United States (federal) · statute
Section 504: what it requires, and the records to keep
Section 504 bars disability discrimination by recipients of federal funds, and ED's rules require free appropriate public education, fair evaluation, and academic adjustments for students with disabilities. AI ed-tech is covered when a school uses it, so inaccessible tools, unreviewed AI-written 504 plans, and AI flags that penalize disability-related behavior can all violate the law.
01 / What it requires
What Section 504 requires
Any program or activity receiving federal financial assistance, including public school districts and most colleges, and the services they deliver through vendors.
- 01Do not exclude or disadvantage students on the basis of disability, directly or through contractual or licensing arrangements (34 CFR 104.4).
- 02Provide K-12 students with disabilities a free appropriate public education, with individualized 504 plans decided by knowledgeable people.
- 03Evaluate students with validated tests given by trained personnel, drawing on varied sources (34 CFR 104.35).
- 04Modify academic requirements and exam methods so evaluations measure achievement, not disability (34 CFR 104.44).
- 05Keep grievance procedures for disability complaints if the recipient has 15 or more employees (34 CFR 104.7).
02 / AI work
Where it touches AI work
A school's use of AI tools, such as tutoring, proctoring, monitoring or 504-plan drafting, is part of its program, so the tools must be accessible and must not disadvantage students with disabilities. Accountability stays with the school even when a vendor built the tool.
03 / Dates
The dates that matter
Rehabilitation Act enacted
Cummings v. Premier Rehab Keller limits damages
A.J.T. v. Osseo: no heightened standard for students' 504/ADA claims
ED-DOJ agreement: DOJ assists OCR investigations, including Section 504
04 / Enforcement
Who enforces it
ED Office for Civil Rights (with DOJ helping investigate complaints under a June 2026 agreement), up to termination of federal funds; private lawsuits for injunctive relief and compensatory damages, but not emotional distress damages (Cummings, 2022).
05 / Records
Records an organisation keeps
What an auditor or an inquiry usually asks to see. Your obligations depend on your role and your facts.
- 01Accessibility review and conformance report for each AI tool procured
- 02504 team records showing individualized review of AI-drafted plans
- 03Accommodation request and response logs
- 04Grievance procedure and complaint resolution records
Optional evidence · where Planisphere fits
Keep a record anyone can check
When your team meets a duty, Planisphere can seal the event it reports as a receipt.
A disclosure shown, a review signed, a model change approved: the event your system reports.
The event becomes a sealed receipt, dated and attributed to whoever is signed in.
Paste the receipt into Verify. No account or key.
A record supports your compliance evidence process. It is not a legal finding or a certification. Systems that call Planisphere's gate API can also hold or refuse an action before it runs.
QUESTIONS
The questions that come next
Can a generative AI tool legally write Section 504 plans?+
An AI tool can draft material, but it cannot make the decisions. Section 504 rules require that a K-12 student's evaluation and placement draw on varied information and be decided by a group of people who know the child, the evaluation data and the options, and the plan must meet that student's individual needs. A district that lets a tool write plans with no policy and no review by that group risks plans that are not individualized. Review and adapt every AI draft before it is adopted. Read the full answer
What's the difference between Section 504 and IDEA for AI accommodation tools?+
Section 504 is a civil rights law that bars disability discrimination by any recipient of federal funds and covers any student with a disability that substantially limits a major life activity. IDEA is a funding law that gives students in specific disability categories who need special education an IEP, detailed evaluation rules and due process rights. Students covered by IDEA are also protected by Section 504. An AI accommodation tool must fit whichever plan applies, a 504 plan or an IEP, and both depend on individualized decisions by people. Read the full answer
SOURCES
Go back to the source
Legal Information Institute (Cornell)
Legal Information Institute (Cornell)
Legal Information Institute (Cornell)
CHANGE LOG
What changed, and when
Rebuilt from primary sources; facts checked on this date.
Related: Section 504 for education AI workflows · NIST AI RMF · OMB M-25-21/22 · DoW RAI S&IP · EO 14179 · FIPS 140-3 · SHA-256 / FIPS 180-4