What is Section 508 and How Does It Impact Your PDFs?

If your organization is part of the federal government or does business with the federal government (or wants to), you’ve probably heard of Section 508. “Section 508” refers to Section 508 of the Rehabilitation Act, which prohibits discrimination on the basis of disability by programs run or funded by federal government agencies. The goal of Section 508 is to ensure all electronic and information technology is accessible to everyone, including people with disabilities. It also applies to any content available on or through websites, including PDFs. To fully understand Section 508 and its goals and requirements, it’s important to consider its origins. 

What is the Rehabilitation Act?

Signed into law in 1973, the Rehabilitation Act prohibits discrimination on the basis of disability. It applies specifically to programs run by federal agencies. It also applies to organizations that receive federal funding, as well as to employment by the federal government and federal contractors. 

What is Section 504 of the Rehabilitation Act?

Section 504 grants civil rights for people who have disabilities. According to Section 504, “No otherwise qualified individual with a disability in the United States […] shall, solely by reason of her or his disability, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance or any program or activity conducted by any Executive agency or by the United States Postal Service.” 

Programs and organizations that receive federal funding include public libraries, public transportation such as airports, federal housing, public hospitals and healthcare facilities, and all levels of public and private education that receive federal funding. 

The establishment of Section 504 led to the creation of the Americans with Disabilities Act in 1990.

What is Section 508 of the Rehabilitation Act?

Section 508 of the Rehabilitation Act is an amendment to the Rehabilitation Act that extends Section 504 to specifically include electronic and information technology (EIT). It requires all federal agencies to comply with Web Content Accessibility Guidelines (WCAG) 2.0, making their EIT accessible to people with disabilities. 

Refreshed in 2018, this law required the US Access Board to develop standards for Information and Communication Technology (ICT) that regulate how the federal government procures equipment and technology. 

Section 508 requires all federal agencies to: 

• Ensure all EIT is accessible for people with disabilities by following WCAG 2.0. This includes websites and the files they contain.
• Make necessary accommodations to allow an employee with a disability to perform their job
• Make accommodations that allow applicants with a disability to apply for a job
• Ensure that all employees have access to equal benefits and privileges
• Provide necessary software to employees to access information

How does Section 508 compliance relate to PDF accessibility?

EIT includes more than just your web pages; it includes everything located on your websites, such as PDF files. PDFs are the most commonly used document format for websites and electronic information. Unfortunately, they can also be one of the least accessible document formats. When considering accessibility for your electronic and information technology (EIT), it’s important to include your PDF documents. 

What kinds of documents might be in PDF form?

Here’s a list of the types of documents that your agency or organization might store on its website or in its internal digital files in PDF format:

• Employee directories
• Human resources manuals
• Benefits manuals and information
• User manuals
• Financial reports
• Monthly and annual budgets
• Meeting minutes
• Departmental reports
• Brochures
• Course descriptions
• Textbook lists
• Syllabi
• Regulations 
• Legislation
• Monthly statements

How to achieve 508 compliance for PDF accessibility

All electronic content, whether it’s a web page or PDF document, “shall conform to Level A and Level AA Success Criteria and Conformance Requirements in WCAG 2.0.”

WCAG is not a cut-and-dry checklist for exactly what to do to make a PDF accessible. Rather, WCAG is a set of “pillars” that can guide your design and remediation efforts. Below is an overview of those pillars, and you can read a full explanation of what WCAG requires for your PDFs here.

1. Perceivable- People with disabilities, many of whom may use assistive technology, must be able to perceive the content. For PDFs, that means applying tags to each element of the document so assistive technology can identify the content.
2. Operable- The document must be navigable by keyboard, as many people who are blind or otherwise disabled cannot use a mouse to navigate on a screen. That means all links on a page must be appropriately tagged and functional, and the linked text must indicate where the reader will go. Headings must also be tagged correctly so people with disabilities can quickly tab through them to find the content they want.
3. Understandable- All relevant tables, charts, and other images must be explained clearly and concisely using alt text or otherwise correctly tagged.
4. Robust- Tags must carry over so PDF read the same regardless of the browser or tool used to read it.

You can also learn more about how to comply with Section 508 using WCAG 2.0 by downloading our ebook, the Equidox Guide to PDF Accessibility.

How is Section 508 enforced?

All federal agencies must comply with Section 508 regulations. Additionally, any organization that does business with the federal government or receives federal funding must comply with these regulations.

Any person with a disability can file a complaint about an agency’s lack of compliance with these regulations. Direct complaints about Section 508 to the US General Services Administration (GSA). 

When an agency receives a complaint that its EIT (including websites) does not comply with Section 508 and the complaint is found to be supported, the agency will have to provide the complainant with attorney’s fees and injunctive relief–which is usually to resolve the issue. A civil action can also be filed which may result in equitable relief and/or compensatory damages. 

Organizations should resolve these issues quickly to avoid negative publicity and costly fees.  

What if my organization isn’t part of the federal government?

If your organization contracts with or otherwise receives funding from the federal government you need to comply with Section 508. It’s also required if your organization does business with the federal government, or supports or participates in government programs.  That includes most healthcare organizations like hospital systems and health insurance that receive payment from or work with Medicare or Medicaid. Often government contracts are contingent upon meeting these digital accessibility compliance requirements.

Organizations can easily become overwhelmed by the sheer volume of documents they need to make accessible, like physician directories, billing statements, explanations of benefits, and more. Equidox uses AI in all of its applications and solutions (without putting your data at risk), making PDF remediation fast and easy. 

Ready to make your PDFs accessible? Contact us for a free consultation about your document compliance needs. 

Tammy Albee

Tammy Albee | Director of Marketing | Equidox Tammy joined Equidox after four years of experience working at the National Federation of the Blind. She firmly maintains that accessibility is about reaching everyone, regardless of ability, and boosting your market share in the process. "Nobody should be barred from accessing information. It's what drives our modern society."