What Section 508 actually requires
The Revised 508 Standards, in effect since January 2018 for federal agencies, incorporate WCAG 2.0 Level AA by reference and apply it to web and non-web content. Buyers in government, education and regulated industries often ask for WCAG 2.1 AA instead, which contains every WCAG 2.0 AA criterion plus a few more. Checking a course against WCAG 2.1 AA covers both requests.
The checklist
| Criterion | What to check in the course | Automatable? |
|---|---|---|
| 1.1.1 Non-text Content | Every meaningful image has alt text that describes it. Decorative images are marked as decorative. No filenames as alt text. | Detect: yes. Judge quality: needs review |
| 1.2.2 Captions (Prerecorded) | Every video with speech has synchronized captions. | Detect missing tracks: yes. Accuracy: needs review |
| 1.2.5 Audio Description | Visual information in video that is not narrated is described. | Partly |
| 1.3.1 Info and Relationships | Headings, lists and tables use real markup. Heading levels are not skipped. | Mostly |
| 1.3.2 Meaningful Sequence | Screen readers read slide content in a logical order. | Partly |
| 1.4.3 Contrast (Minimum) | Text contrast is at least 4.5:1, or 3:1 for large text. | Yes |
| 2.1.1 Keyboard / 2.1.2 No Keyboard Trap | Every interaction works with the keyboard, and focus can always leave a component. | Needs runtime testing |
| 2.4.3 Focus Order | Tab order follows the visual order. No positive tabindex values. | Partly |
| 3.1.1 Language of Page | Each page declares its language, which also matters after translation. | Yes |
| 4.1.2 Name, Role, Value | Custom buttons, sliders and drag-and-drop items expose a name and role. | Needs runtime testing |
What automation cannot tell you
A scanner can find an image without alt text. It cannot tell whether "chart" is a useful description of a chart. It can find a video without captions, but not whether generated captions spell product names correctly. Treat every automated fix as a draft that a person accepts, and finish with a keyboard-only pass and a screen-reader pass (NVDA or JAWS on Windows, VoiceOver on macOS) through the course in the LMS.
Evidence report, VPAT and ACR
A VPAT is a template. Filled in, it becomes an Accessibility Conformance Report (ACR) that states, criterion by criterion, how a product conforms. A scan report is evidence that supports that work: what was checked, what was found, what was changed. It is not a conformance claim on its own, and it should not be presented as a VPAT or a legal certification.
Fixing a course that is already published
Most accessibility requests arrive after the course is live. Rather than reopening the authoring file, you can scan the published SCORM zip, apply the remediations you accept, such as alt text, caption tracks, contrast changes and page language, and upload the remediated zip as a new version of the same course.