Section 504 is not part of the Americans with Disabilities Act (ADA). It is part of the Rehabilitation Act of 1973, and it bans disability discrimination in programs and activities that receive federal financial assistance. The ADA came later, in 1990. It took the same civil rights model and extended it to employers, state and local governments, and private businesses, whether or not they take federal money.
Most large hospitals, universities, and public agencies are covered by both laws at once. That’s why it makes sense to treat ADA and Section 504 compliance as one program, not two.
Managing that program across complex web properties requires a coordinated effort between IT, legal, human resources, and marketing teams. This guide will help you:
- Identify which law covers which parts of your organization.
- Understand the duties both laws share, including who must name a coordinator.
- Meet the WCAG 2.1 Level AA dates set by the two federal web rules.
- Build one compliance program that covers both laws.
First, let’s define who your core ADA and Section 504 obligations apply to before we look at the digital rules and enforcement.
Who each law covers
The two laws overlap, but they don’t reach the same organizations in the same way. The ADA is split into five titles, and coverage depends on what kind of organization you are. Section 504 coverage depends on one thing: whether you receive federal financial assistance.
| Law | Who it covers | Examples |
|---|---|---|
| ADA Title I | Employers with 15 or more employees | Hiring, job applications, workplace accommodations |
| ADA Title II | All state and local government entities, regardless of size | Public universities, state agencies, public hospitals, courts |
| ADA Title III | Private businesses open to the public (public accommodations) | Private hospitals, banks, retailers, private colleges |
| Section 504 | Programs and activities that receive federal financial assistance | Hospitals that take Medicaid, universities that take part in federal student aid or hold federal grants |
The ADA’s other two titles matter less for most compliance programs. Title IV covers telecommunications relay services and captioning of federally funded public service announcements. Title V holds general provisions, including a ban on retaliation against people who assert their rights.
When both laws apply
Many organizations sit under two or three of these at once:
- A private hospital that takes Medicaid falls under Section 504 for its programs and Title III as a public accommodation. See how this plays out in Section 504 for healthcare and patient portals.
- A public university falls under Title II as a state entity and under Section 504 through federal student aid and research funding. Read more on Section 504 in higher education.
- Almost every large employer falls under Title I. If it also receives federal funds, Section 504’s employment rules apply too.
For a side-by-side view that adds Section 508, see how Section 504, the ADA, and Section 508 compare.
One note on terms. A “504 plan” is a document K-12 schools use to set out an individual student’s accommodations. It is separate from an IEP under the Individuals with Disabilities Education Act (IDEA), and separate from your organization’s compliance program, which is what this guide covers. For how accommodation systems run day to day, see how to operationalize Section 504 across schools and workplaces.
What ADA and Section 504 compliance requires
Because the ADA was modeled on Section 504, the two laws share most of their core duties. Courts generally read them the same way.
How both laws define disability
Both laws use the same definition. A person has a disability if they have a physical or mental impairment that substantially limits one or more major life activities, have a record of such an impairment, or are regarded as having one. Major life activities include walking, seeing, hearing, learning, reading, and working.
The laws protect a qualified individual with a disability. For a program or service, that means someone who meets its essential eligibility requirements. For a job, it means someone who can perform the essential functions of the role, with or without reasonable accommodation.
The duties both laws share
- Effective communication: Communication with people with disabilities must be as effective as communication with everyone else. That can mean auxiliary aids and services such as sign language interpreters, captions, or accessible digital formats.
- Reasonable modifications: You must change policies, practices, and procedures when needed to avoid discrimination, unless the change would fundamentally alter the program.
- Program accessibility: For public entities and funding recipients, programs and services, viewed as a whole, must be accessible. That covers physical access to facilities and the digital channels you deliver services through.
- Reasonable accommodation in employment: Employers must adjust jobs, schedules, or equipment so qualified employees and applicants can do the work, unless doing so causes undue hardship. This includes the hiring process and daily training.
Coordinators and grievance procedures
Section 504 has no minimum size. Any organization that receives federal financial assistance is covered. Size does trigger some administrative duties, though:
- Section 504: Recipients with 15 or more employees must designate at least one employee to coordinate compliance and adopt grievance procedures.
- ADA Title II: Public entities with 50 or more employees must designate an ADA coordinator and publish grievance procedures.
Many organizations name one person to cover both roles. Either way, a designated Section 504 coordinator or ADA coordinator can make compliance considerably easier to track and maintain.
The digital standard: two federal rules
Neither law mentions websites. Both were written before the web existed. But both cover the programs and services you deliver through digital experiences. This includes everything from patient portals to online job applications. It also covers PDFs and videos used in your programs.
Two federal rules now set a specific technical standard for that content: WCAG 2.1 Level AA.
| Rule | Who it covers | Compliance date |
|---|---|---|
| DOJ ADA Title II rule | State and local governments with a total population of 50,000 or more | April 26, 2027 |
| State and local governments under 50,000, and special district governments | April 26, 2028 | |
| HHS Section 504 rule | Recipients of HHS funding with 15 or more employees | May 11, 2027 |
| Recipients of HHS funding with fewer than 15 employees | May 10, 2028 |
Both sets of dates moved back a year in 2026: DOJ’s in an April 20 interim final rule, and HHS’s in a May 2026 interim final rule. The extensions moved only the dates. The underlying duty not to discriminate applies today, and the rest of the HHS rule has been in effect since July 8, 2024.
Other funding agencies, including the U.S. Department of Education, have not issued a web-specific Section 504 rule. Private businesses under Title III have no web rule either. Their websites aren’t exempt. In practice, most organizations adopt WCAG 2.1 Level AA because it’s the standard the federal rules reference.
WCAG is published by the World Wide Web Consortium. The newest version is WCAG 2.2, but both federal rules reference WCAG 2.1 Level AA. It covers aspects such as text size and color contrast. It also makes sure that people can use your site with just a keyboard.
A step-by-step website accessibility audit process
For compliance, your organization should implement a website accessibility audit process. A clear audit process will help teams find and fix errors.
- Inventory: First, take a full inventory of all your digital tools.
- Automated scans: Next, run automated scans to find quick fixes, such as missing image descriptions.
- Manual testing: After that, perform manual testing. This means using auxiliary aids, such as screen readers, to understand how a blind user might experience your site.
- Remediation: Once you find bugs, you must prioritize and fix them. Start with the pages that get the most traffic.
- Retest: Finally, retest everything to make sure the fixes work.
Repeat this cycle on a schedule. New content can break accessibility at any time.
Enforcement and remedies
Each federal agency that provides financial assistance enforces Section 504 for its own recipients. The U.S. Department of Education’s Office for Civil Rights handles schools and universities. The HHS Office for Civil Rights handles hospitals and health programs. The Department of Justice coordinates Section 504 enforcement across federal agencies and enforces Title II. People can also sue directly under both laws.
Complaints to an agency’s Office for Civil Rights generally must be filed within 180 days. If a recipient refuses to fix a violation, the agency can ultimately cut off its federal financial assistance. For more on the consequences, see what happens when Section 504 requirements are violated.
Recent Supreme Court decisions
Three recent cases shape what plaintiffs can recover and how they prove their claims:
- Cummings v. Premier Rehab Keller, P.L.L.C.: In Cummings v. Premier Rehab Keller, P.L.L.C. (2022), the Supreme Court held that emotional distress damages cannot be recovered in private lawsuits under the Rehabilitation Act or the Affordable Care Act. The Court treated these as funding-condition laws, like Title VI of the Civil Rights Act of 1964.
- Luna Perez v. Sturgis Public Schools: In Luna Perez v. Sturgis Public Schools (2023), the Court held that a student may sue for compensatory damages under the ADA without first exhausting the IDEA’s administrative procedures. This is because the IDEA does not offer money damages.
- A.J.T. v. Osseo Area Schools: In A.J.T. v. Osseo Area Schools (2025), the Court held that students bringing ADA and Section 504 claims about their education don’t have to show “bad faith or gross misjudgment.” They face the same standards as plaintiffs in other settings.
Official resources
You can find official guidance on the U.S. Department of Education and U.S. Department of Justice websites. These sites explain the law in detail.
Challenges and best practices for Section 504 compliance
For large enterprises, this is hardly a one-time project. Rather, it’s a long-term commitment to how you build and maintain digital tools.
Many teams face the same hurdles when starting this work. Cultural silos keep developers and marketers from talking. Technical debt in old code makes updates slow and costly. Budget limits stop teams from buying the right testing tools. To solve these, show how accessibility helps the whole business: it reaches more users and lowers legal risk.
Your phased road map
You should prioritize your work using a phased road map.
- Risk assessment: Map each issue to its risk and impact.
- Critical issues first: Start with high-traffic pages and key tasks, such as a patient portal login or an online application. Focus on fixing critical barriers first. This might include keyboard navigation or missing alt text.
- Strong governance: Governance is the system of rules and roles that keeps your accessibility efforts compliant. It’s not enough to fix one bug. You need a structured way to make sure every new website or app is accessible.
- Ongoing training: Set up regular training for all teams, especially your development and content teams.
- Testing: Use a mix of automated scans and manual testing with assistive technology, such as screen readers, to confirm your content conforms to WCAG 2.1 Level AA.
- Reporting: Create clear reports to track your progress over time. This makes your efforts auditable and gives your coordinator a record to show regulators.
Good monitoring makes sure that new updates do not break your existing accessibility features.
Move toward a unified accessibility strategy
Treating ADA and Section 504 as one program means one coordinator, one technical standard, and one record of progress, instead of a separate effort for each law. It also improves the experience for everyone who uses your services.
To get started, your team should take these steps:
- Conduct a full audit of all digital properties using both automated and manual testing.
- Appoint clear owners for accessibility, including a Section 504 or ADA coordinator if your size requires one.
- Update your procurement policies to make sure all new software conforms to WCAG 2.1 Level AA.
- Set up a recurring training schedule to keep staff informed of current legal duties, including the 2027 and 2028 compliance dates.
Frequently asked questions
Is Section 504 part of the ADA?
No. Section 504 is part of the Rehabilitation Act of 1973. The ADA was passed in 1990 and modeled on it. The two laws share a definition of disability and are usually interpreted the same way, which is why they’re so often mentioned together.
Does Section 504 apply to private companies?
Yes, if they receive federal financial assistance, such as Medicaid payments or federal grants. A private business that takes no federal money is covered by the ADA, mainly Titles I and III, but not by Section 504.
What size organization needs a Section 504 coordinator?
Section 504 covers recipients of any size. Recipients with 15 or more employees must designate a coordinator and adopt grievance procedures. Under Title II, public entities with 50 or more employees must designate an ADA coordinator.
Which WCAG version do the federal rules require?
Both the DOJ Title II rule and the HHS Section 504 rule require WCAG 2.1 Level AA. WCAG 2.2 is the newest W3C version and adds success criteria on top of 2.1, so teams that build to 2.2 Level AA are also working to the criteria the rules require.
What is the difference between ADA and Section 504 compliance?
Mainly who is covered. Section 504 follows federal money, while ADA coverage depends on the type of organization. The duties themselves overlap heavily. For the full comparison, see Section 504 vs. ADA vs. Section 508.
Does ADA training cover Section 504?
Mostly. Because the laws share a definition of disability and core duties, ADA training covers much of the ground. Add the parts specific to federal funding: coordinator and grievance duties, and the HHS web deadline if you receive HHS funds.
