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Wednesday, February 13, 2013
You are here: Section 508 Roles - Requiring Official

Section 508 Roles - Requiring Official

If you are a Requiring Official, sometimes called Program Officer or Requesting Official, you can use this site to:
  • Identify which of the Access Board's accessibility standards apply to the specific acquisition;
  • Conduct market research to determine the availability of compliant products and services;
  • Draft specifications and minimum requirements to be submitted with the purchase request
  • Document nonavailability and undue burden determinations, if necessary
Anyone and everyone is or can be a Requiring Official. As soon as you decide you want to procure something, regardless of your grade level or position description, you become the "Requiring Official." For example, a secretary ordering a fax machine or a statistician ordering software is a Requiring Official. As long as you are in the process of buying something or considering a purchase, you are a Requiring Official. If you are a requiring official you may have several different types of responsibilities where you need a knowledge and understanding of Section 508 Standards. Some of your tasks may included:
  • Determining program needs, Section 508 relevance and exceptions, and specific Section 508 technical and performance requirements;
  • Conducting market research on accessibility of available EIT;
  • Providing RFP language for solicitation, assisting in choosing the best proposal during source selection, and conducting inspection and acceptance during EIT delivery.
Requiring officials represent the actual customer side - they "own" the need that will be met by the contract. They may be an IT specialist or program manager or other mission-side representative.

The physical and functional characteristics of the EIT and its intended use to meet program requirements determine which specific technical provisions of the Section 508 standards apply.

Requiring and ordering activities must ensure supplies or services meet the applicable accessibility standards at 36 CFR Part 1194, unless an exception applies, at the time of issuance of task or delivery orders.

The requiring official must document in writing the nonavailability, including a description of market research performed and which standards cannot be met, and provide documentation to the contracting officer for inclusion in the contract file.

The requiring official must identify which standards would apply to the procurement, using the Access Board's EIT Accessibility Standards at 36 CFR part 1194. Then the requiring official must perform market research to determine the availability of compliant products and services.

Technical specifications and minimum requirements would be developed based on the market research results and agency needs. This information would be submitted with the purchase request. The solicitation would then be drafted, or task order or delivery order would be placed. Proposal evaluation may yield additional information that could require reconsideration of the need for an exception.

You can use the BuyAccessible System (, which has four components, all made available to any agency at no cost to help with the quick, easy and efficient implementation of all Section 508 standards. This free tool guides requiring officials through the steps necessary to conduct acquisitions that comply with Section 508. CAOs and CIOs may incorporate the use of this tool into their procurement procedures to improve compliance with the law. You can also take advantage of our free on-line training courses.

If you have a requiring or program Section 508 question, please email for assistance.