The final rule revises both the structure and substance of the ICT requirements to further accessibility, facilitate compliance, and make the document easier to use. Major changes include:
restructuring provisions by functionality instead of product type due to the increasingly multi-functional capabilities of ICT;
incorporating the Web Content Accessibility Guidelines (WCAG) 2.0 by reference and applying Level A and Level AA Success Criteria and Conformance Requirements to websites, as well as to non-web electronic documents and software;
specifying the types of non-public facing electronic content that must comply;
requiring that operating systems provide certain accessibility features;
clarifying that software and operating systems must interoperate with assistive technology (such as screen magnification software and refreshable braille displays);
addressing access for people with cognitive, language, and learning disabilities; and
harmonizing the requirements with international standards.
Incorporation of the Web Content Accessibility Guidelines (WCAG)
The final rule incorporates by reference a number of voluntary consensus standards, including WCAG 2.0. Issued by the W3C’s Web Accessibility Initiative, WCAG 2.0 is a globally recognized, technology-neutral standard for web content. The final rule applies WCAG 2.0 not only to web-based content, but to all electronic content. The benefits of incorporating the WCAG 2.0 into the Section 508 Standards and the 255 Guidelines and applying it in this manner are significant. WCAG 2.0 addresses new technologies and recognizes that the characteristics of products, such as native browser behavior and plug-ins and applets, have converged over time. A substantial amount of WCAG 2.0 support material is available, and WCAG 2.0-compliant accessibility features are already built into many products. Further, use of WCAG 2.0 promotes international harmonization as it is referenced by, or the basis for, standards issued by the European Commission, Canada, Australia, New Zealand, Japan, Germany, and France.