might also be made available in non-web formats, such as information displayed on screens or interactive kiosks in waiting areas.

Question 3 - Will the content be an official agency communication that is not public-facing?

  • If Yes, proceed to Question 4
  • If No, the electronic content component of the ICT item does not have to conform to the Revised 508 Standards.
    • If the ICT contains hardware or software components, proceed below to those sections.

Electronic content that is not public facing but is official business, and is communicated through one or more of the nine categories below is an “agency official communication” and must be accessible. The content might be broadly disseminated or sent to individual agency employees or members of the public. The method of delivery does not determine whether electronic content is “agency official communication.” Such content may be disseminated via an internal agency website or intranet, or by other delivery modes. Common transmittal means include, but are not limited to: emails, text messages, phone alerts, storage media, and downloadable documents.

The nine categories of agency official communication (with examples) are listed below.  All of the following examples are provided to help provide further understanding of these categories. The examples are not all-inclusive. Contact the U.S. Access Board for assistance with interpreting and applying these categories.

  1. Emergency notifications - Examples include: evacuation notices, active shooter alerts, text messages conveying emergency instructions (e.g., “remain in place”), hazardous weather alerts, and operational notices regarding unscheduled closures.
  2. An initial or final decision adjudicating an administrative claim or proceeding - Examples include: an electronic notice or alert of an approved, denied, or pending claim sent to a business or other organization, or to an individual.
  3. Internal or external program or policy announcements - For example, an electronic notification of a new agency policy or a change to an existing program requirement.
  4. A notice of benefits, program eligibility, employment opportunity, or personnel action - For example: an electronic notice sent to a member of the public or employee describing government benefits to which they are entitled; information on whether an individual is eligible for benefits from, or can participate in a government program; information on the status of an application for enrollment in a program; notification of an official personnel action indicating a promotion, adverse action, or other personnel decision affecting a government employee; a job announcement.
  5. A formal acknowledgment of receipt - For example: an email acknowledging receipt of payment; a notice posted to a program participant’s web page containing his or her personal account information and acknowledging that he or she successfully submitted certain records.
  6. Survey questionnaires - Examples include: a set of written questions (open-ended or multiple choice) developed for the purpose of a survey or data analysis such as a questionnaire assessing employee training needs; an employee satisfaction survey; a questionnaire used to gather information related to gauging satisfaction with a government program. This category does not include questions submitted during litigation or legal proceedings.
  7. Templates or forms - For example: an electronic document template used to create official agency documents or presentations; a web page template created to establish a common look and feel for a website;  an official agency form that must be completed by employees or members of the public.
  8. Educational or training materials - Examples include: interactive online training courses; self-paced training course; educational webinars; other educational presentation formats; support materials for such activities including, electronic worksheets, training manuals, and tests. 
  9. Intranet content designed as a web page - For example: an intranet page listing files for downloading; shared calendars; an internal employee locator; and other html web pages distributed internally via an agency Intranet. This category does not include files within a listing distributed via the agency intranet that are not in one or more of the nine categories above.

NOTE: An exception provides that NARA is not responsible for remediating records sent to them by other agencies

Question 4 - Will the electronic content be web-based?

  • If Yes, the following Standards apply:
    • 302 Functional Performance Criteria
    • 602 Support Documentation
    • 603 Support Services
    • All WCAG A & AA Success Criteria
  • If No, the following Standards apply:
    • 302 Functional Performance Criteria
    • 602 Support Documentation
    • 603 Support Services
    • All WCAG A & AA Success Criteria apply except:
      • 2.4.1 Bypass Blocks
      • 2.4.5 Multiple Ways
      • 3.2.3 Consistent Navigation
      • 3.2.4 Consistent Identification

ICT Type - Software

Question 1 - Is the software assistive technology (i.e., any item, piece of equipment, or product system used to increase, maintain, or improve functional capabilities of individuals with disabilities)?

  • If Yes, the software component of the ICT item does not have to conform to the Revised 508 Standards.
    • If the ICT contains hardware components, proceed below to that section.
  • If No, proceed to Question 2

Question 2 - Will the software be web-based?

  • If Yes, the following Standards apply:
    • All WCAG A & AA Success Criteria
    • 502 Interoperability with Assistive Technology
    • 503 Application
    • 602 Support Documentation
    • 603 Support Services
    • 302 All Functional Performance Criteria
      1. Note: Applies when Chapter 5 does not address one or more functions of ICT (E204), or when an agency invokes “equivalent facilitation” (E101.2)
    • Proceed to Question 3
  • If No, the following Standards apply:
    • All WCAG A & AA Success Criteria apply – EXCEPT the following:
      • 2.4.1 Bypass Blocks
      • 2.4.5 Multiple Ways
      • 3.2.3.Consistent Navigation
      • 3.2.4 Consistent Identification
    • 502 Interoperability with Assistive Technology
    • 503 Application
    • 602 Support Documentation
    • 603 Support Services
    • 302 All Functional Performance Criteria
      • Note: Applies when Chapter 5 does not address one or more functions of ICT (E204), or when an agency invokes “equivalent facilitation” (E101.2)
  • Proceed to Question 3

Question 3 - Is the software also an authoring tool?

  • If Yes, the following additional Standards apply:
    • 504 Authoring Tools
  • If No, stop. No additional Standards for software apply.
    • If the ICT contains hardware components, proceed to the next section.

ICT Type - Hardware

Include the following:

  • 404 Preservation of Information Provided for Accessibility
  • 405 Privacy
  • 406 Standard Connections
  • 407 Operable Parts
  • 409 Status Indicators
  • 410 Color Coding
  • 411 Audible Signals
  • 602 Support Documentation
  • 603 Support Services
  • 302 All Functional Performance Criteria
  • If the ICT contains hardware components, proceed below to this section.
    • Note: Applies only when Chapter 4 does not address one or more functions of ICT (E204), or when an agency invokes “equivalent facilitation” (E101.2))

Also include the following, when applicable:

  • If the solution can only be accessed directly through the hardware (e.g., a kiosk), include:
    • 402 Closed Functionality
  • If the hardware support biometrics, include:
    • 403 Biometrics
  • If the hardware is required (or likely to) have display or touch screens, include:
    • 408 Display Screens
  • If the hardware is required to support two-way voice communications, include:
    • 412 ICT with Two Way Voice Communications
  • If the hardware is required to display multimedia content, include:
    • 413 Closed Caption Processing Technologies
    • 414 Audio Description Processing Technologies
    • 415 User Controls for Captions and Audio Descriptions

This guidance was developed by the U.S. Federal Government Revised 508 Standards Transition Workgroup. Members include the U.S. Federal CIO Council Accessibility Community of Practice, the U.S. Access Board, and the General Services Administration.

Page Reviewed/Updated: September 2017