Section 504 Compliance: Website Accessibility Requirements

Section 504 of the Rehabilitation Act of 1973 mandates recipients of assistance from the federal government not discriminate on the basis of disability.

Thus, organizations who receive federal funding may not exclude or deny individuals with disabilities an equal opportunity to participate in or have access to program benefits and services.

Who does Section 504 typically affect?

• universities / colleges
• educational institutions
• public and private schools (who receive funding)
• hospitals
• nursing homes
• mental health centers

Federal funding can include financial aid, grants, and other government monies extended as financial assistance to an organization.

Non-profit associations and organizations who receive federal funding are also affected by Section 504.

Is Website Accessibility Required?

Although the language of Section 504 doesn’t directly address web accessibility, the Section 508 refresh does and the Section508.gov blog definitively answered the question:

Section 504 prohibits discrimination based on disability by federal agencies and recipients of federal assistance. In this instance, accessibility applies to facilities, and communications such as websites. So, if your organization receives federal funding or assistance, your website is required to be accessible. You may also want to consult your funding agencies to determine the requirement to make your websites and other communications accessible. When in doubt, design for accessibility.

What Standards are Required?

WCAG 2.0 AA conformance establishes a great baseline for digital accessibility but because so much of the web is experienced on mobile, I highly recommend WCAG 2.1 AA conformance.

WCAG 2.1 AA includes all of 2.0 AA so you’ll still meet minimum compliance requirements but 2.1 AA also takes more mobile experiences into account so you’ll provide a better experience and be ahead of the curve when compliance requirements are updated.

Download my WCAG 2.1 AA Checklist and Guide for free at Accessible.org.

Read more on the incorporation of WCAG 2.0 AA into Section 508.gov compliance.

Services

There are a handful of reputable companies that offer Section 504 compliance services.

Services typically include manual website accessibility audits, user testing, documentation (including VPATs / ACRs), remediation and/or tech support, and legal support should your entity be on the receiving end of a demand letter or lawsuit.