What is a VPAT and when do we need one?

A Voluntary Product Accessibility Template (VPAT) documents how your product conforms to Section 508 standards. Most agencies require a current VPAT as part of the acquisition process whenever EIT products or services are procured.

Does Section 508 apply to internal-use software?

Yes, if Federal employees will use it. Section 508 covers all EIT procured or developed for Government use, including internal tools, unless an agency-approved exception applies (undue burden, fundamental alteration, or national security).

What is the difference between Section 508 and WCAG?

Section 508 is a U.S. law. WCAG (Web Content Accessibility Guidelines) is the international technical standard. The 2017 Section 508 refresh incorporated WCAG 2.0 Level AA by reference, so meeting WCAG 2.1 Level AA satisfies the web-based portion of Section 508.

What happens if our product has Section 508 gaps at delivery?

The agency can reject the deliverable, require remediation before acceptance, withhold payment, or terminate for default. Document any known gaps in your VPAT and discuss remediation timelines proactively with the contracting officer.

High RiskFARAccessibility

Section 508 — Section 508 Accessibility Requirements

Last updated: 2026-04-09

Researched by the BidStride Research Team

What This Clause Requires

Electronic and information technology (EIT) developed, procured, or used must conform to Section 508 of the Rehabilitation Act. Deliverables must meet WCAG 2.1 Level AA standards.

Official Regulation Text

See 36 CFR Part 1194 and FAR 39.2 for the full regulatory text. Section 508 of the Rehabilitation Act requires that all electronic and information technology developed, procured, maintained, or used by Federal agencies be accessible to people with disabilities.
Source: eCFR, 48 CFR Section 508 (36 CFR Part 1194; FAR 39.2)

Compliance Checklist

All EIT deliverables must conform to applicable Section 508 standards
Provide a Voluntary Product Accessibility Template (VPAT) or Accessibility Conformance Report (ACR)
Test against WCAG 2.1 Level AA criteria
Document any exceptions with justification
Include accessibility testing in acceptance criteria

Flow-Down to Subcontractors

Flow-down required

This clause must be included in subcontracts with all subcontractors at all tiers where the subcontractor will perform work covered by this clause. Typically appears in contract Sections C, H, L, M.

Frequently Asked Questions

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This summary is for informational purposes only and reflects the BidStride Research Team's plain-English interpretation of the regulation. It is not legal advice and does not constitute an attorney-client relationship. Always consult the official Federal Acquisition Regulation (FAR) or Defense Federal Acquisition Regulation Supplement (DFARS) text and qualified legal counsel for compliance decisions.