Recommendations

Recommendations to Federal Agencies

1. Strengthen leadership support and accountability for Section 508 compliance

   1. Reinforce that Chief Information Officers (CIO) lead the integration of Section 508 across the ICT lifecycle, embedding accessibility controls into existing processes, infrastructure, and governance using current staff and resources.

   2. Include Section 508-related metrics in CIO performance plans.

2. Integrate Section 508 into core risk management frameworks

   1. Treat ICT accessibility as an integral part of agencies’ already established security, privacy, and risk management lifecycles.

   2. Integrate Section 508 compliance into the risk analysis for major ICT investments and ATO reviews to ensure ICT accessibility is a part of core IT governance.

3. Use acquisition as a primary lever for Section 508 compliance

   1. Leverage the buying power of the federal government by prioritizing “buy over build” and evaluating ICT through accessibility conformance reports (ACRs) to validate the accuracy of vendor conformance claims.

   2. Systematically track and document all exceptions, including “Best Meets” determinations, and use this data to inform contract reviews, identify recurring accessibility gaps, and guide procurement decisions.

   3. Incorporate accessibility performance into contract renewals, past performance evaluations, and future award considerations.

   4. Reject contract deliverables that fail to meet Section 508 requirements to ensure agencies only pay for ICT products and services that meet federal standards and contractual obligations.

   5. Require all ICT contracts to include defined testing methodologies and right-to-repair provisions to ensure vendors fix, replace, or correct non-conforming products at their own expense.

      Verification and enforcement steps lag with almost half of all agencies only “sometimes”, “rarely”, or “never” verifying contract deliverables for Section 508 conformance.

4. Strengthen and optimize Section 508 resourcing and governance

   1. Leverage shared services, federal buying power, common tools, and cross-government expertise to improve ICT accessibility outcomes at lower cost and to deliver greater value to the taxpayer.

   2. Prioritize the procurement and use of accessible authoring tools to enable the creation of accessible content by default, reducing the introduction of accessibility defects at the source, lowering or eliminating remediation and rework costs, and accelerating delivery of accessible digital content and services.

      Forty-three agencies failed to respond to the FY 2025 assessment and more than half of responding agencies cited resource limitations.

5. Require annual role-based Section 508 training

   1. Require annual Section 508 training for all employees who create, maintain, or contribute to agency ICT by embedding accessibility training by roles and responsibilities into mandatory onboarding and annual learning requirements.

      55% of agencies do not provide Section 508 training tailored to specific roles despite the fact that key personnel, including those in acquisitions, developers, document authors, web content managers, and testing staff, have direct responsibility for Section 508 compliance.

   2. Use guidance and training resources on Section508.gov to integrate Section 508 principles, checkpoints, and accessibility risk awareness into training related to content authoring, generative artificial intelligence (AI), automation, data science, and digital modernization.

   3. Ensure personnel whose position descriptions include responsibility for handling Section 508-related complaints complete role-specific training on intake, triage, documentation, and resolution workflows, including coordination with civil rights, legal, and ICT accessibility offices.

   4. Identify the highest-priority training gaps using compliance findings, complaint trends, and internal audit results, and address them through targeted upskilling via role-based courses, hands-on workshops and labs, and communities of practice.

6. Expand Section 508 conformance validation and remediation

   1. Expand automated and manual Section 508 conformance testing, validation, and defect remediation before deployment.

   2. Apply a risk-based approach that prioritizes high-impact and high-use ICT, with targeted manual testing and remediation efforts for ICT supporting public-facing information, services, benefits, and programs.

   3. Align agency testing methodologies with the Baselines for Web and Electronic Documents to ensure comprehensive coverage of requirements and support the effective use of generative AI.

   4. Leverage existing AI tools and train staff to configure and prompt these tools to automatically generate, evaluate, and remediate digital content for conformance to Section 508 standards.

      The average conformance continues to be under 2 on a 5-point conformance index scale with an average of 23% of agencies not able to test top viewed ICT.
      Generative AI systems produce new content, such as text, images, or documents. Agencies may leverage generative AI to create electronic documents or web pages. To ensure content generated or assisted by AI consistently adheres to Section 508 requirements before publication or deployment, it is beneficial if agency testing methodologies are aligned with the Baselines for evaluation.