For vendors selling to federal agencies
Section 508 ACR for software sold to federal agencies.
Federal agencies must buy accessible technology, and GSA’s guidance tells them to require an ACR for each commercial product. Here is what the Section 508 edition covers for a web-based product, and what we deliver for $1,990.
The requirement
Section 508 in four facts.
- Section 508 of the Rehabilitation Act (29 U.S.C. 794d) covers the information and communication technology that federal agencies develop, procure, maintain or use.
- The technical rules are the Revised 508 Standards (36 CFR part 1194), published January 18, 2017 and corrected January 22, 2018.
- For web content and software, they incorporate WCAG 2.0 Level A and AA (sections E205.4 and E207.2). Electronic support documentation must meet the same (602.3).
- GSA’s buyer guidance tells agencies to require, for each commercial product, an ACR based on the VPAT®, a Supplemental Accessibility Report, and GSA’s Issue Detail Supplement (Section508.gov).
GSA’s FAQ for vendors is blunt about it: without the ACR, “the government may not proceed with the purchase” unless the government itself claims an exception, and while the VPAT® template is optional, “it is not voluntary to complete an ACR if you wish the government to consider purchasing your product” (Section508.gov FAQ).
WCAG 2.0 or 2.1?
The 508 edition reports on WCAG 2.0, because that is the version in the Revised 508 Standards. The W3C notes that content conforming to WCAG 2.1 also conforms to WCAG 2.0. Our WCAG 2.1 evaluation covers all 38 WCAG 2.0 Level A and AA criteria — so the same testing can also feed a WCAG or INT edition later.
The 508 edition
What the report covers for a web-based product.
ITI’s VPAT® 2.5Rev Revised Section 508 edition has these parts. For a typical SaaS product:
| Part | What it covers | For a web-based product |
|---|---|---|
| WCAG 2.0 Report (Tables 1 and 2) | The 38 WCAG 2.0 Level A and AA criteria. These tables also document 501.1 (software), 504.2 (authoring tools) and 602.3 (electronic support documentation). | Fully reported, with a remark for every criterion. |
| Chapter 3: Functional Performance Criteria | 302.1–302.9: use without vision, with limited vision, without perception of color, without hearing, with limited hearing, without speech, with limited manipulation, with limited reach and strength, and with limited language, cognitive and learning abilities. | Reported, based on the WCAG findings and the screen reader and keyboard passes. |
| Chapter 4: Hardware | Physical devices: closed functionality, operable parts, display screens and two-way voice hardware. | Not applicable to web software; summarized in the chapter notes. |
| Chapter 5: Software | 502 interoperability with assistive technology, 503 applications, 504 authoring tools. | ITI’s instructions note that 502 and 503 will not apply to a web-only application; 504 is reported if your product lets users create content. |
| Chapter 6: Support Documentation and Services | 602.2–602.4 support documentation; 603.2–603.3 support services. | Reported, from your help center and your support channels. |
GSA’s Issue Detail Supplement
The page agencies now attach to the ACR.
GSA developed the Issue Detail Supplement to go beyond a traditional ACR, and recommends adding it to solicitations whenever an ACR is requested (page updated August 2026). For each accessibility issue it asks:
- Severity — Critical Accessibility Barrier, Major Accessibility Issue, or Minor Accessibility Issue.
- Area impacted — the page, screen, component or workflow, and how extensive the issue is.
- Impacted user groups — using the same categories as the functional performance criteria (without vision, with limited manipulation, and so on).
- Workaround — any temporary alternative that lets users complete the task.
Our fix list already records these four fields for every issue — see the sample fix list. With the 508 edition, we deliver them in GSA’s format as well.
What you receive
$1,990, fixed. Five business days.
- The ACR on ITI’s VPAT® 2.5Rev Revised Section 508 edition, with a remark for every applicable criterion and a summary for the chapters that don’t apply.
- GSA’s Issue Detail Supplement for every Partially Supports and Does Not Support item.
- A draft Supplemental Accessibility Report: the evaluation methods, accessibility features, core functions users can’t complete, and configuration notes — for you to complete and sign off.
- A prioritized fix list, a draft accessibility statement, and one retest within 90 days with an updated ACR.
Not fully conformant? Still considered.
GSA tells vendors that a product “will still be considered for purchase even if all of the Section 508 Technical Standards are not met,” and compared with similar products. Its guidance to buyers adds that “Partially Supports” means the product does not conform, so they should read the details. Precise remarks and the Issue Detail Supplement are those details.
Limits
When we’re not the right fit.
- Trusted Tester requirements. We are not DHS-certified Trusted Testers. Agencies that adopt the Trusted Tester process accept results only from certified testers; if your solicitation requires that, we can’t meet it.
- Hardware, desktop software and native mobile apps. Web-based products only.
- Legal and contract advice. Including the repair-or-replace and acceptance clauses GSA recommends to agencies.
- Certificates or seals. We don’t issue them. What an agency asks for is your ACR — your own statement, reviewed and signed off by you.
Questions
Short answers.
Can the same report go to a university and a federal agency?
Yes: the INT edition combines WCAG, Section 508 and EN 301 549 in one report, for the same $1,990.
The agency sent its own ACR format. Can you use it?
Yes. Send it with your request. We fill in the agency’s format, and the ITI template if you also want one for other buyers.
Is our older, pre-2018 product exempt?
Only in a narrow case: E202.2 exempts existing ICT that met the original 508 standards and has not been altered on or after January 18, 2018. A SaaS product that has shipped updates since then has been altered. Whether the exception applies to your contract is a question for the agency or your counsel.
Sources
Primary sources only. Each was read on September 26, 2026.
- 36 CFR part 1194, Appendix A — Revised 508 Standards (E205.4, E207.2) and Appendix C (Chapters 3–7) — eCFR, current text.
- Information and Communication Technology (ICT) Standards and Guidelines — final rule, 82 FR 5790 — U.S. Access Board, Federal Register, January 18, 2017 (corrected January 22, 2018, 83 FR 2912).
- Accessibility Conformance Report (ACR) — Section508.gov, GSA.
- Accessibility Conformance Report/VPAT® Frequently Asked Questions — Section508.gov, GSA (reviewed/updated June 2026).
- Request Accessibility Information from Vendors and Contractors — Section508.gov, GSA.
- ACR Issue Detail Supplement — Section508.gov, GSA (reviewed/updated August 2026).
- Understanding Vendor Claims in Accessibility Conformance Reports for Section 508 Conformance — Section508.gov, GSA.
- DHS Trusted Tester Process & Certification Program — Section508.gov, GSA (reviewed/updated July 2026).
- VPAT® — current version 2.5Rev (April 2025), four editions, FAQs — Information Technology Industry Council (ITI).
- Web Content Accessibility Guidelines (WCAG) 2.1 — W3C Recommendation (current version dated May 6, 2025) — W3C.
Get a quote
Send us the solicitation’s accessibility section.
We reply within one U.S. business day with a fixed price, the scope and a delivery date that fits your response deadline.