section-508

Use the VPAT 2.x WCAG Edition template from ITI. Complete product information, disclose evaluation methods (axe, NVDA, JAWS), then fill Table 1 (Level A), Table 2 (Level AA), and Table 3 (Functional Performance Criteria) with conformance levels and remarks for each criterion.

The Revised Section 508 Standards (effective January 18, 2018) incorporate WCAG 2.0 Level A and AA for web content, software, electronic documents, and authoring tools. WCAG 2.1 is recommended but not yet mandated by the 508 standards.

Section 508 directly applies to federal agencies for all ICT they develop, procure, maintain, or use. Private companies are affected only when they contract with the federal government, since ICT supplied to agencies must meet the standards.

Combine automated scans (axe-core, Lighthouse, WAVE, catching roughly 30-40% of issues) with keyboard-only navigation, screen reader testing (NVDA, JAWS, VoiceOver), color contrast verification, and 200% zoom checks. Document results per WCAG criterion.

Undue burden applies when compliance imposes significant difficulty or expense. The agency must document the cost analysis, obtain a written determination from the agency head or CIO, and provide an alternative means of access to the information.

Common deficiencies include using the outdated VPAT 1.x template, claiming "Supports" without evidence, overusing "Not Applicable," skipping Functional Performance Criteria, omitting testing methodology, and submitting a VPAT for a different product version than the one being procured.