Compliance reference · 29 USC § 794d
Section 508 captions: what federal contractors and grant recipients must ship
Section 508 of the Rehabilitation Act binds anyone selling information and communications technology to a federal agency, and — through the agency-flow-down clauses in the Common Rule — most federal grant recipients as well. The Revised 508 Standards at 36 CFR Part 1194 adopt WCAG 2.0 Level AA as the legal technical baseline. For training video that means SC 1.2.2 synchronized prerecorded captions at substantial accuracy on every video with audio. Auditors don't sample for "captions exist" — they sample for whether the proper nouns land right.
TL;DR
The Revised 508 Standards (effective 2018-01-18) at 36 CFR § 1194.24 incorporate WCAG 2.0 Level AA by reference for "agency official communications" and "public-facing electronic content" — which includes training video that an agency procures, hosts, or distributes. The caption requirement is SC 1.2.2: synchronized captions on every prerecorded audio-visual asset. Federal contractors get hit at procurement-acceptance review; grant recipients (universities, research orgs, state agencies passing federal money downstream) get hit at the audit cycle. The fix-list is: replace YouTube-grade auto-caption tracks on any video tied to a federal contract or grant deliverable, with synchronized captions accurate enough that an auditor sampling 30 seconds doesn't catch a mangled proper noun.
Who is in scope under Section 508
The statute itself (29 USC § 794d) reaches federal departments and agencies. The flow-down to private parties happens through three mechanisms:
- Federal procurement. Any vendor selling ICT to a federal agency must deliver assets that conform to the 508 Standards. The acceptance criterion lives in the contract Statement of Work; it's enforced at delivery, before payment. Training video — onboarding modules, compliance courses, instructional content — is squarely ICT under 36 CFR § 1194.24 / E103.4.
- Federal grant flow-down. Grant agreements under the Common Rule (2 CFR Part 200) typically pass agency accessibility obligations down to the recipient. Universities receiving NIH, NSF, DOE, or DoD grants run their training programmes under that obligation. State agencies passing federal money to subrecipients pass it again.
- Federal employer obligation. Federal agencies themselves must provide accessible internal training to their employees (29 USC § 794d(a)(1)(B)). The agency's internal LMS — the SkillSoft, Cornerstone, or LinkedIn Learning instance — must serve compliant captions on the training catalogue.
The reach is broader than agencies-only. Roughly: if any federal money touches the training programme that produced or hosts a video, 508 likely applies.
The technical baseline: WCAG 2.0 AA, not 2.1 — yet
This is the most-asked question we get on Section 508, and the answer is currently still WCAG 2.0. The Revised 508 Standards published in 2017 (effective 2018) incorporate WCAG 2.0 Level AA by reference. They have not yet been formally updated to 2.1 — though the U.S. Access Board has signalled an update, and many agency procurement offices write contracts that reference WCAG 2.1 AA as the "no worse than" floor anyway.
For captions specifically, the difference is small: SC 1.2.2 (Captions, Prerecorded) and SC 1.2.4 (Captions, Live) are identical in 2.0 and 2.1. The new 2.1 caption-related criteria (1.2.6 Sign Language at AAA, etc.) sit at AAA and are out of scope at AA.
So the captioning bar is the same: synchronized captions at substantial accuracy on every audio-visual asset. The 99% character-accuracy reading we walk through in our WCAG 2.1 AA captions reference applies identically here.
How 508 audits actually catch captions
508 enforcement runs on three tracks, each with its own sampling pattern:
- Pre-award product testing. An agency contracting officer's technical representative runs an Accessibility Conformance Report (ACR — formerly the VPAT) review and may directly audit training-video deliverables. They typically sample 5-10 videos, open each with captions on, and watch 30-90 seconds. A miscaptioned program name or acronym in the first minute is a finding.
- Section 508 Coordinator audits. Each agency has a designated 508 Coordinator who runs internal audits on procured content. These are scheduled and predictable — but the sampling is the same as above: open captions, watch a slice, look for obvious failures.
- Complaint-driven investigation. A 508 complaint filed under 29 USC § 794d(f) triggers an agency investigation. Sampling here is complainant-driven: whichever video the complainant flagged is the one that gets reviewed first, often in detail.
Across all three tracks, the reviewer's eye lands on the high-meaning words first: program names, technical terms, acronyms. That's the proper-noun surface where general STT systematically fails.
The proper-noun failure mode in federal training content
Federal training video is dense with proper nouns the way medical training is dense with drug names. Across the federal-contractor and federal-grant L&D leads we've talked to, the failures cluster:
- Program names. "PEPFAR" → "pepfor" or split into letters; "ARPA-H" → "ARPA H" with hyphenation lost; "BARDA" → "bardha". These are exactly the words a federal employee being trained must see correctly.
- Agency acronyms. "NIST SP 800-53" → "NIST SP eight hundred fifty three" or "NIST SP eight zero zero dash five three"; "FISMA" → "fizma"; "FedRAMP" → "fed ramp" with capitalization lost.
- Regulatory citations. "FAR 52.224-3" → splintered fragments; "DFARS 252.204-7012" → garbled digit cluster; "OMB A-130" → "OMB A one thirty".
- Internal program codes. Agency-specific names — "SCAMP", "CARES Act", "EAGLE-II", "ALLIANT 2" — get phonetically guessed.
- Personnel titles. "ASD/A&S" → "A SD A and S"; "OUSD(R&E)" → splintered. Department of Defense training is especially dense with these.
The shared pattern: the words a federal trainee must learn are exactly the words general STT has never seen in its training corpus.
The glossary-biased workflow for federal training content
- Build the program-and-acronym glossary once. Most federal contractors and grant recipients already maintain a controlled vocabulary — the program nomenclature in a SharePoint glossary, the acronym list in the onboarding deck, the regulatory citations in the compliance handbook. Connect it (Confluence, SharePoint, Google Docs) or paste a flat list.
- Process the training catalogue in batches. GlossCap runs Whisper-large with the glossary tokens logit-boosted into the decoder. Output is SRT/VTT/TTML with proper-noun surface forms preserved on first export.
- Reviewer pass before LMS upload. The amber-highlight UI lets a 508 Coordinator or training lead scrub every glossary-applied term in context — exactly the sample an auditor would pull. Corrections feed back into the workspace glossary, so the term doesn't break next time.
- Export and attach with documentation. Each video gets a caption file plus a row in your accessibility-statement spreadsheet (asset → caption source → review date → reviewer). When an audit lands, the documentation is the difference between a clean finding and a remediation order.
508 vs ADA Title II vs Title III — which one applies?
Three federal accessibility regimes touch training video in the United States; the difference matters for who can sue you and on what timeline:
- ADA Title II — state and local government entities. The DOJ web rule is enforceable as of 2026-04-24 for large entities, 2027-04-26 for small. Standard is WCAG 2.1 AA. Public universities, state agencies, county and municipal governments.
- ADA Title III — public accommodations: private universities, hospitals, retailers, large employers' public-facing content. No fixed federal technical standard, but courts overwhelmingly apply WCAG 2.0 AA (and increasingly 2.1 AA). Private suit is the typical enforcement.
- Section 508 — federal contractors and grant recipients. Standard is WCAG 2.0 AA via 36 CFR § 1194. Procurement-acceptance review and 508 Coordinator audits. The complaint mechanism in 29 USC § 794d(f).
Many entities are in scope under more than one. A public university research lab funded by NIH is in Title II (state actor) and 508 (federal grant recipient) simultaneously; a private university hospital training new clinicians under a CMS contract is Title III plus 508. The captioning bar is broadly the same in either case; the audit mechanism differs.
The ACR / VPAT line item for training video
Federal procurement requires an Accessibility Conformance Report (ACR — formerly Voluntary Product Accessibility Template, VPAT) at submission. For training-video deliverables, the ACR has a specific row for SC 1.2.2 and SC 1.2.4. The honest answer for a YouTube auto-captioned library is "Partially Supports" or "Does Not Support" — and that costs the bid. The honest answer for a glossary-biased workflow with reviewer signoff is "Supports", which clears the bid.
The ACR row is what your contracts team writes; the workflow that supports it is what your training team runs. We built GlossCap to make the second one trivial.
Related questions
Does Section 508 cover internal training, or only public-facing content?
Both. The Revised 508 Standards distinguish "agency official communications" from "public-facing electronic content," and training video falls under the former when it's internal to an agency or contractor. Internal-only training that touches federal money is in scope; the difference is mostly about which audit pattern catches it (procurement review vs. coordinator audit vs. employee complaint), not whether captions are required.
Is the WCAG 2.1 update going to happen?
The U.S. Access Board has signalled an update, but as of mid-2026 the formal 36 CFR § 1194 incorporation is still WCAG 2.0 AA. Many agency procurement offices already write 2.1 AA into Statements of Work as a contract-level requirement, so contractors increasingly meet 2.1 AA voluntarily. The caption bar (SC 1.2.2) is unchanged either way.
What's the relationship between Section 508 and Section 504?
Section 504 of the Rehabilitation Act prohibits disability discrimination in any federally funded programme, with technical accessibility implied. Section 508 is the specific ICT-procurement standard. A grant-funded university training programme is in scope under both — but 508 gives the auditable WCAG 2.0 AA technical bar, where 504 only gives the discrimination prohibition.
How does 508 interact with state-level analogs?
Many states adopted Section 508-equivalent standards (California Government Code § 7405, Minnesota Statute § 16E.03, Texas Government Code § 2054.451 et seq.) for state-funded ICT. The technical reference in nearly every case is WCAG 2.0 or 2.1 AA. A state contractor handling state-funded training is in scope under the state analog; if the state programme also draws federal money, 508 applies as well.