Section 504, the ADA, and Section 508 all protect people with disabilities, but they cover different organizations, rely on different technical standards, and are enforced in different ways. Section 504 applies to programs that receive federal financial assistance. The ADA reaches employers, state and local governments, and businesses open to the public. Section 508 applies to the information and communication technology (ICT) that federal agencies develop, buy, and use.
Most large organizations fall under more than one of these laws at the same time. A public university answers to Section 504 and ADA Title II. A hospital that receives HHS funding answers to Section 504 and ADA Title III. A software company selling to federal agencies meets Section 508 through its contracts. This comparison shows where the laws differ, where they overlap, and how to run one digital accessibility program that covers all three.
Section 504 vs. ADA vs. Section 508 at a glance
Section 504 and Section 508 are both part of the Rehabilitation Act of 1973. The Americans with Disabilities Act (ADA) is a separate law, passed in 1990. The table compares the parts of each law that govern websites, mobile apps, and digital documents.
| Section 504 | ADA Title II | ADA Title III | Section 508 | |
|---|---|---|---|---|
| Who it covers | Programs that receive federal financial assistance, plus federal agencies’ own programs | State and local governments, including public colleges and universities | Private businesses open to the public | ICT that federal agencies develop, procure, maintain, or use |
| Technical standard for the web | WCAG 2.1 Level AA for recipients of HHS funding. Check your funding agency’s rules otherwise. | WCAG 2.1 Level AA | No web regulation | Revised 508 Standards, which incorporate WCAG 2.0 Level A and AA |
| Compliance dates | HHS recipients: May 11, 2027 (15 or more employees) and May 10, 2028 (fewer than 15) | April 26, 2027 (population of 50,000 or more) and April 26, 2028 (smaller entities and special districts) | No date set. The obligation applies now. | In effect since January 18, 2018 |
| Who enforces it | The funding agency’s Office for Civil Rights, plus private lawsuits | The Department of Justice (DOJ), plus private lawsuits | Private lawsuits, plus DOJ | Agency complaint processes and civil actions |
| Consequences | Corrective action, with loss of federal funding as the final remedy | Corrective action and court-ordered relief | Court-ordered fixes and attorney’s fees. DOJ can also seek civil penalties. | Equitable relief and attorney’s fees. Section 508 carries no civil penalties. |
The dates reflect interim final rules that the DOJ issued in April 2026 and HHS issued in May 2026, each of which moved the original deadlines back by one year. Neither rule paused the underlying obligation. Covered organizations still have to provide accessible services today.
Section 504
Section 504 was the first major federal civil rights law for people with disabilities. It prohibits disability discrimination in any program or activity that receives federal financial assistance, and in programs that federal executive agencies run themselves. That covers most hospitals and health systems, colleges and universities, state agencies, and many nonprofits.
For a long time, Section 504 required equal access without naming a technical standard for websites. That changed for health and human services in 2024. The HHS Section 504 rule requires recipients of HHS funding to make their web content and mobile apps conform to WCAG 2.1 Level AA, including content that third parties provide under contract. Recipients of other agencies’ funding still owe equal access under Section 504, so check your funding agency’s regulations for any technical requirement. When an organization falls short, the consequences start with a complaint and an investigation. Learn more about what happens when Section 504 requirements are violated.
Section 504 in education
In schools, Section 504 is best known for the 504 plan, which sets out an individual K-12 student’s accommodations. A 504 plan is a separate obligation from an institution’s duty to make its own digital properties accessible. In higher education, students with disabilities receive academic adjustments rather than 504 plans, and the institution’s course content, portals, and websites must be accessible under Section 504. A public university also falls under ADA Title II and its WCAG 2.1 Level AA requirement. See the Section 504 glossary entry for the definition, and this guide to how ADA and Section 504 work together.
The Americans with Disabilities Act (ADA)
The ADA extended the principle behind Section 504 beyond federal funding. It prohibits disability discrimination across most of public life, and three of its titles matter for digital accessibility.
- Title I covers employers with 15 or more employees. It requires reasonable accommodations for qualified employees and job applicants, which can include accessible internal systems and software.
- Title II covers state and local governments. The DOJ’s 2024 web rule requires their web content and mobile apps to conform to WCAG 2.1 Level AA, with compliance dates now set for April 26, 2027 and April 26, 2028.
- Title III covers businesses open to the public, such as retailers, banks, hotels, and private healthcare providers. The DOJ has not issued a web accessibility regulation under Title III, but the obligation to provide equal access still applies to websites and apps.
Titles II and III also require effective communication. Organizations provide that through auxiliary aids and services, such as captions, accessible documents, and content that works with screen readers. Under Title III, private plaintiffs can win court-ordered fixes and attorney’s fees. The DOJ can also seek civil penalties, which are adjusted for inflation each year. For the differences between the two public-facing titles, see Title II vs. Title III.
Section 508
Congress added Section 508 to the Rehabilitation Act in 1986 and strengthened it in 1998. It requires federal agencies to make the ICT they develop, procure, maintain, or use accessible to employees and members of the public with disabilities.
The Revised 508 Standards from the U.S. Access Board took effect on January 18, 2018. They incorporate WCAG 2.0 Level A and AA and apply it to web content, electronic documents, and software. They also add hardware and support documentation requirements that WCAG doesn’t cover. Existing ICT that met the original standards and hasn’t been altered since January 18, 2018 doesn’t have to be updated. Documents are a common gap, so review the Section 508 PDF requirements if your agency or contractor work includes them.
Vendors don’t comply with Section 508 as a matter of law. Agencies do, and they pass the requirements to vendors through procurement contracts. Vendors document how their products conform in an Accessibility Conformance Report (ACR), usually built on the Voluntary Product Accessibility Template (VPAT). An ACR is the vendor’s own statement at a point in time. It is not a certification, and no Section 508 certification exists.
Where the laws overlap
The laws are easiest to understand through the organizations they cover together.
- Public university: Section 504 applies because the university receives federal funding, and ADA Title II applies because it’s a public entity. Title II sets WCAG 2.1 Level AA for its websites and apps.
- Hospital or health system: Section 504 applies to its patient portal and public website when it receives HHS funding. A private hospital is also a public accommodation under ADA Title III.
- Federal contractor: Section 508 reaches the products it sells to agencies through contract terms. Its own public-facing website falls under ADA Title III.
When more than one law applies, build to the highest technical standard among them. In practice that’s WCAG 2.1 Level AA, which includes every WCAG 2.0 success criterion, so it also meets the Section 508 baseline.
Common questions
Is Section 508 part of the ADA?
No. Section 508 is part of the Rehabilitation Act of 1973, the same law that contains Section 504. The ADA is a separate statute passed in 1990.
How does Section 508 relate to Section 504 and the ADA?
Section 504 and the ADA are nondiscrimination laws. They require equal access and apply to organizations based on how they’re funded or what they do. Section 508 is narrower and more technical. It sets accessibility requirements for the technology federal agencies use and buy.
Does Section 508 apply to state and local governments?
Not directly. Section 508 binds federal agencies. State and local governments are covered by ADA Title II, and some states have adopted Section 508 standards through their own laws or policies.
Does Section 508 apply to private businesses?
Only through contracts. A business that sells ICT to federal agencies has to meet the Section 508 requirements in its contract. Its public-facing digital properties fall under ADA Title III instead.
Which WCAG version does each law require?
Section 508 incorporates WCAG 2.0 Level AA. The DOJ’s Title II rule and the HHS Section 504 rule both require WCAG 2.1 Level AA. Title III has no web regulation, though many organizations use WCAG 2.1 Level AA as their benchmark.
One governance program for all three laws
Managing Section 504, the ADA, and Section 508 as three separate checklists duplicates testing and leaves gaps between them. A single program, built to the highest standard that applies to your organization, covers all three.
Leaders should prioritize fixing issues based on three key factors.
- First, look at legal risks. Focus on pages that are most likely to create accessibility issues, triggering complaints.
- Next, look at user impact. Fix the blockers that stop people from completing a purchase or signing up.
- Finally, look at business value. Start with high-traffic templates that affect the most customers at once. This makes sure your budget does the best.
The program needs clear ownership to hold. Every digital property needs a named owner responsible for its accessibility, and the program needs a cross-functional team that includes IT, marketing, legal, and compliance. Map each property to the laws that cover it, set the standard in an internal policy, and track error rates over time so leadership can see progress. Start by asking your teams to perform a full audit of your most important digital assets.
This article is for informational purposes and describes US accessibility law in general terms. It is not legal advice. Consult qualified counsel about your organization’s specific obligations.
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