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Section 504 of the Rehabilitation Act: who it covers and what it requires

Section 504 of the Rehabilitation Act of 1973 says that no otherwise qualified individual with a disability may, solely by reason of the disability, be excluded from, be denied the benefits of or be subjected to discrimination under any program or activity that receives Federal financial assistance, or that an Executive agency or the U.S. Postal Service conducts (Rehabilitation Act, section 504 (29 U.S.C. 794), subsection (a)). It follows the money, where the ADA follows the kind of organization. This guide covers who has to follow it, who is protected, what the regulations ask for, how it differs from the ADA, where complaints go, the other sections of the Rehabilitation Act, and one HHS rule whose web deadlines have moved.

This guide summarizes the sources it cites; it is not legal advice. The official texts are the reference.

What Section 504 says

Congress enacted section 504 as part of the Rehabilitation Act on September 26, 1973 (Pub. L. 93-112, title V, section 504), and it is classified at 29 U.S.C. 794 (Rehabilitation Act, section 504 (29 U.S.C. 794), source note). Subsection (a) is the rule. It bars exclusion from participation, denial of benefits and discrimination, and it applies to two kinds of programs: those receiving Federal financial assistance and those conducted by any Executive agency or by the U.S. Postal Service (Rehabilitation Act, section 504 (29 U.S.C. 794), subsection (a)).

Three phrases in that sentence do most of the work. “Otherwise qualified” is defined by each agency’s regulation for each setting; the Department of Education’s version is in the table below. “Solely by reason of her or his disability” ties the ban to disability. And “program or activity” is defined at length in subsection (b), which decides how much of an organization is covered (Rehabilitation Act, section 504 (29 U.S.C. 794), subsections (a) and (b)). The statute takes its meaning of “individual with a disability” from section 705(20) of title 29, which this guide does not reproduce, and it requires the head of each agency to promulgate the regulations necessary to carry out the section’s 1978 amendments (Rehabilitation Act, section 504 (29 U.S.C. 794), subsection (a)).

Two other things share the number. Section 504 of the 2010 ADA Standards is the one about stairs, covered in ADA stair requirements, and has nothing to do with this law. A “504 plan” is a term from school practice, not from the regulation; the school section below says what the regulation requires.

Who has to follow Section 504

Section 504 applies to a program or activity, and subsection (b) defines that term as all of the operations of the entities it lists, any part of which is extended Federal financial assistance (Rehabilitation Act, section 504 (29 U.S.C. 794), subsection (b)). The closing words, “any part of which is extended Federal financial assistance”, are why assistance to one part of a covered entity can bring all of its operations under the law. The table shows the entities the statute lists and what counts as the program or activity for each.

What “program or activity” covers under section 504(b), by kind of recipient.
Recipient What is covered Where in the statute
State or local government All the operations of a department, agency, special purpose district or other instrumentality; where assistance goes to a government, also the entity that distributes it and each department, agency or other government entity it is extended to 794(b)(1)
College, university or other postsecondary institution All of its operations, or those of a public system of higher education 794(b)(2)(A)
School system All the operations of a local educational agency, a system of career and technical education or another school system 794(b)(2)(B)
Corporation, partnership, other private organization or sole proprietorship The entire organization if assistance goes to it as a whole, or if it is principally engaged in education, health care, housing, social services or parks and recreation; otherwise the entire plant or comparable, geographically separate facility that receives assistance 794(b)(3)
An entity two or more of those set up All of its operations 794(b)(4)

The table is a reading of subsection (b) (Rehabilitation Act, section 504 (29 U.S.C. 794), subsection (b)). The reach is not limited to governments and schools: the Department of Justice’s guide says the Rehabilitation Act covers programs conducted by Federal agencies, programs receiving Federal financial assistance, Federal employment and the employment practices of Federal contractors (DOJ, Guide to Disability Rights Laws, Rehabilitation Act).

A place with no Federal assistance that no Federal agency runs is outside what subsection (a) describes. Businesses open to the public are reached by the ADA instead: Title III bars discrimination in the full and equal enjoyment of the goods, services, facilities, privileges, advantages or accommodations of any place of public accommodation (ADA statute (42 U.S.C. 12101 et seq.), 12182(a)); see ADA Title III.

Who is protected: disability and “qualified”

Each agency’s regulation fills in the terms. Congress replaced “handicap” with “disability” in the statute in 1992 (Rehabilitation Act, section 504 (29 U.S.C. 794), amendments note), but the Department of Education’s regulation, 34 CFR part 104, whose source is a rule of May 9, 1980, still says “handicapped”; this guide quotes that word only where the wording matters. The regulation defines a handicapped person as anyone who has a physical or mental impairment that substantially limits one or more major life activities, has a record of such an impairment, or is regarded as having one (34 CFR part 104, section 104.3(j)(1)). Its list of major life activities includes seeing and hearing (34 CFR part 104, section 104.3(j)(2)(ii)). The three parts match the three parts of the ADA’s definition (ADA statute (42 U.S.C. 12101 et seq.), 12102(1)).

Being protected also depends on being qualified, which the same regulation defines by setting (34 CFR part 104, section 104.3(l)):

Who counts as a qualified person under 34 CFR 104.3(l).
Setting Who is qualified
Employment A person who, with reasonable accommodation, can perform the essential functions of the job
Public preschool, elementary, secondary or adult education A person of an age at which people without disabilities are provided those services, of any age at which state law makes it mandatory to provide them to people with disabilities, or to whom a state must provide a free appropriate public education under the Education of the Handicapped Act
Postsecondary and vocational education A person who meets the academic and technical standards required for admission or participation
Other services A person who meets the essential eligibility requirements for receiving the services

For complaints about employment, section 504 uses another law’s yardstick: the standards applied under Title I of the ADA, and the ADA provisions that relate to employment (Rehabilitation Act, section 504 (29 U.S.C. 794), subsection (d)).

What the regulations ask for

The statute is short and the detail is in regulations, and there are many of them. According to the Department of Justice, each Federal agency has its own section 504 regulations for its own programs, and agencies that give Federal financial assistance also have regulations for the entities that receive it; there are over 20 for assisted programs, such as 34 CFR part 104 for the Department of Education, and over 95 for programs the agencies conduct, such as 28 CFR part 39 (DOJ, Guide to Disability Rights Laws, Rehabilitation Act). Requirements common to them include reasonable accommodation for employees with disabilities, program accessibility, effective communication with people who have hearing or vision disabilities, and accessible new construction and alterations; each agency enforces its own regulations (DOJ, Guide to Disability Rights Laws, Rehabilitation Act).

Part 104 is the clearest example for a funded program. It applies to each recipient of assistance from the Department of Education and to the program or activity that receives it (34 CFR part 104, section 104.2). The table summarizes the rules that matter most for access.

What 34 CFR part 104 asks of a recipient, in its own terms.
Topic What the regulation says
Existing facilities The program, viewed in its entirety, must be readily accessible; the recipient does not have to make every existing facility or every part of one accessible (34 CFR part 104, section 104.22(a))
Ways to get there Redesigning equipment, moving classes or services to accessible buildings, assigning aides, home visits, delivering services at accessible sites, or altering facilities; no structural changes are required where other methods work (34 CFR part 104, section 104.22(b))
New construction and alterations New facilities must be readily accessible to and usable by people with disabilities; altered portions must be, to the maximum extent feasible (34 CFR part 104, section 104.23(a) and (b))
Which design standard Building to sections 3 to 8 of the Uniform Federal Accessibility Standards counts as compliance with the new-construction rule since January 18, 1991 (34 CFR part 104, section 104.23(c)(1))
Telling people what is accessible The recipient must have procedures so that interested persons, including persons with impaired vision or hearing, can find out where the accessible services, activities and facilities are (34 CFR part 104, section 104.22(f))
Notice of nondiscrimination A recipient with 15 or more employees must notify participants, applicants and employees, including those with impaired vision or hearing, that it does not discriminate (34 CFR part 104, section 104.8(a))
A coordinator and a grievance process A recipient with 15 or more employees must designate at least one person to coordinate compliance and adopt grievance procedures (34 CFR part 104, section 104.7)
Employees Reasonable accommodation for a known limitation of an otherwise qualified applicant or employee, unless it would impose an undue hardship (34 CFR part 104, section 104.12(a))

Two features are easy to miss. The existing-facilities rule is about the program as a whole, not each building, which is why the listed methods include moving a class or a service to an accessible building (34 CFR part 104, section 104.22(a) and (b)). And the rule for small providers has conditions: a recipient with fewer than 15 employees that provides health, welfare or other social services may refer a person to accessible providers only if, after consulting the person, it finds that nothing short of a significant alteration would make the service accessible (34 CFR part 104, section 104.22(c)). Subsection (c) of the statute itself says that small providers need not make significant structural alterations to existing facilities if alternative means of providing the services are available (Rehabilitation Act, section 504 (29 U.S.C. 794), subsection (c)).

Section 504 and the ADA

The ADA, enacted in 1990, came after section 504. The two overlap, since a state agency or public college that receives Federal money can be covered by both, and they differ in what triggers coverage and in some wording:

Section 504 compared with the ADA, using the statutes’ own words.
Question Section 504 ADA
What triggers coverage Receiving Federal financial assistance, or being a program an Executive agency or the Postal Service conducts (Rehabilitation Act, section 504 (29 U.S.C. 794), subsection (a)) Title II: being a public entity, meaning a state or local government or one of its departments, agencies or instrumentalities (ADA statute (42 U.S.C. 12101 et seq.), 12131(1)). Title III: owning, leasing or operating a place of public accommodation (ADA statute (42 U.S.C. 12101 et seq.), 12182(a))
The wording of the ban “Solely by reason of her or his disability” (Rehabilitation Act, section 504 (29 U.S.C. 794), subsection (a)) Title II: “by reason of such disability” (ADA statute (42 U.S.C. 12101 et seq.), 12132). Title III: “on the basis of disability” (ADA statute (42 U.S.C. 12101 et seq.), 12182(a))
What is covered Participation in, the benefits of and discrimination under a program or activity (Rehabilitation Act, section 504 (29 U.S.C. 794), subsection (a)) Title II: the services, programs or activities of a public entity (ADA statute (42 U.S.C. 12101 et seq.), 12132). Title III: the goods, services, facilities, privileges, advantages or accommodations of a place of public accommodation (ADA statute (42 U.S.C. 12101 et seq.), 12182(a))
Remedies and procedures Those of title VI of the Civil Rights Act of 1964, for anyone aggrieved by a recipient of Federal assistance (Rehabilitation Act, section 505 (29 U.S.C. 794a), subsection (a)(2)) Title II adopts the remedies, procedures and rights of section 794a (ADA statute (42 U.S.C. 12101 et seq.), 12133)
Employment Judged by the standards of ADA Title I (Rehabilitation Act, section 504 (29 U.S.C. 794), subsection (d)) Title I: a covered entity may not discriminate against a qualified individual on the basis of disability in hiring, advancement, discharge, pay, training and other terms, conditions and privileges of employment (ADA statute (42 U.S.C. 12101 et seq.), 12112(a))

The ADA itself says how the two relate: nothing in it applies a lesser standard than the standards applied under title V of the Rehabilitation Act or the regulations Federal agencies issued under that title (ADA statute (42 U.S.C. 12101 et seq.), 12201(a)). For the ADA side, start with the Americans with Disabilities Act guide and ADA Title II.

Complaints, remedies and who enforces it

Section 505 of the Rehabilitation Act makes the remedies, procedures and rights of title VI of the Civil Rights Act of 1964 available to any person aggrieved by an act or failure to act by a recipient or Federal provider of assistance under section 504 (Rehabilitation Act, section 505 (29 U.S.C. 794a), subsection (a)(2)). The Department of Education’s regulation adds that the procedural provisions of title VI apply to it (34 CFR part 104, section 104.61). In an action or proceeding to enforce the subchapter, the court may, in its discretion, allow the prevailing party, other than the United States, a reasonable attorney’s fee as part of the costs (Rehabilitation Act, section 505 (29 U.S.C. 794a), subsection (b)).

In practice a complaint can start in more than one place. A recipient with 15 or more employees must have a coordinator and a grievance procedure (34 CFR part 104, section 104.7), and each agency enforces its own regulations (DOJ, Guide to Disability Rights Laws, Rehabilitation Act). This guide gives no deadlines or forms, because they depend on the agency and the court. For how to file a section 504 complaint with the appropriate agency, the Department of Justice’s guide points to its Civil Rights Division’s Disability Rights Section (DOJ, Guide to Disability Rights Laws, Section 504).

Section 504 in schools and colleges

Most people meet section 504 in a school, and Part 104 has a subpart for each level.

  • Public elementary and secondary schools: a recipient must provide a free appropriate public education to each qualified person in its jurisdiction, regardless of the nature or severity of the disability (34 CFR part 104, section 104.33(a)). An appropriate education means regular or special education and related aids and services designed to meet individual needs as adequately as the needs of students without disabilities are met (34 CFR part 104, section 104.33(b)(1)). Implementing an Individualized Education Program (IEP) developed under the Education of the Handicapped Act is one way to meet that standard (34 CFR part 104, section 104.33(b)(2)). A school must evaluate a student who needs or is believed to need special education or related services before an initial placement and before any significant change of placement (34 CFR part 104, section 104.35(a)), and must have procedural safeguards that include notice, access to records for the parents or guardian, an impartial hearing and a review procedure (34 CFR part 104, section 104.36).
  • Colleges and other postsecondary programs: a recipient must modify academic requirements as needed so that they do not discriminate, though requirements it can show are essential to the instruction or to a licensing requirement are not treated as discriminatory (34 CFR part 104, section 104.44(a)).
  • Rules that limit participation: a college may not impose rules, such as banning tape recorders in classrooms or dog guides in campus buildings, that have the effect of limiting the participation of students with disabilities (34 CFR part 104, section 104.44(b)).
  • Exams: for students whose disability impairs sensory, manual or speaking skills, exams must be given in a way that measures achievement, not the impairment, unless the skill is what the test measures (34 CFR part 104, section 104.44(c)).
  • Auxiliary aids: a recipient must take the steps needed so that no student is denied the benefits of the program for lack of aids for impaired sensory, manual or speaking skills. The examples include readers in libraries for students with visual impairments; attendants, individually prescribed devices and readers for personal use or study are not required (34 CFR part 104, section 104.44(d)).

The phrase “504 plan” does not appear in Part 104. The regulation requires an appropriate education, evaluation and procedural safeguards, and says an IEP is one way to meet the standard (34 CFR part 104, sections 104.33 to 104.36); the name belongs to school practice. The Department of Justice describes the separate education law, the Individuals with Disabilities Education Act, which requires public school systems to develop an IEP for each child (DOJ, Guide to Disability Rights Laws, Individuals with Disabilities Education Act).

The Rehabilitation Act’s other sections: 501, 503 and 508

Section 504 is one part of a longer Act. The Department of Justice’s guide names the others that matter for disability rights:

Sections of the Rehabilitation Act that the Department of Justice’s guide lists.
Section What it covers
501 Affirmative action and nondiscrimination in employment by Federal executive branch agencies (DOJ, Guide to Disability Rights Laws, Section 501)
503 Affirmative action and a ban on employment discrimination by Federal contractors and subcontractors with contracts of more than $10,000, as the guide states (DOJ, Guide to Disability Rights Laws, Section 503)
504 Programs receiving Federal financial assistance and programs Federal agencies conduct, the subject of this guide (Rehabilitation Act, section 504 (29 U.S.C. 794), subsection (a))
508 Electronic and information technology that the Federal government develops, procures, maintains or uses (Rehabilitation Act, section 508 (29 U.S.C. 794d), subsection (a)(1))

Section 508 is the one that touches blind and low-vision users most directly. It requires each Federal department or agency, unless an undue burden would result, to ensure that employees with disabilities and members of the public with disabilities have access to and use of information and data comparable to what others have (Rehabilitation Act, section 508 (29 U.S.C. 794d), subsection (a)(1)(A)). When meeting the standards would be an undue burden, the agency must provide the information by an alternative means of access (Rehabilitation Act, section 508 (29 U.S.C. 794d), subsection (a)(1)(B)). The standards themselves are published by the Access Board (Rehabilitation Act, section 508 (29 U.S.C. 794d), subsection (a)(2)). The Department of Justice illustrates the idea: a system that gives output only in visual format may not be accessible to people with visual impairments (DOJ, Guide to Disability Rights Laws, Section 508).

A rule in motion: HHS and web accessibility

The Department of Health and Human Services (HHS) revised its section 504 regulation in a final rule published May 9, 2024, effective July 8, 2024 (HHS section 504 final rule, 89 FR 40066). On May 11, 2026, HHS published an interim final rule, effective May 7, 2026, that extends the compliance dates for the web content and mobile app accessibility requirements adopted on May 9, 2024, for recipients of HHS financial assistance (HHS interim final rule, 91 FR 25496):

Compliance dates for the web content and mobile app requirements of the HHS section 504 rule, before and after the 2026 interim final rule.
Recipients Date set in 2024 Date now
15 or more employees May 11, 2026 May 11, 2027
Fewer than 15 employees May 10, 2027 May 10, 2028

The dates are those stated in the interim final rule’s own summary (HHS interim final rule, 91 FR 25496). HHS has published other documents under the same title since 2024, so read the current text in the Federal Register and on the HHS site before relying on a date. This guide does not summarize the technical requirements, which it has not read in full.

What section 504 means at the door, and Braillito Maps

Section 504 tells a funded school, clinic or city office what it must do for people with disabilities. It does not tell a visitor whether a particular entrance has a step. Braillito Maps is a free community map that answers ten questions about each place: step-free entrance or ramp, wide doorway, accessible restroom, accessible parking, tactile paving, braille signage, braille menu, audible signals, guide dogs welcome and a quiet environment.

Each question is answered yes, no or no data until someone knows. A yes means that someone who went reported it; it is not an assessment of whether a place meets section 504 or the ADA. The score of a place is the number of yes answers out of ten, always shown with its number, never by color alone. If a place is missing, add it with its answers; if what a place says is wrong, report it. Meet Braillito Maps.

Frequently asked questions

What is Section 504 of the Rehabilitation Act?

The part of the Rehabilitation Act of 1973 that bars discrimination on the basis of disability in any program or activity receiving Federal financial assistance, and in programs conducted by Executive agencies and the U.S. Postal Service (Rehabilitation Act, section 504 (29 U.S.C. 794), subsection (a)). It is classified at 29 U.S.C. 794.

Who has to follow Section 504?

Any recipient of Federal financial assistance, for the program or activity defined in subsection (b): a state or local government agency, a college or school system, a corporation or other private organization (the whole organization if assistance goes to it as a whole or if it is principally engaged in education, health care, housing, social services or parks and recreation), and the Executive agencies and Postal Service for the programs they conduct (Rehabilitation Act, section 504 (29 U.S.C. 794), subsections (a) and (b)).

What is the difference between Section 504 and the ADA?

Section 504 is triggered by Federal financial assistance or by being a Federal program, while the ADA applies to public entities (Title II) and to places of public accommodation (Title III) whether or not they receive Federal money (Rehabilitation Act, section 504 (29 U.S.C. 794), subsection (a); ADA statute (42 U.S.C. 12101 et seq.), 12131(1); ADA statute (42 U.S.C. 12101 et seq.), 12182(a)). The ADA says it does not apply a lesser standard than section 504 and its regulations (ADA statute (42 U.S.C. 12101 et seq.), 12201(a)).

Does Section 504 apply to private businesses?

Only if the business receives Federal financial assistance, and then the program or activity is the whole organization or just the plant or facility receiving the assistance, depending on the kind of business (Rehabilitation Act, section 504 (29 U.S.C. 794), subsection (b)(3)). A business open to the public with no Federal assistance is not reached by section 504; ADA Title III applies to it instead (ADA statute (42 U.S.C. 12101 et seq.), 12182(a)).

Is a 504 plan required by the law?

The words “504 plan” are not in 34 CFR part 104. The regulation requires public elementary and secondary schools to provide a free appropriate public education, to evaluate before placement and to have procedural safeguards, and it says an IEP is one way to meet the standard (34 CFR part 104, sections 104.33 to 104.36).

Can a college ban guide dogs or tape recorders?

The Department of Education’s regulation says a college that receives its funds may not impose rules, such as banning tape recorders in classrooms or dog guides in campus buildings, that have the effect of limiting the participation of students with disabilities (34 CFR part 104, section 104.44(b)). Rules for service animals under the ADA are in ADA service animals.

More accessibility guides

  • Americans with Disabilities Act: who counts as having a disability, what each of the five titles covers, who enforces it and what it leaves to other laws.
  • ADA Title II: what state and local governments have to make accessible: existing buildings, new construction, streets and curb ramps, parks, programs and the 2024 web rule.
  • ADA Title III: who Title III covers, readily achievable barrier removal, new buildings, alterations and the 20 percent rule, and how it is enforced.
  • ADA Title I: which employers Title I covers, what a reasonable accommodation is, and how a charge with the EEOC works.
  • Accessibility laws by country: the ADA, the UK Equality Act, the Accessible Canada Act, Australia’s DDA and the EU rules, and what each covers.
  • ADA compliance: a checklist for small businesses, with the 2010 Standards section behind each item.
  • ADA service animals: what counts as one, the two questions staff may ask, and when one can be asked to leave.
  • Guide dogs: how they work, where they can go under the ADA, and how to act around one.
  • All accessibility guides

Sources

Every figure in this guide comes from one of these official texts, which we read on November 1, 2026.

  1. Rehabilitation Act of 1973, section 504 (29 U.S.C. 794), Nondiscrimination under Federal grants and programs. U.S. Government Publishing Office (govinfo), United States Code, 2023 edition; read November 1, 2026.
  2. Americans with Disabilities Act of 1990, As Amended (42 U.S.C. 12101 et seq.). U.S. Department of Justice (ADA.gov), mirroring the U.S. Code, including the ADA Amendments Act of 2008; read November 1, 2026.
  3. 34 CFR Part 104, Nondiscrimination on the basis of handicap in programs or activities receiving Federal financial assistance. U.S. Department of Education, in the Electronic Code of Federal Regulations, current text, source 45 FR 30936 (May 9, 1980); read November 1, 2026.
  4. Guide to Disability Rights Laws. U.S. Department of Justice (ADA.gov), page last updated February 28, 2020; read November 1, 2026.
  5. Rehabilitation Act of 1973, section 505 (29 U.S.C. 794a), Remedies and attorney fees. U.S. Government Publishing Office (govinfo), United States Code, 2023 edition; read November 1, 2026.
  6. Rehabilitation Act of 1973, section 508 (29 U.S.C. 794d), Electronic and information technology. U.S. Government Publishing Office (govinfo), United States Code, 2023 edition; read November 1, 2026.
  7. Nondiscrimination on the Basis of Disability in Programs or Activities Receiving Federal Financial Assistance (89 FR 40066). U.S. Department of Health and Human Services, in the Federal Register, published May 9, 2024, effective July 8, 2024; read November 1, 2026.
  8. Extension of Compliance Dates for Nondiscrimination on the Basis of Disability; Accessibility of Web Content and Mobile Applications of Recipients of Departmental Financial Assistance (91 FR 25496). U.S. Department of Health and Human Services, in the Federal Register, published May 11, 2026, effective May 7, 2026; read November 1, 2026.

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