With publication in the Federal Register on January 18, 2017, the long-awaited Section 508 Refresh became a reality. Publication started a 60-day countdown to the rule’s taking effect on March 20. Compliance with the new Section 508–based standards is required starting January 18, 2018. This Spotlight provides basic information regarding what the Refresh might mean for eLearning.

What is Section 508?

Section 508 is an amendment to the US Rehabilitation Act of 1973. It requires federal agencies to ensure that all electronic and information technology (often referred to as “ICT,” or information and communications technology) and content that they develop, obtain, or maintain is fully accessible to people with disabilities. The Refresh updates the requirements that equipment and content must meet to be considered accessible.

So, what does the Refresh mean for eLearning?

Federal agencies are required to comply with Section 508; therefore, any business that supplies electronic and information technology, goods, or services to a federal agency must ensure that those items meet the updated accessibility standards. This includes hardware and software, website design, apps—and educational or training programs.

In addition, many state governments have adopted Section 508, and all states receive funding under the Assistive Technology Act. Therefore, most state agencies and their suppliers, including state universities, are also required to comply.

The regulations apply to all publicly accessible content and to most official communication content, including emergency notifications, policy announcements, notices of program eligibility or employment opportunities, questionnaires, forms and templates, and educational or training materials.

This means, for example, that all eLearning that a state university offers, whether standalone courses or elements of in-person courses, must meet the new guidelines.

What does the Refresh require?

The Section 508 Refresh incorporates by reference the WCAG 2.0 standard, a global standard for accessibility of Internet content. The rule also explicitly refers to WCAG 2.0 levels A and AA success criteria and conformance requirements in several places.


WCAG 2.0 is a set of guidelines and recommendations for ensuring that online content is accessible. Level A stipulates, for example, that all images have alt text, which is a description of the image that a screen reader can read to a person who has a visual impairment. Level A also stipulates that closed captions and transcripts or audio descriptions be provided for all non-live audio; Level AA adds synchronized captions for live multimedia events that include audio as well. This would cover, for example, a video conference, live-cast of a lecture, or a webinar. The Refresh also covers support documentation, which may be provided to learners with disabilities in alternate formats, such as Braille, large print, or audio files.

Authoring tools

Section 504.2 of the Refresh requires that authoring tools have the ability to create content that conforms to all criteria in Levels A and AA except when used to directly edit plain text source code. Authoring tools must preserve accessibility information, such as alt text descriptions, when content is edited or converted to multiple formats. The tools should be able to prompt users to include accessibility content and tags during content creation or saving. The requirements for authoring tools apply to any eLearning authoring platform purchased by or used in a federal or covered state agency, including a state university.


WCAG 2.0 is technology-neutral; the guidelines and success criteria apply equally to web content, PDFs, user interface components, non-web documents, and the content of platforms (including eLearning modules) and applications.


Information and communication technology includes hardware, such as self-contained information kiosks, self-service machines, and the like. Thus eLearning delivered via an automated kiosk would need to comply if delivered to or used by a covered agency. 

What else does the Refresh cover?

The published rule includes several “advisory” paragraphs, which describe best practices. Some of these list examples of accommodations or acceptable alternate formats for content, as well as suggestions for providing content and assistance in a variety of formats and via multiple delivery channels—underlining the need for flexibility and adaptability when designing eLearning to meet the needs of a broad range of potential learners.


For additional information, review:

Learn more

Join Jenny Nilsson, owner of Varma Multimedia Learning, at Learning Solutions 2017 Conference & Expo, March 22 – 24 in Orlando, Florida. Her session, Building Accessible eLearning in Captivate, takes place Wednesday, March 22, at 10:45 AM.

The eLearning Guild will host a Summit on accessible eLearning on May 17 and 18, 2017. Watch the Guild’s website for schedule and registration information.