Standard
Section 508 PDF checklist: what federal agencies actually require
The Revised 508 Standards incorporate WCAG 2.0 Level AA by reference. Here is what that means for a PDF, condition by condition.
U.S. Access Board · technical standard: WCAG 2.0 Level AA, incorporated by reference
The practical checklist
Section 508 conformance for a PDF resolves to WCAG 2.0 Level AA. In file-format terms, that is a specific and checkable list.
Tagged, with real structure. The document must have a /StructTreeRoot, /MarkInfo /Marked true, and every piece of content either tagged or declared an artifact. The condition →
Correct reading order. The structure tree order must match the order a person would read the page. This is where the time goes on multi-column documents. Why →
Document title and language. A dc:title in the XMP metadata, /DisplayDocTitle true, and a /Lang on the catalog. Ninety seconds of work, and it is the first thing a screen reader announces. How →
Alternative text on meaningful images, and artifacts for decorative ones. An empty /Alt is a failure, not the PDF equivalent of alt="". How →
Table headers with associations. TH cells with /Scope, or /Headers and /ID on complex tables. How →
Form fields with accessible names. /TU on every field, /Tabs /S on every page carrying annotations, widgets inside Form elements. How →
Bookmarks in long documents. Not a PDF/UA machine test, but a routine finding in 508 reviews and a WCAG 2.4.5 issue in practice.
Evidence, not assertions
Federal review processes ask how you know. “We ran a checker” is a weaker answer than a document showing which conditions were tested, which failed, what was changed, which items required human judgement, who made each call and when.
Taggart’s remediation report is built to be that document: findings mapped to both the Matterhorn condition and the WCAG success criterion, a timestamped decision log with an actor on each entry, the tool version, and the SHA-256 of the input and output files so the report cannot be detached from what it describes.
It does not assert conformance, and it says so on every copy. That determination is yours to make.
Frequently asked questions
Which WCAG version does Section 508 use?
The Revised 508 Standards (2017) incorporate WCAG 2.0 Level A and AA by reference. Not 2.1. Meeting WCAG 2.1 AA meets 2.0 AA, since 2.1 is a superset, so targeting 2.1 is the practical choice — it covers Section 508 and the newer instruments at once.
What is a VPAT and do I need one?
A Voluntary Product Accessibility Template is the document a vendor uses to report conformance, in a format federal buyers expect. If you are selling to a federal agency you will almost certainly be asked for one. It is a report about a product, not a certification, and it is only as good as the testing behind it.
Does 508 apply to documents an agency publishes, or only to what it buys?
Both. Section 508 covers ICT that federal agencies develop, procure, maintain or use. A PDF an agency publishes on its own website is covered ICT.
How does this relate to ADA Title II?
Section 508 covers federal agencies; ADA Title II covers state and local government. Different instruments, different scopes, similar technical requirements — 508 names WCAG 2.0 AA, Title II names WCAG 2.1 AA.
Related failure conditions
- 01-005 Content is neither marked as Artifact nor tagged as real content Every text-showing, image-painting and path-painting operator on a page must sit either inside a marked-content sequence that maps to the structure tree, or inside an artifact sequence. Content that is in neither is orphaned.
- 09-001 Tags are not in logical reading order The order of elements in the structure tree does not match the order a human would read the page. This is the single most common substantive defect in tagged PDFs and the one Acrobat's own tooling handles worst.
- 13-004 Figure tag alternative or replacement text missing A Figure element has neither /Alt nor /ActualText. Every Figure must have one or the other; if the image is decorative it should be an artifact instead of a Figure.
- 15-003 A TH cell does not contain a Scope attribute Header cells must declare whether they head a row, a column, or both, unless the table instead uses explicit /Headers ID references on every data cell.
- 28-005 A form field has neither a TU entry nor an alternative description The /TU tooltip is the accessible name of a PDF form field. Without it the field has no name at all — the visible label printed next to it is not connected to the control.
Check your own file. Taggart's validator is free and unlimited — no page cap, no watermark, no account.
Primary source: https://www.access-board.gov/ict/. This page is a working summary, not legal advice.
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