Section 508 vs WCAG 2.1 AA: What Federal Procurement Actually Requires
A vendor selling to a federal agency gets asked about Section 508. A vendor selling to a city gets asked about Title II. Both questions point at WCAG, but at different versions, and the difference decides what the conformance report has to say.
What Section 508 actually covers
Section 508 of the Rehabilitation Act applies to federal agencies, not to private business generally. It requires federal agencies to make the information and communication technology they develop, procure, maintain, or use accessible to people with disabilities. The 2017 refresh of the 508 standards incorporated WCAG 2.0 Level A and AA by reference, so the technical bar for a federal site is WCAG 2.0 AA, plus the 508-specific requirements for hardware, software, and documentation.
The practical consequence lands on vendors, not agencies alone. A federal procurement asks the vendor for an Accessibility Conformance Report, usually built on the Voluntary Product Accessibility Template, the VPAT. The VPAT lists each WCAG criterion and states whether the product supports it, partially supports it, or does not support it, with remarks. A VPAT that says supports on every line without evidence is worthless, and contracting officers have learned to check.
The 508 standards also reach further than WCAG does. They cover things WCAG never touches: the accessibility of the product documentation, the support services around it, and the interoperability of software with assistive technology. A product can pass WCAG 2.0 AA and still fail 508 on its documentation, which is why the VPAT has chapters beyond the WCAG table.
Where Title II differs
Title II of the ADA covers state and local government, and its 2024 rule names WCAG 2.1 Level AA, a newer version with 50 success criteria against 2.0's 38. The compliance dates moved in April 2026 to April 26, 2027 for larger entities and April 26, 2028 for smaller ones, but the version named is still 2.1. A product that meets 2.1 AA necessarily meets 2.0 AA, so a vendor conforming to 2.1 covers both statutes with one program. Related reading: Watching Third Party Payment Buttons: Iframes, Titles, and Tab Order.
Section 504 adds a third path. Organizations that receive federal funding, which includes most hospitals, universities, and many nonprofits, must make their web content meet WCAG 2.1 AA under a 2024 rule of its own. A hospital website can therefore be covered by 504 even though it is not a federal agency and not a government entity. The three statutes overlap heavily, and the overlap is the plan: one remediation program, aimed at 2.1 AA, with conformance reports written to the statute each buyer cites.
None of this reaches a private company that neither sells to the government nor takes federal money. That company faces Title III instead, which has no technical standard, only the general prohibition on discrimination and a growing body of settlements that all point at WCAG 2.1 AA in practice. More on this: 3,117 Federal Filings in 2025, and Ecommerce Took the Biggest Share.
What to put in the conformance report
Name the version and the level, WCAG 2.1 Level AA, and the date of the test. List the criteria that partially support or do not support, with the specific failure and the remediation date, because a report that hides the gaps is worse than no report: it becomes an exhibit. And test with the product as sold, not a demo build. The demo with the accessibility features switched on is the oldest trick in this market, and buyers have seen it.
Frequently asked questions
Does Section 508 apply to my company?
Only if you sell information technology to a federal agency, or receive federal funding under Section 504. A purely private company with no federal customers is covered by Title III instead.
Is WCAG 2.1 enough for Section 508?
Yes. Section 508 incorporates WCAG 2.0, and conforming to 2.1 AA covers every 2.0 criterion. Aim at 2.1 and both statutes are satisfied.
What is a VPAT?
The Voluntary Product Accessibility Template, the standard form for an Accessibility Conformance Report. It lists each criterion with a support level and remarks, and federal buyers expect one with every procurement.
Does Section 508 cover mobile apps?
Yes. The 508 standards apply to software and mobile applications procured or developed by federal agencies, not only to websites.