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Step 3: Determine Which Standards Apply

To ensure that any technology your agency buys or builds will be accessible, you must determine which of the Revised 508 Standards apply to your Federal IT procurement and development project. (Note, this is the third and final step in determining 508 standards and exceptions.)

Identify which Standards apply to each ICT item:

  • Select the type of ICT, then answer the questions
  • If your ICT item falls under a single category:
    • Select the category that best fits, and only answer those questions
  • If your ICT item spans multiple categories (e.g., a VOIP IP solution that includes both hardware and software):
    • Answer the questions under each relevant category
  • Record your responses in the Revised 508 Standards Applicability Checklist (MS-Word, April 2018)

Note, this step is not required if your entire ICT item is eligible for any of the exceptions (which you should have determined in Step 2), except the Best Meets exception. If only some components of the ICT item qualify for an exception, you must determine which Standards apply to the remaining components.

ICT Types

Electronic Content

Question 1 - Is the content comprised of records maintained by the National Archives and Records Administration (NARA) pursuant to Federal recordkeeping statutes?

  • If Yes, the electronic content component of the ICT item does not have to conform to the Revised 508 Standards.
    • If the ICT contains hardware or software components, proceed below to those sections, below.
  • If No, proceed to Question 2

Question 2 - Will the content be public-facing?

  • If Yes, proceed to Question 4
  • If No, proceed to Question 3

All public facing electronic content must be accessible. The standards define ”public facing” as content made available by an agency to members of the general public. Section E205 of the Revised 508 Standards specifies which electronic content, including web, software, multimedia and electronic documents, must conform to the technical requirements. Usually, public facing content is published on the web (for example, on an agency website, blog, form, or social media page). However, public facing content might also be made available in non-web formats, such as information displayed on screens or interactive kiosks in waiting areas.

Question 3 - Will the content be an official agency communication that is not public-facing?

  • If Yes, proceed to Question 4
  • If No, the electronic content component of the ICT item does not have to conform to the Revised 508 Standards.
    • If the ICT contains hardware or software components, proceed below to those sections.

Electronic content that is not public facing but is official business, and is communicated through one or more of the nine categories below is an ”agency official communication” and must be accessible. The content might be broadly disseminated or sent to individual agency employees or members of the public. The method of delivery does not determine whether electronic content is ”agency official communication.” Such content may be disseminated via an internal agency website or intranet, or by other delivery modes. Common transmittal means include, but are not limited to: emails, text messages, phone alerts, storage media, and downloadable documents.

The nine categories of agency official communication (with examples) are listed below. All of the following examples are provided to help provide further understanding of these categories. The examples are not all-inclusive. Contact the U.S. Access Board for assistance with interpreting and applying these categories.

  1. Emergency notifications - Examples include: evacuation notices, active shooter alerts, text messages conveying emergency instructions (e.g., ”remain in place”), hazardous weather alerts, and operational notices regarding unscheduled closures.
  2. An initial or final decision adjudicating an administrative claim or proceeding - Examples include: an electronic notice or alert of an approved, denied, or pending claim sent to a business or other organization, or to an individual.
  3. Internal or external program or policy announcements - For example, an electronic notification of a new agency policy or a change to an existing program requirement.
  4. A notice of benefits, program eligibility, employment opportunity, or personnel action - For example: an electronic notice sent to a member of the public or employee describing government benefits to which they are entitled; information on whether an individual is eligible for benefits from, or can participate in a government program; information on the status of an application for enrollment in a program; notification of an official personnel action indicating a promotion, adverse action, or other personnel decision affecting a government employee; a job announcement.
  5. A formal acknowledgment of receipt - For example: an email acknowledging receipt of payment; a notice posted to a program participant’s web page containing his or her personal account information and acknowledging that he or she successfully submitted certain records.
  6. Survey questionnaires - Examples include: a set of written questions (open-ended or multiple choice) developed for the purpose of a survey or data analysis such as a questionnaire assessing employee training needs; an employee satisfaction survey; a questionnaire used to gather information related to gauging satisfaction with a government program. This category does not include questions submitted during litigation or legal proceedings.
  7. Templates or forms - For example: an electronic document template used to create official agency documents or presentations; a web page template created to establish a common look and feel for a website; an official agency form that must be completed by employees or members of the public.
  8. Educational or training materials - Examples include: interactive online training courses; self-paced training course; educational webinars; other educational presentation formats; support materials for such activities including, electronic worksheets, training manuals, and tests.
  9. Intranet content designed as a web page - For example: an intranet page listing files for downloading; shared calendars; an internal employee locator; and other html web pages distributed internally via an agency Intranet. This category does not include files within a listing distributed via the agency intranet that are not in one or more of the nine categories above.

NOTE: An exception provides that NARA is not responsible for remediating records sent to them by other agencies

Question 4 - Will the electronic content be web-based?

  • If Yes, the following Standards apply:
    • 602 Support Documentation
    • 603 Support Services
    • All WCAG A & AA Success Criteria
  • If No, the following Standards apply:
    • 602 Support Documentation
    • 603 Support Services
    • All WCAG A & AA Success Criteria apply except:
      • 2.4.1 Bypass Blocks
      • 2.4.5 Multiple Ways
      • 3.2.3 Consistent Navigation
      • 3.2.4 Consistent Identification

Software

Question 1 - Is the software assistive technology (i.e., any item, piece of equipment, or product system used to increase, maintain, or improve functional capabilities of individuals with disabilities)?

  • If Yes, the software component of the ICT item does not have to conform to the Revised 508 Standards.
    • If the ICT contains hardware components, proceed below to that section.
  • If No, proceed to Question 2

Question 2 - Will the software be web-based?

  • If Yes, the following Standards apply:
    • All WCAG A & AA Success Criteria
    • 502 Interoperability with Assistive Technology
    • 503 Application
    • 602 Support Documentation
    • 603 Support Services
    • 302 All Functional Performance Criteria
  1. Note: Applies when Chapter 5 does not address one or more functions of ICT (E204), or when an agency invokes ”equivalent facilitation” (E101.2)
  • Proceed to Question 3
    • If No, the following Standards apply:
      • All WCAG A & AA Success Criteria apply – EXCEPT the following:
        • 2.4.1 Bypass Blocks
        • 2.4.5 Multiple Ways
        • 3.2.3.Consistent Navigation
        • 3.2.4 Consistent Identification
      • 502 Interoperability with Assistive Technology
      • 503 Application
      • 602 Support Documentation
      • 603 Support Services
      • 302 All Functional Performance Criteria
        • Note: Applies when Chapter 5 does not address one or more functions of ICT (E204), or when an agency invokes ”equivalent facilitation” (E101.2)
    • Proceed to Question 3

    Question 3 - Is the software also an authoring tool?

    • If Yes, the following additional Standards apply:
      • 504 Authoring Tools
    • If No, stop. No additional Standards for software apply.
      • If the ICT contains hardware components, proceed to the next section.

    Hardware

    Include the following:

    • 404 Preservation of Information Provided for Accessibility
    • 405 Privacy
    • 406 Standard Connections
    • 407 Operable Parts
    • 409 Status Indicators
    • 410 Color Coding
    • 411 Audible Signals
    • 602 Support Documentation
    • 603 Support Services
    • 302 All Functional Performance Criteria
    • If the ICT contains hardware components, proceed below to this section.
      • Note: Applies only when Chapter 4 does not address one or more functions of ICT (E204), or when an agency invokes ”equivalent facilitation” (E101.2))

    Also include the following, when applicable:

    • If the solution can only be accessed directly through the hardware (e.g., a kiosk), include:
      • 402 Closed Functionality
    • If the hardware support biometrics, include:
      • 403 Biometrics
    • If the hardware is required (or likely to) have display or touch screens, include:
      • 408 Display Screens
    • If the hardware is required to support two-way voice communications, include:
      • 412 ICT with Two Way Voice Communications
    • If the hardware is required to display multimedia content, include:
      • 413 Closed Caption Processing Technologies
      • 414 Audio Description Processing Technologies
      • 415 User Controls for Captions and Audio Descriptions

    What’s Next?

    See the other steps in this process:

    Related Resources

    • Revised 508 Standards Applicability Checklist (MS-Word, April 2018) - Use this checklist to document your accessibility requirements for ICT items
    • Accessibility Requirements Tool - Automates the Revised 508 Standards Applicability Checklist; generates an accessibility reporting requirements template and customizable accessibility solicitation language.
    • Original Guidance Document - Developed by the U.S. Federal Government Revised 508 Standards Transition Workgroup; members include the U.S. Federal CIO Council Accessibility Community of Practice, the U.S. Access Board, and the General Services Administration.

    Contact your agency’s Section 508 Coordinator or email us at section.508@gsa.gov with questions.


    Updated/Reviewed: May 2018