Section 508 Refresh

On January 18, 2017, the Access Board published a final rule that jointly updates the requirements for information and communication technology (ICT) covered by Section 508 of the Rehabilitation Act and Section 255 of the Communication Act. The refresh harmonizes these requirements with guidelines and standards in the U.S. and abroad, including standards issued by the European Commission and with the Web Content Accessibility Guidelines (WCAG), a globally recognized voluntary consensus standard for web content and ICT.

This final rule is effective March 20, 2017. [Note: The Board changed the effective date to March 21, 2017, as indicated in a notice published on March 2, 2017.] However, compliance with the new section 508-based standards is required beginning January 18, 2018.

Safe Harbor Provision

The final rule contains a Safe Harbor Provision that states "legacy ICT that complies with the existing 508 Standards and has not been altered after the compliance date (i.e., one year after publication of the final rule) need not be modified or upgraded to conform to the Revised 508 Standards. However, when existing ICT is altered after the compliance date, such alterations must comply with the Revised 508 Standards." The provision allows for micro-compliance; which is compliance limited only to the elements updated on a page.

Update to Section 255 of the Telecommunications Act

Section 255 is the FCC's set of accessibility regulations for telecommunication equipment manufacturers and service providers. The previous update to section 255 occurred in 2000. The goal of the 255 refresh was to align the regulations with the reality of 21st century telecommunications technology - the smartphone and mobile technology in particular. Not only is telecommunication hardware subject to 255 regulations, but software that is integral to the device - for example, the contacts and phone dialing apps that come pre-loaded on smartphones - must also be compliant with section 255.

Comparing WCAG 2.0 to Original Section 508

The Section 508 Refresh incorporates WCAG 2.0, Level AA standard by inclusion. Below is a table that indicates whether newly incorporated WCAG standards are substantially equivalent to prior Section 508 requirements, or if they are new criteria that now must be considered.

WCAG 2.0 [Level]	Original Section 508	Summary	Change	Comment
1.1.1 Non-text Content [A]	1194.22(a)	Provides for text alternatives of images and other non-text content, including user interface components	Substantially Equivalent	Proposed standard provides additional detail for 8 common categories of non-text content.
1.2.1 Prerecorded Audio-only and Video-only [A]	1194.22(a)	Provides that prerecorded audio is available in a visible format and that silent animations are available in an audible format	Substantially Equivalent
1.2.2 Captions (Prerecorded) [A]	1194.22(b) and .24(c)	Provides for synchronized captioning of prerecorded video and multimedia.	Substantially Equivalent	Proposed standard distinguishes between live and prerecorded media.
1.2.3 Audio Description or Media Alternative (Prerecorded) [A]	1194.22(b) and .24(d)	Provides for audio description of prerecorded video and multimedia
1.2.4 Captions (Live) [AA]	1194.22(b) and .24(c)	Provides for captioning of live video and multimedia
1.2.5 Audio Description (Prerecorded) [AA]	1194.22(b) and .24(d)	Provides for audio description of live video and multimedia
1.3.1 Information and Relationships [A]	1194.22(e) through (h)	Provides that information, structure, and relationships conveyed visually are available to users of assistive technology Provides that semantic markup be used for headings, lists, emphasized or special text, and tabular data, including the association of data cells with their headers	Substantially Equivalent	Proposed standard is written broadly and is technology neutral, whereas existing standard is specific to HTML image maps and data tables.
1.3.2 Meaningful Sequence [A]	None	Provides for a reasonable and logical reading order when using assistive technology	New
1.3.3 Sensory Characteristics [A]	None	Provides that instructions are not conveyed only through sound, shape, size, or visual orientation	New
1.4.1 Use of Color [A]	1194.21(i) and .22(c)	Provides that information and prompts are not conveyed only through color	Substantially Equivalent	No technical difference.
1.4.2 Audio Control [A]	None	Provides that there is a way to stop, pause, mute, or adjust volume with audio that plays automatically	New
1.4.3 Contrast (Minimum) [AA]	None	Provides for specified contrast between foreground and background of text and images of text	New
1.4.4 Resize Text [AA]	None	Provides tor content that remains readable and functional when the font size is doubled	New
1.4.5 Images of Text [AA]	1194.21(f)	Provides for the use of text, as opposed to images of text	Substantially Equivalent	Proposed standard provides detail for two situations where images of text are permissible.
2.1.1 Keyboard [A]	1194.21(a)	Provides for functionality when using only the keyboard interface	Substantially Equivalent	Proposed standard clarifies the requirement by emphasizing the method of input, rather than the nature of the output.
2.1.2 No Keyboard Trap [A]	None	Provides that the keyboard focus is not trapped when the keyboard is used for navigation	New
2.2.1 Timing Adjustable [A]	1194.22(p)	Provides for flexible time limits	Substantially Equivalent	Proposed standard provides additional options to the single approach specified in the existing provision (that the user “be alerted and given sufficient time to indicate more time is required”).
2.2.2 Pause, Stop, Hide [A]	1194.21(h)	Provides for user control over moving, blinking, scrolling, and information that updates automatically	Substantially Equivalent	Proposed standard specifies options (pause, stop, hide, or control the frequency) instead of “displayable in at least one non-animated presentation mode”, and allows for when animation “is part of an activity where it is essential” (for example, data that is being updated in real time).
2.3.1 Three Flashes or Below Threshold [A]	1194.21(k) and .22(j)	Provides that nothing flashes more than three times per second, unless the flash is very small and does not contain too much red	Substantially Equivalent	Proposed standard takes into consideration the size and hue of the flash.
2.4.1 Bypass Blocks [A]	1194.22(o)	Provides for a skip navigation link or other means to bypass repetitive content	Substantially Equivalent	Proposed standard uses the phrase “blocks of content that are repeated” instead of just “repetitive navigation links”.
2.4.2 Page Title [A]	1194.22(i)	Provides for descriptive and informative page titles	Substantially Equivalent	Proposed standard is for all types of content instead of just HTML frames.
2.4.3 Focus Order [A]	None	Provides for a keyboard-oriented navigation order that is reasonable and logical Provides that links, form elements, and other user interface controls and components have a reasonable and logical navigation order	New
2.4.4 Link Purpose (In Context) [A]	None	Provides that the purpose of any link is understandable from its text or context	New
2.4.5 Multiple Ways [AA]	None	Provides for two or more means to locate content	New
2.4.6 Headings and Labels [AA]	None	Provides that headings and labels are descriptive	New
2.4.7 Focus Visible [AA]	1194.21(c)	Provides that the keyboard focus is visually apparent when using the keyboard to navigate	Substantially Equivalent	Proposed standard uses the phrase “indicator is visible” instead of “well-defined on-screen indication”.
3.1.1 Language of Page [A]	None	Provides that the default language of content is exposed to assistive technology	New
3.1.2 Language of Parts [AA]	None	Provides that changes in language are exposed to assistive technology	New
3.2.1 On Focus [A]	1194.21(l) and .22(n)	Provides that user interface components do not initiate a change of context when receiving focus	Substantially Equivalent	Proposed standard is explicit instead of having the requirement implicit in that “the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.”
3.2.2 On Input [A]	1194.21(l) and .22(n)	Provides that changing the setting of user interface components does not automatically cause a change of context	Substantially Equivalent
3.2.3 Consistent Navigation [AA]	None	Provides that repeated navigational components occur in the same relative order each time they are encountered	New
3.2.4 Consistent Identification [AA]	1194.21(e)	Provides that components having the same functionality are identified consistently	Substantially Equivalent	Proposed standard is for all types of content instead of just “bitmap images”.
3.3.1 Error Identification [A]	1194.21(l) and .22(n)	Provides that automatically detected input errors are identified and described in text to the user	Substantially Equivalent	Proposed standard is explicit instead of having the requirement implicit in that “the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.”
3.3.2 Labels or Instructions [A]	1194.21(l) and .22(n)	Provides for labels or instructions when content requires user input	Substantially Equivalent
3.3.3 Error Suggestion [AA]	None	Provides that the system makes suggestions for correction when input errors are automatically detected and suggestions are available	New
3.3.4 Error Prevention (Legal, Financial, Data) [AA]	None	Provides that when legal, financial, or test data can be changed or deleted the changes or deletions can be reversed, verified, or confirmed	New
4.1.1 Parsing [A]	None	Provides that significant HTML/XHTML validation and parsing errors in source code are avoided	New
4.1.2 Name, Role, Value [A]	1194.21(d)	Provides that sufficient information (including identity, operation, and state) about user interface components is available to assistive technology	Substantially Equivalent	Proposed standard uses the phrase “programmatically determined” instead of “available to assistive technology”.

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Section 508 Refresh

Safe Harbor Provision

Update to Section 255 of the Telecommunications Act

Comparing WCAG 2.0 to Original Section 508

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