Section 508 of the Rehabilitation Act applies to federal agencies. The Department of Justice's ADA Title II web rule applies to state and local governments. A state agency or public school district usually points to the second. A vendor selling to both should expect either name on a questionnaire. This is not legal advice.
The two rules side by side
| Question | Section 508 | ADA Title II web rule |
|---|---|---|
| Who is bound | Federal agencies | State and local government entities |
| What it covers | Electronic and information technology a federal agency develops, procures, maintains or uses | Websites and mobile apps of those entities |
| Where to read it | Section508.gov | ADA.gov |
| Typical vendor ask | An Accessibility Conformance Report | Confirmation that the tool or portal meets the stated standard |
Section508.gov says the law applies to all federal agencies when they develop, procure, maintain or use electronic and information technology. It also says the Access Board updated the standards in a final rule issued 18 January 2017, effective 18 January 2018.
What the Title II rule says
ADA.gov states that the Department of Justice published the rule in April 2024 to set technical requirements for state and local government websites and mobile apps. In April 2026 the Department published an Interim Final Rule that moved the compliance dates:
- Entities with a total population of 50,000 or more: 26 April 2027.
- Entities under 50,000, and special district governments: 26 April 2028.
ADA.gov points readers to the Federal Register for the official text. If a date matters to a deal, read that text, not a summary.
Why this reaches a security tool vendor
Most scanners and dashboards are used by staff, not the public. Even so, procurement teams often send one accessibility question to every software vendor, because it is simpler than sorting tools by audience. The practical result is a request for a report or a short statement, plus a contact person.
A simple way to respond
- Ask which rule the buyer cites and which surface of your product is in scope.
- Send a current Accessibility Conformance Report for that surface, if you have one.
- State known gaps and any workaround in plain words.
- Offer a short hands on test with the buyer's own accessibility lead.
- Record the answer and date in your questionnaire library so the next buyer gets the same facts.
Mistakes to avoid
- Quoting an old date from a blog post. The dates moved in 2026.
- Calling a product "508 compliant" without a report to back it. Federal guidance describes conformance reports, not blanket labels.
- Treating the rule as only a website matter when the buyer's questionnaire covers desktop software and plugins.
For help reading a conformance report, see what is an ACR (VPAT) and why public buyers ask for one.
Quick check
Does Section 508 bind a public school district?
Section508.gov describes it as applying to federal agencies. A district more often cites ADA Title II or its own state policy. Ask the buyer which one they mean.
What are the current ADA Title II web rule dates?
Per ADA.gov, 26 April 2027 for entities of 50,000 or more people, and 26 April 2028 for smaller entities and special districts. Confirm in the Federal Register.
Sources
- Section508.gov: IT Accessibility Laws and Policies
- ADA.gov: First Steps Toward Complying with the Web Rule
Last reviewed: 19 October 2026.
