What Are the ADA Requirements for Hotels and Resorts? A Compliance Checklist

Which rules apply

Title III of the ADA covers lodging. Facilities built or altered after March 15, 2012 must meet the 2010 ADA Standards. Older facilities must remove barriers where it is readily achievable — easily accomplishable without much difficulty or expense. Nevada building codes may add requirements on top of federal law.

Accessible guest rooms

The 2010 Standards set a minimum number of mobility-accessible rooms, a portion of which must have roll-in showers, scaled to the total number of rooms. Separate minimums apply to rooms with communication features for guests who are deaf or hard of hearing. Accessible rooms must be dispersed across room types and price levels, not concentrated in the cheapest category.

Hotel ADA compliance checklist

• Accessible parking with van-accessible spaces and signage
• Accessible route from parking and drop-off to the entrance and lobby
• Registration counter with a lowered accessible section
• Required number of accessible rooms, dispersed by type
• Roll-in showers, grab bars, and accessible toilets and sinks
• Visual alarms and notification devices in communication rooms
• Pool lifts or sloped entries (two means of entry for larger pools)
• Accessible routes to restaurants, fitness centers, and amenities
• Accessible public restrooms
• Online reservations that describe and allow booking of accessible rooms
• Policies for service animals and staff training

The reservations rule

Under 28 CFR 36.302(e), a hotel must let guests with disabilities reserve accessible rooms during the same hours and in the same manner as others, describe accessible features in enough detail for a guest to judge suitability, hold accessible rooms until all others in that class are booked, and guarantee the specific accessible room reserved. Website and third-party booking descriptions are a frequent source of complaints.

Pools and amenities

Pools with less than 300 linear feet of wall need at least one accessible means of entry, which must be a pool lift or sloped entry; larger pools need two. Spas need one. Lifts must be installed and operable — a lift stored in a closet does not satisfy the requirement.

Why Las Vegas resorts face more scrutiny

Large resorts have thousands of rooms, multiple pools, restaurants, and convention space — every element is a potential barrier. Serial plaintiffs target high-traffic properties, and ADA claims allow recovery of attorney's fees, which drives settlements. A proactive audit is cheaper than defending a lawsuit.

Compliance from a real estate perspective

Chris Sullivan advises hotels and resorts on ADA compliance as both a Nevada attorney and a licensed real estate broker — combining audits, remediation priorities, and defense when claims arrive.