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

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

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

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”.

Did you know?

  • In the United States, about 55 million people have a disability (src: 2010 U.S. Census).
  • About 1 in 5 Americans have some kind of disability (src: 2010 U.S. Census).
  • The percentage of people affected by disabilities is growing as our population ages.
  • Two popular, free screen readers are VoiceOver (Mac OS and iOS) and NVDA (Win).
  • Good accessibility practices can improve the search ranking of your website.
  • Form fields without labels can cause problems for some assistive technology users.
  • Low color contrast makes content difficult to see, especially for users with low vision.
  • Documents linked on a website need to be accessible too (e.g., PDF and Word files).
  • Audio content, like podcasts, need transcripts for deaf or hard of hearing users.
  • Online videos should be captioned for deaf or hard of hearing users.
  • Using HTML tags correctly is very important for accessibility.
  • Descriptive link text helps make a website more accessible. Avoid using "Click here" or "Read more."
  • A "screen reader" is an application that reads content aloud to a user.
  • There is no "alt tag" in HTML. "Alt" is an attribute used with the img tag.
  • HTML uses the alt attribute to provide a text description of an image.
  • Alt text should describe an image, if the purpose of the image is to convey information.
  • If an image is a link, the alt text for the image should explain where the link goes.
  • If an image is only being used for decoration, the alt text should be null (i.e., alt="").
  • If a table has headers, using header tags (<th>) will make the table more accessible.
  • An accessible website is one that can be navigated and understood by everyone.