Functional MRI is an indirect measure of neural activity, being the convolution of the hemodynamic response function (HRF) and latent neural response. The HRF is variable across brain regions and individuals. However, resting-state spinal cord fMRI studies still largely ignore this variability, partly due to an incomplete understanding of HRF variability in the cord. To address this gap, we characterized within- and between-subjects HRF variability within the cervical spine (N=20). 6–9% HRF variability was observed in the gray matter, and 3–5% in the white matter. This is an important confound to be accounted for in future spinal cord fMRI studies.