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Section 508 Frequently Asked Questions

Q1. I'm not posting my document, instead I will distribute by email to State DOTs. Do I have to make this conformant with Section 508?

A1. Yes, all information and communication technology (ICT) that we procure, maintain, use, or develop that is public-facing or in one of nine categories of internal agency official communication need to be 508 conformant.

Q2. What are the 9 categories of internal agency official communication?


  • An emergency notification;
  • An initial or final decision adjudicating an administrative claim or proceeding;
  • An internal or external program or policy announcement;
  • A notice of benefits, program eligibility, employment opportunity, or personnel action;
  • A formal acknowledgement of receipt;
  • A survey questionnaire;
  • A template or form;
  • Educational or training materials; or
  • Intranet content designed as a Web page.

Q3. Can I finish my content then have someone else make them 508 conformant?

A3. No. You need to consider 508 from the start. Properly structuring your content from the start is important. Correcting some failures like color contrast and use of color are difficult to fix after the fact. Save time, money, and frustration by thinking about 508 from the start.

Q4. I'm a Contracting Officer Representative (COR). My contractor says the deliverable is conformant. I do not know how to check. Can I take their word for it?

A4. No. As a COR, it is your responsibility to ensure the deliverable is conformant. Resources are provided and you are expected to do an initial evaluation on the deliverable. Contact the Section 508 Core Team if you have any questions.

Q5. I am new to my office and recently assumed COR duties for a project with a number of deliverables over a year. The old COR accepted non-conformant deliverables, what can I do?

A5. Your office or team is responsible for finding the resources to make them conformant.

Q6. I've run my file through a validator. It's conformant, right?

A6. No. Not all validators are set to run against the requirements for Section 508. There are a number of standards available, we don't have to meet them all. Validators can find only 25-40% of the problems depending on the validator. A validator is great at checking if all images have alt text but can't tell if the alt text is appropriate for that image.

Q7. My content is too technical/complicated. No one using assistive technology will use it so I do not need to be 508 conformant.

A7. See Q1. If your content falls into one of the categories of that needs to be conformant, it will proactively be made 508 conformant. It is likely someone using your content will need an accommodation. One in 10 men1 are color-blind. If you use color to convey information, they may not be able to understand your content. Disabilities can be temporary. Maybe you had shoulder surgery so can't use a mouse. Or can occur as a complication from a medical condition such as diabetes or glaucoma.

Q8. I have deliverables from a contract signed before the 508 Refresh went into effect. Do they need to meet the new standards?

A8. Yes. Deliverables are not grandfathered in and will need to meet the standards under the 508 Refresh.

Q9. Do I need to update existing files to meet the new standards?

A9. No. Unaltered ICT that was conformant under the original standards do not need to be updated. Any part of ICT that is altered must be conformant with the new standards.

Q10. If I have a document posted on the web in more than one file format, e.g. HTML, PDF and Excel, do all versions need to comply with 508 standards?

A10. No. Only one version of the document needs to meet the standards.

Q11. Can I provide a contact number and/or email so someone can get an accessible document if needed?

A11. No. If you are developing, maintaining, procuring, or using ICT, it will be 508 conformant.

Q12. The Office of Public Affairs has cleared this for distribution. They checked this for 508 conformance as well, right?

A12. No. The 508 conformance check is separate from HPA's review. Contact the Section 508 Program Manager if you need assistance checking your document.

Section 508 You are the key

Disclaimer: FHWA is committed to making its Information and Communication Technology (ICT) accessible by meeting the requirements of Section 508 of the Rehabilitation Act of 1973. The tools, resources, criteria and other items provided herein are for internal use by FHWA for ICT it procures, develops, maintains, and utilizes. The U.S. Government assumes no liability for the use by third parties of the information contained in this website. The U.S. Government does not endorse products or manufacturers. Trademarks or manufacturers' names appear on this website only because they are considered essential to the objective of the information.