Section 504 and Digital Accessibility
- Section 504 of the Rehabilitation Act requires organizations receiving federal financial assistance to provide accessible programs and services
- Section 504 compliance includes making websites, applications, documents, and digital services accessible
- The 2024 HHS final rule aligns Section 504 digital accessibility requirements with WCAG 2.1 AA
- Section 504 applies broadly to healthcare organizations, universities, nonprofits, and state agencies
- Section 504 compliance is closely related to ADA requirements but specifically tied to federal financial assistance
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Strengthening healthcare digital accessibility requirements in the US
What is Section 504?
Section 504 of the Rehabilitation Act of 1973 is a U.S. civil rights law that prohibits discrimination on the basis of disability in programs and services that receive federal financial assistance. It requires covered organizations to ensure that people with disabilities have equal access to the services, programs, and experiences they provide.
Section 504 compliance extends to digital accessibility. Organizations must ensure that websites, applications, documents, and other digital services are accessible and usable by people with disabilities. This is especially important in sectors such as healthcare, education, and public services.
Section 504 is closely related to the Americans with Disabilities Act (ADA). Both laws address disability discrimination, but Section 504 applies specifically to organizations that receive federal funding, while the ADA applies more broadly across public and private entities. Section 504 is administered by each department that provides federal funding, so specific requirements for a covered organization may vary depending on the source of its funding.
Who must comply with Section 504 ?
If your organization receives federal financial assistance, you are required to meet Section 504 compliance requirements. This includes ensuring that people with disabilities have equal access to your programs, services, and digital channels.
Organizations commonly covered under Section 504 include:
- Healthcare organizations
- Universities and schools
- State and local government agencies
- Nonprofits receiving federal funding
Organizations that receive federal financial assistance should evaluate whether Section 504 accessibility requirements apply to their programs, services, and digital channels.
What Section 504 requires for digital accessibility
Under Section 504, digital accessibility should be considered part of providing equal access to programs and services. Organizations must ensure that people with disabilities can independently access, use, and complete tasks across their digital experiences.
Section 504 digital accessibility requirements apply to a wide range of technologies, including:
- Websites
- Mobile applications
- Digital documents and forms
This includes making sure content is accessible, navigation is usable, and key actions—such as scheduling appointments, accessing information, or completing forms—can be performed without barriers.
Meeting Section 504 website accessibility and Section 504 web accessibility expectations means delivering digital experiences that people with disabilities can use independently, including people who rely on assistive technologies.
The HHS Section 504 technical standard
Organizations that receive funding from the Department of Health and Human Services (HHS) have greater clarity on how to meet Section 504 requirements for digital services, following a rule published by HHS in 2024. This rule clarifies how Section 504 compliance applies to digital accessibility for covered entities by aligning Section 504 digital accessibility requirements with WCAG 2.1 Level AA conformance, establishing a consistent standard for accessible digital experiences.
This means organizations must ensure that websites, applications, patient portals, and digital content meet WCAG accessibility criteria. WCAG 2.1 serves as the technical standard used to evaluate and implement Section 504 website accessibility.
For healthcare organizations and others that receive funding from HHS, meeting WCAG 2.1 AA is a key component of achieving and maintaining Section 504 compliance.
Section 504 vs ADA
Section 504 and the Americans with Disabilities Act (ADA) both prohibit discrimination on the basis of disability, but they apply in different ways.
Section 504 applies specifically to organizations that receive federal financial assistance. It requires those organizations to ensure equal access to their programs, services, and digital experiences as part of Section 504 compliance.
The ADA is a broader civil rights law that applies across public and private sectors, including businesses, state and local governments, and public accommodations.
Both laws share similar expectations for accessibility, including digital accessibility, and organizations may have obligations for accessibility under both laws. Organizations often rely on WCAG guidelines to meet accessibility requirements under both Section 504 and the ADA.
Section 504 vs Section 508
Section 504 and Section 508 are both part of the Rehabilitation Act, but they serve different roles in digital accessibility.
Section 504 is a nondiscrimination requirement. It requires organizations that receive federal funding to provide equal access to programs, services, and digital experiences as part of Section 504 compliance.
Section 508 is a law with a supporting technical accessibility standard that applies to federal agencies and organizations. It defines accessibility requirements for information and communication technology (ICT) provided or procured by federal agencies. The Section 508 ICT Accessibility Standards refer to Version 2.0 of the WCAG standards for website, software, and document accessibility.
Both may apply to federal agencies, contractors, or organizations receiving federal funding. In these cases, Section 504 compliance focuses on equal access, while Section 508 provides technical accessibility requirements for ICT provided by federal agencies.
Section 504 and healthcare accessibility
Healthcare is a major focus for Section 504 compliance, particularly following the 2024 HHS rule clarifying digital accessibility requirements for covered healthcare systems. Organizations must ensure that patients with disabilities can independently access services and complete key tasks without barriers.
Section 504 works alongside Section 1557 of the Affordable Care Act, which also prohibits discrimination in healthcare programs and services. Together, these requirements establish clear expectations for Section 504 healthcare accessibility, including digital access to critical services.
This includes ensuring accessibility across:
- Patient portals
- Online scheduling and registration
- Telehealth platforms and digital care services
Meeting Section 504 digital accessibility requirements in healthcare means more than technical compliance. It requires delivering real-world access so patients can find information, complete tasks, and receive care without barriers.
What does Section 504 require for accessibility
Section 504 accessibility requirements ensure that people with disabilities can access and use programs, services, and digital experiences without barriers. For digital accessibility, evaluation typically occurs across three core areas.
Technical accessibility (WCAG conformance)
Organizations are expected to conform to Version 2.1 of the WCAG standards, which provide requirements for how digital resources should be structured, presented, and behave, to support Section 504 website accessibility.
Usability in real-world scenarios
Accessibility must support real user outcomes. People with disabilities must be able to navigate content, understand information, and complete key tasks independently across digital experiences.
Assistive technology compatibility
Digital systems must work with assistive technologies such as screen readers, magnifiers, and alternative input methods, ensuring users can interact with content regardless of how they access it.
Together, these elements define how organizations meet Section 504 digital accessibility requirements in a consistent and meaningful way.
How to comply with Section 504
Achieving Section 504 compliance requires a structured approach that identifies covered digital experiences, addresses accessibility barriers, and maintains access over time.
Identify in-scope systems
Determine which websites, applications, patient portals, documents, and digital services fall under Section 504 accessibility requirements.
Conduct an accessibility audit
Evaluate digital experiences against WCAG 2.1 Level AA to identify gaps and establish a baseline for Section 504 compliance.
Remediate accessibility issues
Prioritize and fix barriers that prevent users from accessing content or completing key tasks.
Test and validate accessibility
Use automated tools and manual testing, including assistive technologies and testing with people with disabilities, to confirm accessibility and usability across real-world scenarios.
Maintain compliance over time
Integrate accessibility into design, development, and content workflows to ensure new resources are built to meet accessibility requirements and to sustain Section 504 compliance as systems evolve.
Section 508 and EN 301 549 are accessibility standards used in different regulatory environments but share a common foundation. Section 508 is the U.S. federal accessibility standard that applies to agencies and organizations working with the federal government, while EN 301 549 is the European standard used to meet accessibility requirements under the European Accessibility Act (EAA).
Both standards were created in a way that harmonizes requirements, including adopting WCAG, providing a consistent framework for implementing accessible digital experiences across websites, software, documents, and other information and communication technology, in the United States and Europe. However, recent updates to EN 301 549 mean its accessibility requirements have evolved and are no longer so tightly aligned with Section 508.
What is a Section 504 accessibility audit
A Section 504 accessibility audit provides a clear baseline of how well your digital experiences meet Section 504 accessibility requirements. It helps organizations identify barriers across websites, applications, patient portals, and digital content.
Effective audits combine automated testing with manual expert review, using WCAG 2.1 Level AA as a conformance baseline. Automated tools can identify certain technical issues, while manual evaluation is needed to assess additional accessibility issues, along with a contextual assessment of usability issues that may affect and workflow completion by people with disabilities.
Testing also includes validation with assistive technologies such as screen readers, magnifiers, and keyboard navigation to ensure users can independently access and interact with digital services.
In addition, a Section 504 audit reviews supporting documentation and processes to confirm that accessibility is addressed consistently across systems and over time.
Learn more about accessibility audits and how to evaluate your current state.
Section 504 compliance checklist
Most organizations start with these core steps to meet Section 504 compliance requirements and establish a strong foundation for digital accessibility:
Identify scope
Determine which websites, applications, patient portals, documents, and digital services fall under Section 504 accessibility requirements.
Audit accessibility
Evaluate digital experiences against WCAG 2.1 Level AA to identify gaps and establish a baseline for Section 504 compliance.
Fix accessibility issues
Prioritize and remediate barriers that prevent users from accessing content or completing key tasks.
Test for accessibility
Validate improvements using automated tools and manual testing, including assistive technologies and testing with people with disabilities, to ensure compliance with Section 504 website accessibility requirements and real-world usability.
Document accessibility
Maintain clear records of how digital systems meet Section 504 digital accessibility requirements, including evaluation and remediation efforts.
Monitor and maintain
Establish ongoing processes to track, test, and improve accessibility over time.
This Section 504 compliance checklist provides a starting point, but long-term success depends on integrating accessibility into how digital services are designed, delivered, and maintained.
Section 504 compliance requires ongoing processes
Section 504 compliance is not a one-time effort. Organizations must establish processes to ensure accessibility is maintained as digital programs and services evolve.
This includes maintaining documentation that demonstrates how systems meet Section 504 accessibility requirements, implementing ongoing monitoring to identify new issues, providing clear channels for users to report accessibility barriers, and tracking remediation efforts to ensure issues are resolved effectively.
Sustaining Section 504 compliance requires accessibility to be integrated into everyday workflows, from up-front user research, through design and development to testing and ongoing maintenance. Effective accessibility processes also apply to procurement of third-party tools and services to support digital development.
Need help with Section 504 compliance?
Understanding your current level of Section 504 compliance is the first step toward delivering accessible, usable digital experiences. An accessibility audit can help identify gaps across websites, applications, patient portals, and digital content, while structured evaluation supports ongoing alignment with Section 504 digital accessibility requirements.
If you’re assessing your accessibility baseline or looking to strengthen how you meet Section 504 accessibility requirements, Vispero’s Digital Accessibility Services experts can help through expert audits, assistive technology-informed evaluation, and ongoing accessibility support.
Section 504 FAQ
What is Section 504
What is Section 504 compliance?
Who must comply with Section 504?
What are Section 504 accessibility requirements?
What is the HHS Section 504 rule?
What are the deadlines for the HHS Section 504 web and mobile accessibility requirements?
Does Section 504 apply to websites?
What is the difference between Section 504 and ADA?
Section 504 applies to organizations that receive federal funding, while the ADA applies more broadly to public and private entities. Both require accessibility and prohibit discrimination based on disability.