How do Section 508 accessibility failures impact bid evaluations and what must vendors do to comply? 2026

According to GSA guidelines, contractors must provide clear accessibility evidence—VPATs, conformance levels, test reports and remediation plans—when bidding on federal IT and digital services. Per FAR 19.502, small businesses can claim preferences but still must meet accessibility requirements in solicitations and SOWs. The SBA reports that 78% of small federal contractors encounter accessibility requirements in solicitations, so accessibility now directly affects award competitiveness. Under OMB M-25-21, agencies will include accessibility as an evaluation criterion and may remove non-conforming offers from consideration. DoD's CMMC framework requires secure and accessible reporting interfaces when CUI is present, and FedRAMP-authorized cloud offerings must also demonstrate accessibility controls. This means GSA, SBA, OMB, DoD and agency contracting officers will treat Section 508 failures as technical non-conformities that can lower scores or trigger exclusion. Vendors bidding to DHS, VA or NASA should assume reviewers will request a current VPAT and testing artifacts; failure to deliver those documents can delay source selection and eliminate award eligibility for contracts valued at $100K to $100M depending on the procurement.