Federal Agencies Must Prepare for New Requirements Under Section 508 ICT ADA Law


Last week, the US Access Board delivered a long awaited final rule under the authority of Section 508 of the Rehabilitation Act. Widely known as the “Section 508 Refresh,” the law ensures that federal agencies provide full accessibility in all aspects of their information and communication technology (ICT).  After being published in the Federal Register yesterday, agencies and vendors are expected to comply within a one-year period (January 18, 2018).


To make sure that the refresh keeps pace with a continuously evolving technological landscape, the Web Content Accessibility Guidelines (WCAG) 2.0, an internationally accepted standard, were incorporated. Its success criteria were adopted by the New York City and European Union governments early last year. The rule states that agencies must conform to Level A (which provide the most basic web accessibility features) and Level AA (which address the biggest and most common barriers for disabled users) requirements. These are the requirements that apply to online video content:

Level A

To conform to Level A guidelines, federal agencies must provide the following:

Offline Captions Pre-recorded video content with audio must have closed captions.

Video Description Pre-recorded video content with audio must have video description OR text video description (media alternative) that is accessible using screen reader technology.

Level AA

To conform to Level AA guidelines, federal agencies must provide what is listed in Level A, as well as:

Live Captions Live streaming videos must have closed captions. Video Description Pre-recorded video content with audio must have video description.

The Impact Beyond Section 508

While Section 508 only applies to federal agencies, the Title III team at Seyfarth Shaw believes the refresh “makes it even more likely that the DOJ will adopt the same standard for the websites of public accommodations and state and local governments under Titles II and III of the ADA,” meaning organizations that want to be proactive should start looking to WCAG 2.0 requirements sooner rather than later.

We help government agencies and businesses of all sizes meet WCAG 2.0 standards for their video content. In addition to producing the highest quality closed captioning and video description, our team works closely with clients to provide custom style guides and streamlined workflows that meet their needs.

If you need help, 

contact Kerry Brown at 

or at (314) 647-9400, xt 230.