Is Your Power Pages or SharePoint Portal Section 508 Compliant?

Quick answer. As of October 2026, Section 508’s Revised 508 Standards require a federal agency’s public-facing content to conform to WCAG 2.0 Level A and AA, and Microsoft states that Power Pages conforms to the newer WCAG 2.2 standard and to the Section 508 guidelines defined by the GSA. SharePoint Online appears in the in-scope services table of Microsoft’s U.S. Section 508 page, and Microsoft says its Accessibility Conformance Reports assess products against WCAG levels A and AA criteria, but no Microsoft page read for this guide states a SharePoint-specific WCAG version the way the Power Pages page does. Neither statement covers what your agency builds on the platform: templates, forms, uploaded documents and customizations remain yours to test, and Microsoft’s own Power Pages guidance makes the person who changes Liquid templates and content snippets responsible for the accessibility of what they add.

A GSA or OMB accessibility review is on the calendar, a complaint has arrived, or a new public-facing portal is about to launch, and the answer offered in the room is that Microsoft already covers Section 508. That answer is true about something. The work in front of you is finding out what it is true about, because the platform your portal runs on and the pages, forms and documents your team or a contractor put on it are two different things, and a reviewer tests the site the public uses.

Why this lands on your desk now

If the portal is public-facing, it is inside the law’s reach. Section508.gov’s Web Content Overview states that “Section 508 applies to public facing websites, extranet, and internal websites such as intranet sites.” Its own examples of covered web content include “A web portal to view Social Security benefits”, which is the same kind of site a citizen-facing Power Pages or SharePoint portal is.

The U.S. Access Board defines the term in its Revised 508 Standards material: “Public-facing content refers to electronic information and data that a Federal agency makes available directly to the general public.” That is the part of Section 508 this guide is about.

Section 508 also has an employee side, and it is a separate obligation. Microsoft’s U.S. Section 508 page describes it as agencies procuring, maintaining and using technology so that federal employees with disabilities have comparable access to data and technology. An internal SharePoint site can carry that obligation even when it is not public-facing, so keep the two lists apart when you scope the work.

None of this is new. The Access Board’s page records that “compliance with the section 508-based standards is not required until January 18, 2018”, and that date is long past. The requirement is standing and already in force, so the question a reviewer asks is not whether you are ready for a future date but whether the portal you serve today conforms.

What the Revised 508 Standards require

When a reviewer asks which standard the portal is measured against, the answer is in the U.S. Access Board’s Revised 508 Standards, published at 36 CFR Part 1194 and reproduced on the Board’s own page. The Board states that “Compliance with these standards is mandatory for Federal agencies subject to Section 508 of the Rehabilitation Act of 1973, as amended”. For electronic content, the technical requirement is one sentence: “Electronic content shall conform to Level A and Level AA Success Criteria and Conformance Requirements in WCAG 2.0”.

Section508.gov says the same thing in plainer words on its Web Content Overview: “Websites must conform to the Section 508 Standards and the W3C Web Content Accessibility Guidelines (WCAG) 2.0 Level AA.”

The planning rule that follows: treat WCAG 2.0 Level A and AA as the regulatory floor your portal is tested against. A supplier may state conformance to a later WCAG version for its own product, and that statement is about the product. It does not change the version the Revised 508 Standards name, and it does not test your content.

What Microsoft already provides

If someone in the room says Microsoft already covers Section 508, the platform statements they mean are real, and each one says exactly what it covers. On its Accessibility in Power Pages page, last updated April 22, 2025, Microsoft states: “Power Pages conforms to the WCAG 2.2 accessibility standard.” On the same page it states: “Power Pages conforms to the Section 508 guidelines defined by the US GSA.” Both are Microsoft’s statements about its product. WCAG 2.2 is the version Microsoft names for Power Pages; the Revised 508 Standards still name WCAG 2.0 for your content, and nothing on this page turns one into the other.

For SharePoint Online the evidence is a list, not a sentence. Microsoft’s U.S. Section 508 page, last updated June 2, 2026, carries an Office 365 applicability table whose Commercial row names SharePoint Online and Power Apps among its in-scope services. The page explains why it exists: “To assist government customers in making procurement decisions, Microsoft publishes Accessibility Conformance Reports describing the extent to which our products and services support the criteria of Section 508.” No page read for this guide states a SharePoint-specific WCAG version, so this guide does not supply one. The report for the product is where that detail lives.

Microsoft’s Accessibility Conformance Reports page describes what those reports are: “Microsoft Accessibility Conformance Reports (ACRs) document the degree of conformance to global accessibility standards of products, services, and accessibility features.” It states that “Microsoft assesses products and services against WCAG levels A and AA criteria.” It describes the method as well: “Microsoft evaluates products and services using the Department of Homeland Security (DHS) Trusted Tester program, Version 5, which creates a common testing approach for determining conformance to Section 508.” Microsoft writes most new reports on the Voluntary Product Accessibility Template (VPAT), and its page explains where each report lists the version of the standards it was assessed against. The page describes Microsoft’s method; it does not publish a pass or fail result for Power Pages or SharePoint Online, and this guide does not claim one.

The planning rule: a platform conformance statement or report is a starting reference for the parts Microsoft built. It is never a substitute for testing the finished site your agency serves.

What Microsoft’s own statement does not cover

Your agency’s additions are where the gap sits, and Microsoft says so on the same Power Pages page. Its section on Liquid templates and content snippets reads: “When custom HTML and Use Liquid content are added to your Power Pages site, accessibility must be taken into consideration. The person making the changes to the Liquid templates and Content snippets is responsible for ensuring that the content they add is accessible.”

Its next sentence names a third WCAG version, and it applies to customizations: “It’s important to make sure that customizations adhere to the required policies, such as WCAG 2.1, US Section 508, or ETSI EN 301 549.” That is Microsoft’s guidance for what you build on Power Pages, as Microsoft wrote it. It sits beside, and does not replace, the WCAG 2.0 Level A and AA requirement the Revised 508 Standards set for your agency’s content, or the WCAG 2.2 statement Microsoft makes about the platform itself.

Embedded reports follow the same logic. The page says that “as a Power BI report and dashboard author, you should make sure your Power BI reports and dashboards are accessible.” On Microsoft’s U.S. Section 508 page, in the Office 365 section that carries the SharePoint Online listing, Microsoft adds: “Your organization is wholly responsible for ensuring compliance with all applicable laws and regulations.”

The planning rule: everything your agency adds is your agency’s testing scope. That means custom pages and templates, Liquid code and content snippets, forms and their error messages, uploaded PDFs and other documents, embedded reports, third-party embeds and any content a contractor built on your behalf. Microsoft’s statement about the platform covers none of those.

The inventory and the testing plan

Before any test runs, know what the portal serves. The Access Board’s definition of public-facing content tells you where to start the inventory, and the version the Revised 508 Standards name tells you what to test it against. Microsoft’s description of its own evaluation is a useful reference for coverage: “Along with Trusted Tester, our evaluation is commonly supported by automated testing; manual testing; testing with assistive technology; and functional testing by individuals with disabilities.” That describes Microsoft’s method for its products; your plan applies the same kinds of coverage to your site.

• List every public-facing page, form, workflow and document type on the portal, and mark who built each one.
• List every customization added to the platform: Liquid templates, content snippets, custom HTML, scripts and third-party embeds.
• Plan automated testing coverage against the WCAG 2.0 Level A and AA success criteria, and record which criteria automated testing cannot judge.
• Plan manual testing and assistive-technology testing for those criteria, on the flows citizens complete.
• Request the current VPAT or Accessibility Conformance Report from every supplier in the stack, and read it rather than assume it: check the product, the version of the standards it was assessed against, and any exceptions it records.
• Write down the gaps and a remediation order, and take the conformance determination to your Section 508 Program Manager and contracting officer, who make it for your agency.

When this guide is the wrong starting point

If one of these situations is yours, the work starts somewhere else:

• If the portal serves patients for an organization that receives HHS financial assistance, rather than the public under a federal agency’s own authority, that is a Section 504 question, and this guide does not cover it.
• If the requirement comes from a non-US standard, such as the European one Microsoft names beside Section 508, this guide describes it only as Microsoft wrote it and does not advise on it.
• If your agency already holds a current VPAT or Accessibility Conformance Report from every supplier in the stack, the remaining work is testing your own customizations and content, not re-arguing the platform statements.
• If Microsoft updates its Power Pages or Section 508 pages, re-read them at the source before relying on this guide. The Microsoft statements in this guide are quoted as served in October 2026.

What to ask of whoever does the work

When you assign the work in-house, to a contractor or to an outside team, hold it to the same criteria:

• A written inventory of public-facing content and customizations before any purchase or test.
• A request for each supplier’s current VPAT or Accessibility Conformance Report, read rather than assumed current.
• A testing plan that names automated, manual and assistive-technology coverage against WCAG 2.0 Level A and AA.
• No claim that any product, supplier or project makes the portal conform to Section 508 outright; the determination stays with your agency.
• Senior people who have worked in Microsoft estates, based in the US.
• A plain statement that your team owns the portal and its content after the project ends.

How i3solutions answers

i3solutions scopes this work as a project: an inventory of the portal’s public-facing content and the customizations built on Power Pages or SharePoint, a testing plan that names automated, manual and assistive-technology coverage against WCAG 2.0 Level A and AA, and a remediation scope your team can fund and track, with embedded specialists where your team needs them. i3solutions has been a Microsoft Partner with 30 years of enterprise technology delivery experience and has delivered 1,500+ Microsoft engagements across aerospace and defense, financial services, and health sciences. Delivery is senior and US-based. An i3solutions project engagement does not by itself include ongoing support of what it delivers, which i3solutions scopes separately as Application Managed Services, and it is not a replacement for the internal team, open-ended scope expansion, or vendor lock-in. The conformance determination stays with your agency’s Section 508 Program Manager and contracting officer.

This guide is part of i3solutions’ governance and compliance work.

Key Takeaways

• The Revised 508 Standards require a federal agency’s public-facing content, including a Power Pages or SharePoint portal, to conform to WCAG 2.0 Level A and AA.
• Microsoft states that Power Pages conforms to WCAG 2.2 and to the Section 508 guidelines defined by the US GSA; that is a statement about the platform.
• SharePoint Online appears in the in-scope services table of Microsoft’s U.S. Section 508 page; no page read for this guide states a SharePoint-specific WCAG version.
• Microsoft’s Power Pages guidance names WCAG 2.1 for customizations and makes whoever changes Liquid templates and content snippets responsible for their accessibility.
• Inventory what your agency added, test it with automated, manual and assistive-technology coverage, and read every supplier’s conformance report rather than assume it.

Frequently Asked Questions

Does Section 508 apply to our public-facing Power Pages or SharePoint site?

Yes, when the site is content your agency makes available to the public. Section508.gov states that Section 508 applies to public facing websites, extranet and internal websites, and the U.S. Access Board defines public-facing content as electronic information and data a federal agency makes available directly to the general public. The platform the site runs on does not change that.

What WCAG level does Section 508 require?

WCAG 2.0 Level A and AA. The Revised 508 Standards require electronic content to conform to Level A and Level AA success criteria and conformance requirements in WCAG 2.0, and Section508.gov restates the requirement for websites as WCAG 2.0 Level AA.

Is Power Pages Section 508 compliant?

Microsoft states that Power Pages conforms to the WCAG 2.2 accessibility standard and to the Section 508 guidelines defined by the US GSA. That is Microsoft’s statement about the platform. Your agency’s own templates, forms, documents and customizations are outside it, and Microsoft’s page makes the person who changes Liquid templates and content snippets responsible for the accessibility of what they add.

Does using Power Pages or SharePoint satisfy Section 508 by itself?

No. A platform statement covers what Microsoft built. The Revised 508 Standards apply to the content your agency serves, Microsoft’s Power Pages guidance says customizations should adhere to policies such as WCAG 2.1 or US Section 508, and Microsoft’s Section 508 page says your organization is wholly responsible for compliance with applicable laws and regulations. The finished site still needs your own testing.

What is a VPAT or Accessibility Conformance Report, and do we still need our own testing?

An Accessibility Conformance Report documents the degree of conformance of a product or service to accessibility standards. Microsoft writes most new reports on the Voluntary Product Accessibility Template (VPAT) and assesses products against WCAG levels A and AA criteria using the DHS Trusted Tester program, Version 5. A report describes the product, not your site, so your agency still tests its own pages, forms, documents and customizations.