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Integrating Section 508 Data into Asset Management and GRC Tools

Integrating Section 508 conformance data, such as test reports or Accessibility Conformance Reports (ACR) into IT product portfolios—like asset and application inventories or Governance, Risk, and Compliance (GRC) tools—is crucial for ensuring Section 508 conformance across an agency’s digital ecosystem. Effective execution of these practices supports informed procurement decisions, facilitates audits, strengthens governance, and enhances risk management, all while optimizing documentation storage.

Asset Inventory Tools

Federal agencies track their information and communication technology (ICT) in an inventory of information systems and each agency may have a different name for their inventory, asset management system, or model. Regardless of the specific system, Section 508 conformance should be integrated. This integration enables users to easily determine if a product is conformant and identify any existing barriers to accessibility.

Tip: Require each Section 508-related field to be filled out when a new product is listed. This may involve integrating Section 508 conformance questions during intake and as part of IT governance.

Consider updating the inventory to include the following fields:

  • Ownership, if not already implemented in the tool.
  • Section 508 conformance status such as Fully Conformant, Partially Conformant, Not Conformant, or Not Tested. This helps users easily identify products with ICT accessibility defects.
  • For any product not fully conformant, include a documented remediation plan with responsible party and target resolution date.
  • Date of Section 508 evaluation.
  • Link to the conformance report such as a test report or ACR.
  • Link to the accommodation plan or documentation of alternate means of access, if applicable. This will help users understand barriers and methods to overcome them.
  • Section 508 exception identification number, if applicable.

A new test report, demonstrating Section 508 conformance of the version currently in use, should be acquired and linked within the tracking tool whenever a product is updated to a new version.

Tip: All Section 508-related data fields should be reviewed by a designated accessibility compliance officer such as the agency's Section 508 Program Manager, member of the Section 508 Program or other designee, or control owner before entry is finalized. Agencies should establish periodic data quality checks to ensure records reflect an accurate and current conformance status of each ICT product.

GRC Tools

Federal agencies utilize Governance, Risk, and Compliance (GRC) tools to centralize, standardize, and automate the management of policies, risks, audits, and compliance activities.

While the exact GRC tool or platform may vary, most allow:

  • Custom risk and control libraries
  • Workflow automation
  • Role-based access and evidence tracking
  • Integration with development pipelines

By aligning Section 508 controls with existing digital policy mandates such as Modernizing the Federal Risk and Authorization Management Program (FedRAMP) (M-24-15), agencies can unify information and communication technology (ICT) accessibility with IT governance. Where possible, agencies should align Section 508 controls with related compliance domains, such as information security, privacy, and records management, to enable unified workflows and reduce duplication of compliance activities. Integrating Section 508 into the agency’s GRC tools ensures ICT accessibility is not treated as an afterthought, but rather as a managed and measurable part of the agency’s overall risk and compliance posture. Per M-24-15 agencies should “[e]nsure that agency governance, risk, and compliance (GRC) tools and system inventory tools can produce, transmit, and ingest machine readable authorization artifacts using OSCAL or any succeeding formats as identified by FedRAMP”.

Agencies must ensure GRC and inventory tools themselves meet Section 508 requirements. This includes conducting accessibility testing of the platforms, reviewing vendor ACRs, and documenting alternate access methods if full conformance is not possible.

The following table outlines the integration of Section 508 considerations into GRC tools, detailing the actions, steps, and expected outcomes.

Table 1: Section 508 actions, GRC Integration Steps, and Expected Outcomes
Action GRC Integration Steps Expected Outcome
Update IT and digital service governance policies to include Section 508 requirements.
  • Create a Section 508 policy artifact in the GRC policy library.
  • Tag it as applicable to all systems, software development, content publication, and acquisitions.
 Section 508 becomes a tracked policy with associated controls and oversight.
Add ICT accessibility or Section 508 compliance as a specific risk type or sub-risk category under IT risk.
  • Identify critical risks including: funding implications for rework, investment in inaccessible ICT that cannot be deployed, legal liabilities, and user impact.
  • Assign frequency, consequence or likelihood, and mitigation strategies.
 Section 508 risks are visible and evaluated in enterprise risk frameworks.
Develop and document controls specifically aligned with Section 508 Standards.
  • Add these as technical controls such as "All public-facing applications undergo Section 508 conformance testing before release".
  • Link to Section 508 Standards.
 Section 508 becomes part of internal control frameworks and audit readiness.
Require evidence of Section 508 conformance at key software development lifecycle (SDLC) phases.
  • Use GRC workflows to enforce gated approvals and determine when they cannot pass to deployment without Section 508 test results.
  • Require upload of artifacts. At minimum, require an accessibility test report or ACR, and remediation plans for any defects.
 Section 508 becomes a condition for development and change control approvals.
Use integrations with scanning tools or test report applications to feed test results into GRC dashboards.
  • Link test results to compliance evidence and trigger remediation workflows.
  • Track compliance trends and exceptions across systems and programs.
 Continuous monitoring supports proactive Section 508 compliance.
Designate responsible roles in the GRC tool for ICT accessibility oversight.
  • Assign control owners, approvers, and remediation leads to each Section 508-related control.
  • Use reminders, escalation paths, and review workflows to maintain accountability.
 Clear lines of responsibility reduce the risk of compliance gaps.
Make Section 508 part of internal and external IT and system audits.
  • Add Section 508 to compliance checklists and audit criteria.
  • Record test reports and required remediation in audit modules.
 Demonstrable evidence of Section 508 oversight supports Office of Management and Budget (OMB), GSA, and Department of Justice (DOJ) reporting requirements.

Procurement Integration

Procurement teams should verify Section 508 conformance status and review test reports before awarding new contracts or renewing existing ICT procurements. The agency’s inventory of information systems or GRC system should serve as a source of record for this review, and solicitations should require vendors to provide updated accessibility conformance documentation.

Monitoring and Maintenance

Agencies should regularly monitor their IT portfolio and tracking systems to ensure governance policies and procedures are followed. It is recommended that IT is assessed every 12-36 months or on a frequency based on risk assessment of non-conformant IT, to determine if conformance status has changed. If retesting after a product update identifies significant new accessibility barriers, the agency should log the defect in the GRC system, initiate remediation workflows, and, where feasible, revert to a prior accessible version until the issue is resolved.

Reviewed/Updated: September 2025

Section508.gov

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