https://armypubs.army.mil/epubs/DR_pubs/DR_a/ARN44468-PPM_CIO-030-000-WEB-1.pdf
DEPARTMENT OF THE ARMY
CHIEF INFORMATION OFFICER
107 ARMY PENTAGON
WASHINGTON DC 20310-0107
ISES-GOV-CP-30
ISES-TCC (25-1rrrr) 15 July 2025
MEMORANDUM FOR SEE DISTRIBUTION
SUBJECT: Army Section 508 Proponent Guidance
References. See Enclosure 1.
1. Purpose. Provide guidance for the Army's responsibilities regarding Section 508 of
the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794d), hereinafter referred to
as Section 508.
2. Background. Section 508 mandates that federal agencies develop, procure,
maintain, and utilize accessible Information and Communication Technology (ICT). This
requirement ensures that employees and members of the public with disabilities have
access to information comparable to that of individuals without disabilities, unless it
poses an undue burden on the agency.
3. Scope.
a. This memorandum provides guidance and reinforces existing policy and federal
law concerning electronic content (as detailed in the Enclosures) and offers general
guidance for other ICT.
b. The Army Chief Information Officer (CIO) will issue separately specific guidance
on information systems, formalized exceptions, ICT acquisition, testing, and assistive
technology.
c. ICT includes information technology and equipment, systems, or processes for
which the principal function is the creation, manipulation, storage, display, receipt, or
transmission of electronic data and information, as well as any associated content.
Examples of ICT include but are not limited to:
(1) Computers and peripheral equipment
(2) Information kiosks and transaction machines
(3) Telecommunications equipment
ISES-TCC (25-1rrrr)
SUBJECT: Army Section 508 Proponent Guidance
(4) Multifunction office machines
(5) Software and applications
(6) Websites and web pages
(7) Video and multimedia products
(8) Electronic documents and forms
d. ICT must meet the technical accessibility standards or the functional performance
criteria established by the Architectural and Transportation Barriers Compliance Board
(also known as the Access Board) unless an exception applies. For more information,
see https://www.access-board.gov/ict/.
4. Applicability. This guidance applies to all Headquarters, Department of the Army
(HDQA) organizations, Army Commands, Army Service Component Commands, Direct
Reporting Units, the Army Reserve Command, and the Army National Guard.
5. Responsibilities. The U.S. Army Enterprise Services Agency (ESA) will execute this
mission and assign the Army Section 508 PM to manage the Army Section 508
Program on behalf of the Army CIO (see Enclosure 2).
6. Guidance.
a. Guidance and Implementation. See Enclosure 3 for specific guidance on ICT, to
include electronic content, media, software, and hardware.
b. Training and resources. All Army personnel must complete Section 508 training
relevant to their roles. For more information on specific training please refer to
Enclosure 4.
c. Records Management Requirements. The following records management
requirements apply to all Section 508 compliance documentation, including record
retention, Section 508 compliance records, records management, records availability,
and privacy and security. For more information on specific records management
requirements please refer to Enclosure 5.
7. Points of contact.
a. CIO Policy Inbox: usarmy.pentagon.hqda-cio.mbx.policy-inbox@army.mil
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ISES-TCC (25-1rrrr)
SUBJECT: Army Section 508 Proponent Guidance
b. Section 508 PM: Ms. Lisa Wilcox, (571) 644-7863, lisa.g.wilcox3.civ@army.mil.
Digitally signed by
GARCIGA.LE GARCIGA.LEONEL.T.11
ONEL.T.1186 86170411
Date: 2025.07.15
170411 08:32:38 -04'00'
Encls LEONEL T. GARCIGA
Chief Information Officer
DISTRIBUTION
Principal Officials of Headquarters, Department of the Army
Commander
U.S. Army Forces Command
U.S. Army Training and Doctrine Command
U.S. Army Materiel Command
U.S. Army Futures Command
U.S. Army Pacific
U.S. Army Europe and Africa
U.S. Army Central
U.S. Army North
U.S. Army South
U.S. Army Special Operations Command
Military Surface Deployment and Distribution Command
U.S. Army Space and Missile Defense Command/Army Strategic Command
U.S. Army Cyber Command
U.S. Army Medical Command
U.S. Army Intelligence and Security Command
U.S. Army Corps of Engineers
U.S. Army Military District of Washington
U.S. Army Test and Evaluation Command
U.S. Army Human Resources Command
U.S. Army Corrections Command
U.S. Army Recruiting Command
Superintendent, U.S. Military Academy
Commandant, U.S. Army War College
Director, U.S. Army Civilian Human Resources Agency Executive Director, Military
Postal Service Agency Director, U.S. Army Criminal Investigation Division Director,
Civilian Protection Center of Excellence
Director, U.S. Army Joint Counter-Small Unmanned Aircraft Systems Office
Superintendent, Arlington National Cemetery
Director, U.S. Army Acquisition Support Center
(CONT)
3
ISES-TCC (25-1rrrr)
SUBJECT: Army Section 508 Proponent Guidance
DISTRIBUTION: (CONT)
CF:
Principal Cyber Advisor
Director, Office of Analytics Integration
Commander, Eighth Army
4
REFERENCES
a. Rehabilitation Act of 1973 (29 U.S.C.), Section 508 as amended, 794d. Available at
https://www.access-board.gov/about /lawra.html#section-508-federal-electronic-and-
information-technology.
b. CFR Title 36 (Part 1194: Information and Communication Technology Standards
and Guidelines). Available at https://www.ecfr.gov/current/title-36/chapter-XI/part-1194.
c. FAR (Part 39: Acquisition of Information Technology; Subpart 39.2: Information
Technology). Available at https://www.acquisition.gov/far/subpart-39.2.
d. DoDD 8000.01 (Management of the Department of Defense Information Enterprise),
Paragraph K. Available at
https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodd/800001p.pdf
e. DoDM 8400.01 (Accessibility of Information and Communications Technology (ICT)).
Available at
https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodm/840001m.pdf?ver=
KtbiSK2Kc39T-2mYLga3kg%3d%3d
f. AR 25-1 (Army Information Technology). Available at
https://armypubs.army.mil/epubs/DR_pubs/DR_a/ARN37510-AR_25-1-001-WEB-3.pdf).
g. Army CIO memorandum (Information Technology Reciprocity Acceptance
Guidance), 3 November 2023. Available at
https://armypubs.army.mil/epubs/DR_pubs/DR_a/ARN43976-PPM_CIO-006-000-WEB-
1.pdf.
h. DA Pamphlet 25-1-1-Army Information Technology Implemented Instructions.
(Available at https://api.army.mil/e2/c/downloads/2021/10/20/3b64248b/army-digital-
transformation-strategy.pdf).
Enclosure 1
Army Section 508 Program Manager Responsibilities
1. Manage the Army Section 508 Program on behalf of the Army Chief Information
Officer (CIO), to include developing and providing policy, guidance, training, and best
practices.
2. Increase Army-wide Section 508 compliance based on the U.S. Access Board
standards at https://www.access-board.gov/.
3. Prepare and develop required Section 508 reports, data, and surveys for the
Department of the Army.
4. Work with local Section 508 Liaisons to resolve accessibility related issues and to
distribute Section 508 guidance and information.
5. Supports the agency’s efforts to create a barrier-free ICT environment for all
employees and members of the public with disabilities.
6. Coordinates and collaborates with other staff responsible for Rehabilitation Act
compliance, including the provision of reasonable accommodations.
7. Develop and implement training for local Section 508 Liaisons and the Army
enterprise at large.
8. Monitor and report on Army-wide Section 508 implementation progress.
9. Establish an Army-wide Section 508 electronic and information technology
accessibility working group according to guidance outlined in DoDM 8400.01.
10. Work with Assistant Secretary of the Army for Acquisition, Logistics, and Technology
to ensure procurement policy and procedures provide for assurance of Section 508
conformance during the acquisition of ICT.
11. Work with United States Army Cyber Command and other stakeholders to create
and maintain a list of Army approved assistive technologies to include [but not limited to]
hardware and software.
12. Develop, evaluate, and implement processes for testing ICT accessibility.
13. Develop and maintain a means for reporting Section 508 non-compliance
complaints and requests for assistance.
Enclosure 2
14. Develop, track, maintain, and report the process for tracking Section 508
exceptions.
15. Review and approve applicable Section 508 exceptions and provide administrative
program oversight and guidance as needed.
16. Provide guidance to the enterprise as it relates to content creation to ensure digital
products are accessible IAW Section 508 standards.
17. Participate in DoD and Federal Government accessibility activities, including
collaborative efforts, trainings, forums, and workshops to ensure the Army is up to date
with latest ICT accessibility trends and best practices.
18. Work with Assistant Secretary of the Army for Manpower and Reserve Affairs to
ensure compliance with Army policies and procedures for Equal Employment
Opportunity (EEO), Civil Rights, and Civilian Personnel.
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Guidance and Implementation
1. The Army must ensure that all information and communication technology (ICT)
meets Section 508 standards. Employees with disabilities and the public should have
equal access to information and services. Compliance involves everyone and includes
content, media, software, and websites. For detailed information about Section 508
requirements, visit the U.S. Access Board website (https://www.access-board.gov/ict/)
and check the WCAG 2.2 criteria (https://www.w3.org/TR/WCAG22/).
a. Electronic Content. Section 508 breaks electronic content down into “Public
Facing” electronic content and “Agency Official Communication”. Section 508, E205
(Electronic Content) sets guidelines and standards for electronic content compliance.
Electronic content should be Section 508 compliant. Electronic content creators and
electronic content publishers need to understand Section 508 compliance requirements
and ensure applicable documents are compliant prior to posting online.
(1) Public Facing. Per Section 508, electronic content (to include webpages,
websites, PDFs, Forms, Power Point briefs, videos, etc.) that is public facing shall
conform to Level A and Level AA success criteria and conformance requirements in the
Web Content Accessibility Guidelines (WCAG) 2.2. Non-Web documents shall not be
required to conform to the following four WCAG 2.2 Success Criteria: 2.4.1 Bypass
Blocks; 2.4.5 Multiple Ways; 3.2.3 Consistent Navigation; and 3.2.4 Consistent
Identification. Public facing websites and webpages are those made available to the
general public. Some examples include public organizational websites, official social
media accounts, etc.
(2) Agency Official Communication. Electronic content that is not public facing
shall conform to Level A and Level AA success criteria and conformance requirements
in WCAG 2.2 only when such content constitutes official business and is communicated
by the Army through one or more of the following:
(a) An emergency notification
(b) An initial or final decision adjudicating an administrative claim or proceeding
(c) An internal or external program or policy announcement
(d) A notice of benefits, program eligibility, employment opportunity, or personnel
action
(e) A formal acknowledgement of receipt
(f) A survey questionnaire
(g) A template or form
Enclosure 3
(h) Educational or training materials
(i) Intranet content designed as a Web page
b. Media. Video and audio, both pre-recorded and live, are becoming more widely
used across official platforms. It is imperative that all media, to include videos, are also
Section 508 compliant. WCAG 2.2 breaks media down into prerecorded and live media.
(1) Pre-Recorded Media: All media (prerecorded) posted to Army sites (to include
all official social media sites) shall meet applicable WCAG 2.2 (Level A and Level AA)
standards to include criteria 1.2.2 (Captions (Prerecorded) Level A) and criteria 1.2.3
(Audio Descriptions or Media Alternative (Prerecorded).
(2) Live Media: All live media hosted on Army sites, or from official Army social
media accounts, shall meet applicable WCAG 2.2 Level A and Level AA standards and
criteria 1.2.4 Captions (Live) Level AA. Captions are to be provided for all live audio
content in synchronized media.
c. Hardware. Per Section 508 standards, “Where components of ICT are hardware
and transmit information or have a user interface, such components shall conform to the
requirements in Chapter 4”. Chapter 4 of Section 508 can be found at the U.S Access
Board Website (https://www.access-board.gov/ict/).
d. Software. Per Section 508 standards, “Where components of ICT are software
and transmit information or have a user interface, such components shall conform to
E207 and the requirements in Chapter 5”. Chapter 5 of Section 508 can be found at the
U.S Access Board Website (https://www.access-board.gov/ict/).
e. The above is not an all-inclusive list of requirements. Please review WCAG 2.2
for the appropriate success criteria and conformance requirements.
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Training and Resources
1. The GSA maintains a guide that highlights the laws, policies and other regulations
pertaining to Information Technology accessibility. Visit
https://www.section508.gov/manage/laws-and-policies/.
2. The U.S. Access Board develops and maintains the standards for Information and
Communication Technology accessibility. (See reference [a.] at Enclosure 1.).
3. Training: General Services Administration (GSA) Section 508.gov has several free
online training courses available via the at https://www.section508.gov/training/. This
site has a training videos library that includes Section 508 - What It Is and Why It’s
Important; and offers developer training and resources for building compliant websites,
documents, media, and many more.
a. DoD CIO has several training resources. (Available at
https://intelshare.intelink.gov/sites/dodcio/508/). CAC is required to access this site.
b. Web Content Accessibility Guidelines (WCAG) 2.2. (Available at
https://www.w3.org/TR/WCAG22/).
4. Trusted Tester Training: The Department of Homeland Security offers Trusted Tester
training at https://www.dhs.gov/trusted-tester. This training is offered as a free resource
and once complete you will be a certified Trusted Tester. Even without completing the
entire Trusted Tester certification, this training provides valuable information on Section
508 standards, how to check for compliance, and how to use web accessibility test
tools.
5. Testing Tool: Accessible Name & Description Inspector (ANDI) is a free testing tool
that may be authorized for web developers, testers, and Section 508 managers. More
information on ANDI located at (Available at https://www.ssa.gov/accessibility/andi). This
tool may require approval to use. Please consult with your local network service
provider for more information and approval prior to trying to utilize or download this tool.
6. Assistive Technology: The Computer/Electronic Accommodations Program (CAP)
provides assistive technology accommodations and services to persons with disabilities
throughout the DoD. The CAP operates a Technology Evaluation Center to match
people with specific technologies. For more information, visit http://www.cap.mil/.
7. Acquisition: Accessibility Requirements Tool (ART). This step-by-step guide helps
identify relevant accessibility requirements from the Section 508 standards to include
Enclosure 4
into your procurement and contracting documents. (Available at
https://www.section508.gov/art/#/).
8. Procurement: Solicitation Review Tool (SRT). This tool helps evaluate and improve
overall solicitation compliance with respect to accessibility. (Available at
https://www.section508.gov/buy/solicitation-review-tool/).
9. The GSA provides technical assistance to help federal agencies comply with Section
508 requirements. (Available at https://www.section508.gov/).
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Records Management Requirements
1. Organizations should maintain the following digital Section 508 compliance records:
a. ICT inventory and assessment documentation
b. Section 508 testing results
c. Remediation plans and implementation status
d. Exception requests and approvals
e. Alternate means of access documentation
f. Compliance reports and supporting data
h. Training completion records
2. Records Retention
a. Assessment and testing records should be digitally maintained for three years or
until the ICT is replaced or substantially modified, whichever is longer.
b. Exception requests and approvals should be digitally maintained for the duration
of the exception plus three years.
c. Compliance reports should be digitally maintained for five years.
d. Training records should be digitally maintained in accordance with Army training
record requirements.
3. Records Management
a. All Section 508 records should be managed in accordance with AR 25-400-2,
Army Records Management.
b. Records should be digitally maintained in authorized recordkeeping systems.
c. Records should be properly labeled with appropriate retention codes.
Enclosure 5
d. Electronic records should be maintained in accessible formats.
4. Records Availability
a. Records should be made available for inspection and audit upon request.
b. Records should be accessible to individuals with disabilities in accordance with
Section 508.
c. Records should be available to support litigation, Congressional inquiries, and
other official requirements.
5. Privacy and Security
a. Records containing personally identifiable information should be protected in
accordance with privacy regulations.
b. Records containing sensitive information should be properly marked and
protected.
c. Records shall be shared only with authorized personnel on a need-to-know basis.
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