Section 504 Compliance, Explained

Section 504 of the Rehabilitation Act ensures equal access to programs and services for people with disabilities. While many organizations focus on compliance with the Americans with Disabilities Act (ADA) for websites or Section 508 for federal technology, Section 504 requirements often go overlooked — despite affecting thousands of schools, nonprofits, and organizations receiving federal funding.

And ignoring accessibility isn’t just risky — it can be expensive. Organizations that don’t comply with Section 504 can not only lose federal funding, but they can also face lawsuits that can quickly get expensive. Plus, they risk serious damage to their reputation.

But accessibility isn't just about avoiding penalties. Understanding what Section 504 requires — and how to meet those standards — is key to creating programs and digital content that work for everyone. 

Below, we’ll explore exactly what Section 504 compliance is, what the requirements are, how to meet them, and how to test for compliance.

What is Section 504 Compliance?

Section 504 is part of the Rehabilitation Act of 1973, a landmark civil rights law that prohibits discrimination based on disability in programs and activities that receive federal financial assistance. Unlike the ADA, which applies broadly to businesses and public spaces, Section 504 specifically targets federally funded entities in education, employment, healthcare, transportation, and public service. 

The law states: No otherwise qualified individual with a disability shall, solely by reason of her or his disability, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance.

Put simply, organizations that receive federal funds must provide equal access and reasonable accommodations for people with disabilities. Meeting Section 504 requirements is a key part of accessibility and compliance for schools, healthcare providers, government programs, and more.

The Difference Between Section 504, ADA, and WCAG

It’s common to see Section 504, the ADA, and Section 508 mentioned together — but they are different. Here’s what each covers: 

• Section 504 applies to any organization receiving federal funding and covers all programs, services, and activities — both digital and physical.

• The ADA applies more broadly to businesses, state and local governments, and public accommodations, regardless of federal funding status.

• Web Content Accessibility Guidelines (WCAG) are technical standards created by the W3C that describe how to make web content accessible. WCAG itself isn’t a law, but Section 504 and the ADA often reference WCAG 2.1 Level AA for digital accessibility compliance. 

• Section 508 is another part of the Rehabilitation Act that specifically requires federal agencies to make their electronic and information technology accessible. 

Understanding these differences is crucial for ensuring that you meet accessibility requirements and create digital and physical programs that are accessible to everyone.

Who Must Comply?

Section 504 applies to any organization that receives federal financial assistance. This is broader than many realize — it's not just federal agencies.

Organizations Required to Comply

• Educational institutions: Public schools, colleges, and universities that receive federal funding through programs like Title I, Pell Grants, or federal student loans.

• Healthcare facilities, including hospitals and clinics, that receive federal grants or reimbursements, such as Medicare or Medicaid.

• Nonprofits: Organizations with federal grants, contracts, or assistance. 

• State and local government programs: Any program funded through federal grants.

• Federal agencies and contractors: Organizations working directly with federal contracts.

Programs and Services Covered

Section 504 requirements also extend to all aspects of operations, including:

• Educational programs and extracurricular activities

• Student services and campus facilities

• Employment practices and workplace accommodations

• Healthcare services and patient communications

• Public events and community programs

• Websites, mobile applications, and digital documents

• Internal communications and staff resources

Many organizations mistakenly believe they're exempt from Section 504 because they primarily serve the general public or don't consider themselves "federally funded." In reality, any receipt of federal financial assistance triggers Section 504 compliance, making accessibility a requirement across programs, services, and digital content.

Why Section 504 Compliance Matters

Failing to comply with Section 504 can have serious consequences for any organization receiving federal funding:

Legal Consequences of Non-Compliance:

• Loss of federal funding: Non-compliance can result in the termination of federal financial assistance, potentially costing schools and nonprofits millions in annual funding.

• Lawsuits and legal fees: Individuals can file complaints with the Department of Education's Office for Civil Rights or pursue private legal action, resulting in costly litigation and settlements.

• Mandated remediation: Organizations found non-compliant may be required to undergo extensive corrective action plans, including facility modifications, policy overhauls, and regular monitoring.

• Reputation damage: Public complaints and investigations can erode trust with students, patients, donors, and community members.

Beyond Risk: The Benefits of Compliance

Compliance isn’t just about avoiding penalties — it also provides significant organizational advantages:

• Broader reach: Accessible programs and digital content serve the more than 70 million Americans with disabilities, a market segment representing significant purchasing power and community influence.

• Better user experience: Accessibility features like clear navigation, captions, and readable fonts benefit everyone, including parents with strollers, people with temporary injuries, older adults, and individuals with disabilities.

• Competitive advantage: Demonstrating a commitment to accessibility sets your organization apart, attracting top talent, students, and partners who value equity and inclusion. 

• Future-proofing: As accessibility expectations grow and the population ages, compliant organizations are better positioned to serve evolving demographics.

Woman sitting in front of a computer screen showing a website with various errors on it holding a magnifying glass. A gear shaft with the accessibility symbol is to the left of the computer.

Core Requirements of Section 504

Section 504 compliance encompasses three main areas: physical accessibility, programmatic accessibility, and digital accessibility. Each is essential to ensure people with disabilities can fully participate in your programs, services, and activities.

Physical Accessibility

Organizations must ensure physical facilities are navigable and usable for people with disabilities:

• Wheelchair ramps, elevators, and accessible parking.

• Clear wayfinding signage with tactile and braille elements.

• Accessible restrooms and drinking fountains.

• Adequate lighting and acoustics.

• Accessible routes throughout buildings and outdoor spaces.

Programmatic Accessibility

Beyond the physical space, Section 504 requires equal access to programs, services, and benefits. This includes providing things such as:

• Auxiliary aids, like sign language interpreters or assistive listening devices.

• Alternative formats for printed materials (large print, braille, audio).

• Accessible communication methods for announcements and emergency information.

• Reasonable modifications to policies and procedures.

• Equal opportunity to participate in all activities and events.

Digital Accessibility

In today's digital landscape, Section 504 extends to all digital content and technology:

• Websites that work with assistive technologies, including screen readers and keyboard commands/shortcuts.

• Mobile applications with accessible features and controls.

• PDF documents tagged for assistive technology.

• Videos with accurate captions and audio descriptions.

• Email communications and online forms that are perceivable and operable.

• Learning management systems and educational technology platforms.

For organizations covered by Section 504, Section 508 compliance may also apply to electronic and information technology. Understanding how these standards overlap helps create a truly inclusive experience — online and offline.

How to Meet Section 504 Standards

Achieving Section 504 compliance requires time and intention. It’s about making sure accessibility is built into how you operate — not added on later. Below are five steps to help you meet Section 504 requirements and enhance the user experience.

1. Conduct an Accessibility Audit 

Start by looking at how accessible your existing content is by conducting an accessibility audit. Your audit should be conducted across all areas of your organization, including:

• Physical facilities and campus/office environments

• Digital properties, including websites, apps, and documents

• Communication methods and public-facing materials

• Policies and procedures for requesting accommodations

• Staff training and awareness levels

Consider working with accessibility experts or using specialized tools to identify gaps that automated tools or your team might miss.

2. Identify Barriers in Physical and Digital Spaces

Once you’ve conducted an audit, look at the issues found and take steps to resolve them. Consider prioritizing accessibility fixes based on their overall impact and frequency. For instance:

• Critical barriers: Issues that completely prevent access (e.g., no alt text on essential navigation, inaccessible registration forms, buildings with no ramp access).

• Significant barriers: Problems that make access difficult but not impossible (e.g., poor color contrast, complex navigation, heavy doors).

• Minor barriers: Inconveniences that affect user experience (e.g., inconsistent heading structure, missing form labels).

Document each barrier with specifics: What's the issue? Who does it affect? Where does it occur? This can help guide fix efforts and show good-faith compliance.

3. Implement Practical Solutions

Address identified barriers with concrete, measurable improvements.

For Digital Content:

• Create accessible PDFs with proper tagging, reading order, and alternative text for images.

• Add accurate captions to all videos, including auto-generated content that's been reviewed and corrected.

• Ensure websites are accessible to users with visual impairments by using semantic HTML and ARIA labels.

• Design forms with clear labels, error messages, and keyboard accessibility.

• Test color contrast ratios to meet WCAG 2.1 Level AA standards (4.5:1 for normal text).

For Physical Spaces:

• Install temporary ramps while planning permanent accessibility improvements.

• Add tactile signage and braille labels at decision points.

• Ensure adequate lighting in hallways, stairwells, and parking areas.

• Provide assistive listening systems for meeting rooms and auditoriums.

For Programs and Services:

• Develop clear procedures for requesting accommodations.

• Provide materials in alternative formats upon request (and proactively when possible).

• Train customer service staff on disability etiquette and available accommodations.

• Review policies for inadvertent barriers (e.g., "must present photo ID" when not all individuals can obtain one).

4. Train Staff and Create Policies for Ongoing Compliance

Accessibility isn't a one-time project. It requires ongoing commitment, which can be done by:

• Regular accessibility training for all staff, from leadership to front-line employees.

• Specialized training for content creators, web developers, and facilities managers.

• Clear policies for creating and purchasing accessible content and technology.

• Designated accessibility coordinators or committees.

• Accessible hiring and onboarding practices.

5. Monitor and Update Regularly

Maintaining compliance under Section 504 requires consistent oversight. Regular reviews help ensure that accessibility standards remain current and that new barriers don’t appear over time. Be sure to:

• Conduct annual accessibility audits to catch new issues.

• Test new digital content with accessibility experts and real users who have disabilities before publication.

• Monitor for changes in accessibility laws and standards.

• Gather feedback from users with disabilities.

• Document remediation efforts and progress toward goals.

• Review vendor contracts to ensure third-party tools meet accessibility standards.

Use a Section 508 compliance checklist tailored to your Section 504 requirements to maintain consistent standards throughout your organization.

Common Challenges and How to Overcome Them

Even organizations committed to accessibility face obstacles. Here are some of the most common challenges when meeting Section 504 requirements — and practical ways to address them.

"Accessibility is too Expensive or Technically Difficult."

This is a common misconception. While updating inaccessible legacy content may require an investment, integrating accessibility into a new process from the start is typically a low-cost approach. Many features — like proper heading structure, descriptive link text, keyboard navigation, and assistive technology compatibility — can be added with minimal extra effort during design and development processes.

Balancing Accessibility with Existing Systems

Legacy websites, learning management systems, and document repositories can seem overwhelming to retrofit. Focus on areas with the greatest impact. Start with high-traffic digital properties, essential services, and frequently requested documents. For older systems, provide accessible alternatives (like a text-only version or an accessible PDF) while planning long-term replacements.

Lack of Internal Expertise

Not every organization has a dedicated accessibility specialist. Training existing team members — developers, designers, copywriters, content creators, and facilities managers — in accessibility fundamentals is often the most practical approach. For complex technical issues or legal questions, automated accessibility testing tools and expert guidance can help fill the gaps.

Pro Tip: Combining automated testing with expert audits can make ongoing compliance with Section 504 (and other accessibility standards) more manageable. For example, AudioEye uses powerful automation to identify common issues, while our team of experts and people with disabilities identify more complex issues. This comprehensive approach streamlines Section 504 compliance and offers 400% more protection than consulting or automation-only approaches.

Illustration of two hands shaking over a desk with a computer, gears, plant, and icons representing communication and data.

Unlock the Benefits of Section 504 Compliance with AudioEye

Meeting Section 504 standards protects civil rights and opens programs to a wider audience. While the requirements may seem complex, breaking them down into manageable steps — such as auditing current accessibility, identifying barriers, implementing solutions, training staff, and regularly monitoring progress — makes compliance achievable.

And with the right accessibility solution, achieving Section 504 compliance is easier than ever. AudioEye’s Digital Accessibility Platform expertly combines powerful automation with human-assisted AI technology to help your team maintain compliance with Section 504 requirements as well as other key accessibility standards. With continuous monitoring, regular audits, and actionable guidance, you can easily stay on top of accessibility requirements and ensure programs, services, and digital content remain accessible for everyone.

Ready to get started? Scan your site to identify accessibility issues and start your path to Section 504 compliance now.