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Section 508 Refresh

The United States Access Board has issued final rulemaking that updates accessibility requirements for information and communication technology (ICT) in the federal sector covered by Section 508 of the Rehabilitation Act of 1973 on Jan. 18, 2017. This rule also updates the guidelines for telecommunications equipment subject to Section 255 of the Communications Act. The rule jointly updates and reorganizes the Section 508 standards and Section 255 guidelines in response to market trends and innovations, such as the convergence of technologies. The refresh also harmonizes these requirements with other guidelines and standards both 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 created by the World Wide Web Consortium (W3C). The rule references Level A and Level AA Success Criteria and Conformance Requirements in WCAG 2.0 and applies them to websites, electronic documents and software. This final rule is effective Mar. 20, 2017. Compliance with section 508-based standards is not required unilt Jan. 18, 2018.

Text of the Standards and Guidelines

Major Changes to Section 508

  • Restructuring provisions by functionality instead of product type due to the increasingly multi-functional capabilities of ICT
  • Incorporation of the Web Content Accessibility Guidelines (WCAG) 2.0 by reference and applying Level A and Level AA Success Criteria and Conformance Requirements to websites, as well as to non-web electronic documents and software
  • Specifying the types of non-public facing electronic content that must comply
  • Requiring that operating systems provide certain accessibility features
  • Clarifying that software and operating systems must interoperate with assistive technology (such as screen magnification software and refreshable braille displays)
  • Addressing access for people with cognitive, language, and learning disabilities
  • Harmonizing the requirements with international standards

A detailed overview on what has changed in the refresh can be found on the Access Board's website.

Take-aways

  • All public facing UH content must be WCAG 2.0 Level A and Level AA compliant.
  • All non-public facing content (e.g., intranet content such as that within Laulima) must be compliant, if it falls under these nine categories:
    • A. An emergency notification;
    • B. An initial or final decision adjudicating an administrative claim or proceeding;
    • C. An internal or external program or policy announcement;
    • D. A notice of benefits, program eligibility, employment opportunity, or personnel action;
    • E. A formal acknowledgement of receipt;
    • F. A survey questionnaire;
    • G. A template or form;
    • H. Educational or training materials; or
    • I. Intranet content designed as a Web page.
  • Content engines that serve and hold information as well as the information they contain must also be WCAG 2.0 Level A and Level AA compliant.
  • The same rules for web pages also apply to non-web documents (PDF/Word/Excel/etc.) that are published online.
  • The rules also apply to social media posts. For example, if one posts a flyer image for an event on Facebook, one must also include the full text of the flyer for the event in the posting. For limited character systems such as Twitter, the post/tweet should include a link to a page that has the full text of the flyer.
  • For legacy content that already meets the previous 508 standards, there is a "safe harbor" provision, which is determined on a case-by-case basis. Therefore, as long as the content is fully 508 (old) compliant prior to 1/18/2018, it does not need to be updated to the new standards until the content is changed, at which point it must meet the new 508 standards.