Section 508 incorporates WCAG 2.0 Level A and AA, not 2.1. See the twelve-criterion gap, the non-web carve-outs, and how to read your contract. The Revised 508 Standards incorporate WCAG 2.0, not 2.1. Here is exactly what the newer versions add, and how to tell which bar your own contract sets. Section 508 vs WCAG 2.1 Section 508 vs WCAG 2.1 is not a version argument. It is a question about which document your contract points at. The Revised 508 Standards incorporate WCAG 2.0 Level A and AA. They do not incorporate 2.1. Plenty of federal solicitations still ask for WCAG 2.1 Level AA, because a program office or an agency policy says so. Both facts can hold on the same award. Read the clause first, then scope the work to whichever bar sits higher. One piece of relief sits underneath all of this. The W3C built each version on the one before it, so clearing the higher bar also clears the lower one. What The Regulation Incorporates Two provisions carry the standard. E205.4 of the Revised 508 Standards (https://www.ecfr.gov/current/title-36/chapter-XI/part-1194/appendix-Appendix%20A%20to%20Part%201194) reads: "Electronic content shall conform to Level A and Level AA Success Criteria and Conformance Requirements in WCAG 2.0." E207.2 says the same for "User interface components, as well as the content of platforms and applications." Section 702.10.1 then names the document itself: WCAG 2.0, the W3C Recommendation of 11 December 2008. The dates matter. The Access Board issued the final rule on 18 January 2017, and the rule took effect on 18 January 2018, as section508.gov records. The Access Board's own ICT page lists every step of that rulemaking, and it shows no later rule moving the regulation off 2.0. So the binding citation still reaches a 2008 document. Confirm the version in force on the day you deliver, because the Board can open a new rulemaking at any time. Our Section 508 compliance checklist (/blog/section-508-compliance-checklist) covers the rest of the scoping sequence. ! Three bars comparing WCAG 2.0, 2.1 and 2.2 at Level A and AA, with Section 508 marked on the 2.0 bar and 12 then 6 added criteria (https://mhhifytmrlyksfrjacvi.supabase.co/storage/v1/object/public/blog-images/2026/10/section-508-vs-wcag-2-1-figure.png) Section 508 binds you to the shortest bar, and every later version simply adds criteria on top of it. What 2.1 Adds WCAG 2.1 keeps every 2.0 criterion and adds seventeen. Twelve of the seventeen sit at Level A or AA. Twelve, then, is the real gap between a 508 deliverable and a 2.1 AA deliverable. | New in WCAG 2.1 | Level | |---|---| | 2.1.4 Character Key Shortcuts | A | | 2.5.1 Pointer Gestures | A | | 2.5.2 Pointer Cancellation | A | | 2.5.3 Label in Name | A | | 2.5.4 Motion Actuation | A | | 1.3.4 Orientation | AA | | 1
The Revised 508 Standards incorporate WCAG 2.0, not 2.1. Here is exactly what the newer versions add, and how to tell which bar your own contract sets.
Section 508 vs WCAG 2.1 Section 508 vs WCAG 2.1 is not a version argument. It is a question about which document your contract points at. The Revised 508 Standards incorporate WCAG 2.0 Level A and AA. They do not incorporate 2.1. Plenty of federal solicitations still ask for WCAG 2.1 Level AA, because a program office or an agency policy says so. Both facts can hold on the same award. Read the clause first, then scope the work to whichever bar sits higher. One piece of relief sits underneath all of this. The W3C built each version on the one before it, so clearing the higher bar also clears the lower one. What The Regulation Incorporates Two provisions carry the standard. E205.4 of the Revised 508 Standards (https://www.ecfr.gov/current/title-36/chapter-XI/part-1194/appendix-Appendix%20A%20to%20Part%201194) reads: "Electronic content shall conform to Level A and Level AA Success Criteria and Conformance Requirements in WCAG 2.0." E207.2 says the same for "User interface components, as well as the content of platforms and applications." Section 702.10.1 then names the document itself: WCAG 2.0, the W3C Recommendation of 11 December 2008. The dates matter. The Access Board issued the final rule on 18 January 2017, and the rule took effect on 18 January 2018, as section508.gov records. The Access Board's own ICT page lists every step of that rulemaking, and it shows no later rule moving the regulation off 2.0. So the binding citation still reaches a 2008 document. Confirm the version in force on the day you deliver, because the Board can open a new rulemaking at any time. Our Section 508 compliance checklist (/blog/section-508-compliance-checklist) covers the rest of the scoping sequence. ! Three bars comparing WCAG 2.0, 2.1 and 2.2 at Level A and AA, with Section 508 marked on the 2.0 bar and 12 then 6 added criteria (https://mhhifytmrlyksfrjacvi.supabase.co/storage/v1/object/public/blog-images/2026/10/section-508-vs-wcag-2-1-figure.png) Section 508 binds you to the shortest bar, and every later version simply adds criteria on top of it. What 2.1 Adds WCAG 2.1 keeps every 2.0 criterion and adds seventeen. Twelve of the seventeen sit at Level A or AA. Twelve, then, is the real gap between a 508 deliverable and a 2.1 AA deliverable. | New in WCAG 2.1 | Level | |---|---| | 2.1.4 Character Key Shortcuts | A | | 2.5.1 Pointer Gestures | A | | 2.5.2 Pointer Cancellation | A | | 2.5.3 Label in Name | A | | 2.5.4 Motion Actuation | A | | 1.3.4 Orientation | AA | | 1