Section 508 vs WCAG 2.1: What Government Agencies Need to Know
Government IT teams often face a confusing question: do we need to meet Section 508, WCAG 2.1, or both? The short answer is both — but they're more aligned than you think. Here's what you need to know.
508 & WCAG Compliant PDF Suite
MiOffice meets both Section 508 and WCAG 2.1 AA. Published VPAT available:
View 508 Compliant Suite →What Is Section 508?
Section 508 is a U.S. federal law (part of the Rehabilitation Act of 1973, amended in 1998 and refreshed in 2017) that requires federal agencies to make their electronic and information technology (EIT) accessible to people with disabilities. It applies to:
- All federal agencies and their contractors
- Any technology purchased, developed, or maintained by the federal government
- Websites, software, documents, and hardware
After the 2017 refresh, Section 508 directly incorporates WCAG 2.0 Level AA as its technical standard for web content. This means meeting WCAG 2.0 AA = meeting Section 508 for web-based tools.
What Is WCAG 2.1?
The Web Content Accessibility Guidelines (WCAG) are published by the W3C (World Wide Web Consortium). WCAG 2.1, released in 2018, extends WCAG 2.0 with 17 new success criteria focused on mobile accessibility, cognitive disabilities, and low vision users.
WCAG has three conformance levels:
- Level A — minimum accessibility (25 criteria)
- Level AA — standard target for most organizations (13 additional criteria)
- Level AAA — enhanced accessibility (23 additional criteria, not typically required)
Key Differences
| Aspect | Section 508 | WCAG 2.1 AA |
|---|---|---|
| Scope | US federal agencies & contractors | Global — any website or application |
| Legal force | US federal law | Technical standard (referenced by laws) |
| Technical standard | References WCAG 2.0 AA | WCAG 2.1 (extends 2.0) |
| Mobile criteria | Not explicitly (via WCAG 2.0) | Yes — 17 new criteria for mobile/touch |
| Enforcement | Federal procurement, complaints | Varies by jurisdiction (ADA, EAA, etc.) |
| Documentation | VPAT (Voluntary Product Accessibility Template) | VPAT or ACR (Accessibility Conformance Report) |
The Overlap: Why You Should Target WCAG 2.1 AA
Since Section 508 references WCAG 2.0 AA, meeting WCAG 2.1 AA automatically satisfies Section 508. But the reverse isn't true — WCAG 2.1 adds criteria that Section 508 doesn't explicitly require yet.
Best practice for government agencies: target WCAG 2.1 AA. You'll satisfy Section 508, ADA Title II, EN 301 549 (EU), and the European Accessibility Act all at once. Future-proof your compliance.
How This Applies to PDF Tools
When a government agency selects a PDF tool, procurement officers check:
- Does the vendor publish a VPAT? (MiOffice: yes)
- Does the tool support keyboard navigation? (MiOffice: full keyboard access)
- Is the tool screen reader compatible? (MiOffice: ARIA labels on all controls)
- Does it meet contrast requirements? (MiOffice: WCAG AA 4.5:1 minimum)
- Does it work without uploading files to a third party? (MiOffice: 100% browser-based)
Related Standards
| Standard | Region | Relationship to WCAG |
|---|---|---|
| ADA Title II & III | US | DOJ references WCAG 2.1 AA as technical standard |
| EN 301 549 | EU | Directly incorporates WCAG 2.1 AA for web content |
| European Accessibility Act | EU | References EN 301 549 (which references WCAG 2.1) |
| AODA | Ontario, Canada | Requires WCAG 2.0 AA for large organizations |
Bottom Line
Target WCAG 2.1 AA and you satisfy Section 508, ADA, EN 301 549, and EAA simultaneously. When selecting PDF tools, demand a published VPAT, verify keyboard access, and confirm files aren't uploaded to third-party servers. MiOffice checks every box.