ADA Checklist for Existing Facilities

Based on the 2010 ADA Standards for Accessible Design

This checklist was produced by the New England ADA Center, a project of the Institute for Human Centered Design and a member of the ADA National Network. This checklist was developed under a grant from the Department of Education, NIDRR grant number H133A060092-09A. However the contents do not necessarily represent the policy of the Department of Education, and you should not assume endorsement by the Federal Government.

Questions or comments on the checklist contact the New England ADA Center at 617-695-0085 voice/tty or

For the full set of checklists, including the checklists for recreation facilities visit

The Americans with Disabilities Act (ADA) requires state and local governments, businesses and non-profit organizations to provide goods, services and programs to people with disabilities on an equal basis with the rest of the public.

Some people think that only new construction and alterations need to be accessible and that older facilities are “grandfathered,” but that’s not true. Because the ADA is a civil rights law and not a building code, older facilities are often required to be accessible to ensure that people with disabilities have an equal opportunity to participate.

The ADA has different requirements for state and local governments and for places of public accommodation (businesses and non-profit organizations that serve the public).

Requirements for State and Local Governments

State and local governments must ensure that services, programs and activities, when viewed in their entirety, are accessible to people with disabilities. This is part of public entities’ program accessibility obligations. Alterations to older buildings may be needed to ensure program accessibility. Generally this is a greater obligation than “readily achievable barrier removal” the standard that applies to public accommodations. State and local governments are not required to take any action that would result in undue financial and administrative burdens.

State and local governments’ ADA obligations for program accessibility are in the Department of Justice’s ADA Title II regulations 28 CFR Part 35.150.

Requirements for Places of Public Accommodation

Businesses and non-profit organizations that serve the public must remove architectural barriers when it is “readily achievable” to do so; in other words, when barrier removal is “easily accomplishable and able to be carried out without much difficulty or expense.”

The decision of what is readily achievable is made considering the size, type, and overall finances of the public accommodation and the nature and cost of the access improvements needed. Barrier removal that is difficult now may be readily achievable in the future as finances change.

Public accommodations’ ADA obligations for barrier removal are in the Department of Justice’s ADA Title III regulations 28 CFR Part 36.304.

Priorities for Accessibility

The checklist follows the four priorities that are listed in the Department of Justice ADA Title III regulations. These priorities are equally applicable to state and local government facilities.

  • Priority 1 - Accessible Approach and Entrance
    • Parking
    • Exterior Accessible Route
    • Curb Ramps
    • Ramps
    • Entrance
  • Priority 2 - Access to Goods and Services
    • Interior Accessible Route
    • Ramps
    • Elevators - Full Size and LULA (limited use, limited application)
    • Platform Lifts
    • Signs
    • Interior Doors - to classrooms, medical exam rooms, conference rooms, etc.
    • Rooms and Spaces - stores, supermarkets, libraries, etc.
    • Controls - light switches, security and intercom systems, emergency/alarm boxes, etc.
    • Seating: Assembly Areas - theaters, auditoriums, stadiums, theater style classrooms, etc.
    • Seating: At dining surfaces (restaurants, cafeterias, bars, etc.) and non-employee work surfaces (libraries, conference rooms, etc.)
    • Seating: General - reception areas, waiting rooms, etc.
    • Benches - In locker rooms, dressing rooms, fitting rooms
    • Check-out Aisles - supermarkets, large retail stores, etc.
    • Sales  and Service Counters - banks, stores, dry cleaners, auto repair shops, fitness clubs, etc.
  • Priority 3 - Access to Public Toilet Rooms
    • Accessible Route
    • Signs at Toilet Rooms
    • Entrance
    • In the Toilet Room
    • Lavatories
    • Soap Dispensers and Hand Dryers (2010 Standards - 603)
    • Water Cloets in Single-User Toilet Rooms and Compartments (Stalls)
    • Toilet Compartments (Stalls)
  • Priority 4 - Additional Access
    • Drinking Fountains
    • Public Telephones
    • Fire Alarm Systems

2010 ADA Standards for Accessible Design

The checklist is based on the 2010 ADA Standards for Accessible Design (2010 Standards). The checklist does not include all sections of the 2010 Standards. For example there are no questions about patient rooms in hospitals or guest rooms in hotels. Consult the 2010 Standards for situations not covered in the checklist. Full compliance with the 2010 Standards is required only for new construction and alterations.

Safe Harbor – Construction Prior to March 15, 2012

Elements in facilities built or altered before March 15, 2012 that comply with the 1991 ADA Standards for Accessible Design (1991 Standards) are not required to be modified to specifications in the 2010 Standards. For example, the 1991 Standards allow 54 inches maximum for a side reach range to a control such as the operating part of a paper towel dispenser. The 2010 Standards lower that side reach range to 48 inches maximum. If a paper towel dispenser was installed prior to March 15, 2012 with the highest operating part at 54 inches, the paper towel dispenser does not need to be lowered to 48 inches.

Elements in the 2010 Standards that aren’t in the 1991 Standards

The 2010 Standards contain elements that are not in the 1991 Standards. These elements include recreation facilities such as swimming pools, team and player seating, accessible routes to court sports facilities, saunas and steam rooms, fishing piers, play areas, exercise machines, golf facilities, miniature golf facilities, amusement rides, shooting facilities with firing positions, and recreational boating facilities. Because these elements are not in the 1991 Standards, they are not subject to the safe harbor exemption. State and local governments must make these items accessible if necessary to ensure program accessibility, unless an undue burden would result. Public accommodations must remove architectural barriers to these items.

What this Checklist is Not

The ADA Title II and III regulations require more than program accessibility and barrier removal. The regulations include requirements for nondiscriminatory policies and practices and for the provision of auxiliary aids and services, such as sign language interpreters for people who are deaf and material in Braille for people who are blind. This checklist does not cover those requirements.

Since this checklist does not include all of the 2010 Standards it is not intended to determine compliance for new construction or facilities being altered.

What are Public Accommodations?

Under the ADA public accommodations are private entities that own, lease, lease to or operate a place of public accommodation. This means that both a landlord who leases space in a building to a tenant and the tenant who operates a place of public accommodation have responsibilities to remove barriers.

A place of public accommodation is a facility whose operations affect commerce and fall within at least one of the following 12 categories:

  1. Places of lodging (e.g., inns, hotels, motels, except for owner-occupied establishments renting fewer than six rooms)
  2. Establishments serving food or drink (e.g. restaurants and bars)
  3. Places of exhibition or entertainment (e.g. motion picture houses, theaters, concert halls, stadiums)
  4. Places of public gathering (e.g. auditoriums, convention centers, lecture halls)
  5. Sales or rental establishments (e.g. bakeries, grocery stores, hardware stores, shopping centers)
  6. Service establishments (e.g. laundromats, dry-cleaners, banks, barber shops, beauty shops, travel services, shoe repair services, funeral parlors, gas stations, offices of accountants or lawyers, pharmacies, insurance offices, professional offices of health care providers, hospitals)
  7. Public transportation terminals, depots, or stations (not including facilities relating to air transportation)
  8. Places of public display or collection (e.g. museums, libraries, galleries)
  9. Places of recreation (e.g. parks, zoos, amusement parks)
  10. Places of education (e.g. nursery schools, elementary, secondary, undergraduate, or postgraduate private schools)
  11. Social service center establishments (e.g. day care centers, senior citizen centers, homeless shelters, food banks, adoption agencies)

Places of exercise or recreation (e.g. gymnasiums, health spas, bowling alleys, golf courses).


Many of the illustrations are from the U.S. Department of Justice and the U.S. Access Board or are based on illustrations produced by the U.S. Access Board and the U.S. Department of Justice.