Section 504 vs. Section 508 Compliance

What are the differences and to whom do they apply?

Section 504 and Section 508 are both part of the Rehabilitation Act, and the names can be confused. They both address accessibility but they apply to different types of organizations and situations.

Section 504 prohibits disability discrimination in programs and activities that receive federal financial assistance.

Section 508 requires federal agencies to make their information and communication technology accessible to people with disabilities.

The difference matters if you're responsible for a website, digital application, online forms, documents, or other public-facing technology. Knowing which law applies to your organization will help you determine which accessibility standards you have to follow.

Section 504 vs. Section 508 at a Glance

Section 504 Section 508
 Focus Disability nondiscrimination Accessible information and communication technology (ICT)
Who is covered Programs and activities receiving federal financial assistance Federal agencies
Websites Covered when part of a covered program or service Covered federal websites and ICT
Mobile apps Covered under applicable regulations, such as the HHS rule Covered federal ICT
Technical standard Depends on the regulation Section 508 Standards

The two laws can overlap. A federal agency can have Section 508 responsibilities while also operating programs covered by Section 504. The laws share a focus on accessibility, but they aren't interchangeable.

What Is Section 504?

Section 504 of the Rehabilitation Act of 1973 is a civil rights law that makes discrimination against people with disabilities in programs and activities receiving federal financial assistance illegal. Source of the funding-dependent, that can include healthcare providers, hospitals, universities, state and local agencies, nonprofits, and other organizations. The requirements depend on the federal agency and type of program involved.

For website owners the main part is that federally funded programs increasingly utilize digital services heavily. If people use your website to apply for a program or schedule an appointment, complete a form and access benefits, or find information about a service, the website is part of how they access that program. HHS, for example, has established clear Section 504 requirements for covered web content and mobile applications.

What Is Section 508?

Section 508 requires federal agencies to make their information and communication technology, or ICT, accessible to people with disabilities. That means websites, software, electronic documents, mobile applications, information kiosks, and other technology used or provided by federal agencies has to be accessible. Section 508 also affects companies that develop and/or provide technology for federal agencies.

A private business doesn't automatically fall under Section 508 because it has a website or sells products to the public. The law is tied to federal agencies and their covered technology.

How Does WCAG Fit In?

This is where website accessibility gets more confusing. WCAG,  (the Web Content Accessibility Guidelines), is technical guidelines developed by the World Wide Web Consortium (W3C). WCAG itself isn't a federal law. Different laws and regulations will use WCAG as their main technical benchmark and there are different levels of WCAG compliance.

Here's an example. The HHS Section 504 rule requires covered web content and mobile applications to conform to WCAG 2.1 Level AA. Section 508 works differently. The current Section 508 Standards incorporate WCAG 2.0 Level A and AA success criteria with additional Section 508 requirements.

When you're looking at a website, figure out which law or regulation applies to your organization. That tells you which technical requirements you have to follow.

What Does Section 504 Mean for a Website?

For organizations covered by Section 504 website accessibility is part of providing equal access to all of its programs and services. Think about a healthcare organization that gets federal funding. Patients use its website to find information, schedule appointments, complete paperwork, or access the patient portal. If part of that experience doesn't work with a screen reader or keyboard, the website can create a huge problem for people trying to access the website with disabilities.

This also applies to online applications, benefits information, educational resources, registration systems, and other digital services. HHS specifically addresses web content and mobile applications in its Section 504 regulations.

What Does Section 508 Mean for a Website?

Section 508 applies directly to websites and other covered ICT for federal agencies. Accessibility needs to be considered throughout the build and development process, from picking service providers  and development through testing and maintenance. It also covers a lot more than public-facing websites. Electronic documents, software, mobile applications, multimedia, and other technology can fall within the standards. All those .pdfs need to be made accessible.

Companies designing or developing websites, software, or other tech for federal agencies need to understand the Section 508 requirements that apply to their projects.

What Are the Current Section 504 Website Deadlines?

If your organization is covered by the HHS Section 504 rule, there are looming deadlines for web and mobile accessibility. HHS extended the original deadlines in May 2026. Under the revised schedule, recipients with 15 or more employees have until May 11, 2027, while recipients with fewer than 15 employees have until May 10, 2028.

These deadlines are for the HHS requirements for covered web content and mobile applications. Other federal agencies might have different requirements and timelines.

How Do You Know Which Requirements Apply?

Who operates the organization, how it is funded, and what the website does? A federal agency brings Section 508 into play, while an organization receiving federal financial assistance could be obliged to Section 504. The nature of the website is important too. A simple informational site and a website handling applications, healthcare services, benefits, education, and other essential services can have extremely different accessibility considerations.

Once you know which requirements you have to follow, an accessibility audit can help you understand where your website stands.

What Should You Check?

A thorough accessibility review takes a look at the parts of the website people actually use. Forms need to have properly associated labels. There need to be clear instructions and useful error messages. Navigation has to work with a keyboard, and you need a visible focus indicator throughout the website. Images need descriptive alt text, videos need require close-captioning and written transcripts, headings have to be in the correct structure, color contrast needs to be high enough, and interactive elements should work with assistive technology.

Don't overlook PDFs and other downloadable documents. A website can be accessible while the documents linked from it aren't. Third-party tools need attention, too. Appointment systems, payment forms, event registration platforms, chat tools, and other embedded services can have accessibility problems of their own.

How Can You Test Your Website?

Automated accessibility tools are a great starting point. They can identify issues such as missing alt text, contrast problems, and certain coding errors.  Manual testing is needed to evaluate keyboard navigation, screen reader usability, forms, menus, documents, and all the parts of the actual user experience.

For larger and more complex websites, a professional accessibility audit can tell your web team what needs attention.

At pondsoup, the audit is the starting point. We identify accessibility barriers, document the issues, and create a practical plan for addressing them. From there, we can handle the remediation work and make the necessary changes to bring a website into alignment with the applicable accessibility requirements and technical standards.

For organizations that need a larger overhaul, we can also rebuild the website with accessibility baked into the design and development process from the start. The goal is to give your organization a website that people with disabilities can use, supported by the standards established in the WCAG.

Frequently Asked Questions

Need to make your website Section 504 or Section 508 Accessible?

If you're responsible for a website and aren't sure which requirements apply, start with your organization's funding, structure, and relationship with the federal government. From there, come to us for an accessibility audit to identify issues and create a plan for taking care of them.

At pondsoup, we'l take care of that process from beginning to end. We audit existing websites, identify accessibility issues, and remediate the site or rebuild it when a larger solution makes more sense. Our goal is to help organizations create websites that meet the accessibility requirements they need to (and more) and work better for everyone who uses them. So get in touch with us so we can get started on your project.

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