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Defense · Section 504

Section 504 for defense AI workflows

Section 504 in defense AI workflows: what compliance requires, who asks for evidence, and the records to keep.

Legal forceBinding on recipients of federal financial assistance
SectorDefense
Checked21 Oct 2026

01 / The rule

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.

  1. 01Do not exclude or disadvantage students on the basis of disability, directly or through contractual or licensing arrangements (34 CFR 104.4).
  2. 02Provide K-12 students with disabilities a free appropriate public education, with individualized 504 plans decided by knowledgeable people.
  3. 03Evaluate students with validated tests given by trained personnel, drawing on varied sources (34 CFR 104.35).
  4. 04Modify academic requirements and exam methods so evaluations measure achievement, not disability (34 CFR 104.44).
  5. 05Keep grievance procedures for disability complaints if the recipient has 15 or more employees (34 CFR 104.7).

02 / In this sector

In a defense AI workflow

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.

Usually asked by

Program office leads and ATO-package owners.

Named alongside

NIST AI RMF · DoW RAI · OMB M-25-21.

Sector pagePlanisphere for defense

03 / Records

Records to keep

  1. 01Accessibility review and conformance report for each AI tool procured
  2. 02504 team records showing individualized review of AI-drafted plans
  3. 03Accommodation request and response logs
  4. 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.

01 · Your teamRecord the event

A disclosure shown, a review signed, a model change approved: the event your system reports.

02 · PlanisphereSeal it

The event becomes a sealed receipt, dated and attributed to whoever is signed in.

03 · AnyoneCheck it

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.

SOURCES

Go back to the source

PRIMARY
PRIMARY
34 CFR 104.44, Academic adjustments

Legal Information Institute (Cornell)

PRIMARY

RELATED

Related: Section 504: the full guide · Section 504 for medicine · Section 504 for law · Section 504 for education