Access Compliance Reference Materials

The valuation threshold is the annually updated figure used when determining path of travel accessibility requirements in alterations, additions and structural repair construction projects regulated by California Building Code Chapter 11B. 

The annual valuation threshold is based on the January 1981 threshold of $50,000 as adjusted using the ENR 20 Cities Construction Cost Index, published by Engineering News-Record, McGraw-Hill Publishing Company, for January of each year.

VALUATION THRESHOLD FOR RECENT YEARS

2025 ACCESS COMPLIANCE ADVISORY MANUAL

The 2025 Access Compliance Advisory Manual is revised to include the 2025 California Building Code published on July 1, 2025, effective January 1, 2026.

The following document contains the 2025 CBC accessibility provisions adopted by DSA and commentary on selected requirements.  Commentary is included from 2010 ADA Standards for Accessible Design and from DSA for provisions unique to California.  Additionally, an expanded table of contents for Chapter 11B is provided at the beginning of Chapter 11B.

• 2025 California Access Compliance Advisory Reference Manual (PDF)

The following document provides a summary of significant changes to the CBC as amended by DSA during the Triennial Adoption of the 2025 CBC.

• Summary of 2025 California Building Code Changes for Accessibility (PDF)

What is "accessibility"?

"Accessibility" is the combination of various elements in a building or area which allows access, circulation, and the full use of the building and facilities by persons with disabilities.

What is the difference between "accessibility" and "universal design"?

"Universal design" is a broader, more comprehensive "design-for-all" approach to the development of architecture around human diversity. It recognizes the changing diversity of needs important to all types of people regardless of their varying age, ability, or condition, during an entire life. By comparison, "accessibility" has traditionally focused on addressing the needs of a few people with separate circumstances from those of the public at large, when in fact almost everyone is, over the course of their lifetime, quite able to benefit from barrier-free design, user-friendly architecture, and comfortable environments.

What is the purpose of the California accessibility requirements?

It is the intent of the California Legislature that the building standards published in the California Building Standards Code (Title 24) relating to accessibility by people with disabilities shall be used as minimum requirements to ensure that buildings, structures, and related facilities are accessible to, and functional for, every member of the public, so as to provide equal opportunity to access public accommodations. Access is to be provided to, through, and within the buildings, without loss of function, space, or facility where the general public is concerned.

Why are the California Building Standards Code (Title 24) requirements more stringent than the federal Americans with Disabilities Act (ADA) requirements?

The regulations in California were developed by the Division of the State Architect, Access Compliance, eight years before the United States Congress passed the ADA. The current California Building Standards Code was written to provide a single code which would meet all of the most stringent requirements of the original California Building Standards Code, as well as the 1991 Federal Fair Housing Amendments Act and the Americans with Disabilities Act Accessibility Guidelines.

Who is the building official?

The "building official" is the officer or other designated authority charged with the administration and enforcement of this code, or the building official's duly authorized representative in accordance with state law. Local cities and counties have building officials who regulate construction in their jurisdiction. State funded construction on state property is often regulated by a state agency, such as the Division of the State Architect. Sometimes public construction has more than one building official — each has separate jurisdictional oversight responsibilities.

Can I get a waiver from the access requirements?

The California Building Standards Code says that you must get a final determination from the local building official that your project has an unreasonable hardship. This is rarely granted for new construction. Existing buildings undergoing alteration are sometimes allowed to depart from the literal requirements of the building code only when equivalent facilitation is provided.

What is "equivalent facilitation"?

"Equivalent facilitation" is an alternate means of complying with the literal requirements of these standards and specifications that provides access in terms of the purpose of these standards and specifications. In determining equivalent facilitation, consideration shall be given to means that provide for the maximum independence of persons with disabilities while presenting the least risk of harm, injury, or other hazard to such persons or others.

Can DSA help me settle a dispute I am having with my local building inspector who says I must provide access to my restaurant?

No, because DSA is a separate jurisdiction. By law, only the local building authority can make a final determination as to code enforcement issues.

Do point-of-sale transaction counters require a lower check writing surface for people who use wheelchairs?

On state funded projects under DSA jurisdiction, DSA approves projects that provide a lower transaction counter which is minimally 36 inches in width and no more than 34 inches high above the finished floor. If your project is under a local jurisdiction, check with the local building official to see if the same enforcement policy is utilized.

Do all the living units in an apartment building need to be accessible?

Accessibility is required to all covered multifamily dwellings on the lowest floor in buildings without elevators. Certain exceptions apply to multistory units, or smaller buildings such as single or duplex units. In covered multifamily dwellings in buildings with elevators, all units are required to be located on an accessible route. Within the units, the requirements are for accessibility are allowed to be for adaptable dwelling units.

What is a "covered multifamily dwelling"?

"Covered multifamily dwellings" are all dwelling units in buildings consisting of three or more privately funded dwelling units if such buildings have one or more elevators; and all ground floor dwelling units in other buildings consisting of three or more dwelling units.

Is an elevator required in "covered multifamily dwellings"?

No, as long as the first dwelling level floor above grade is accessible. Some buildings have parking on the lower floor, and a ramp, wheelchair lift or elevator will be required to provide access to the lowest dwelling level floor above the parking.

What is an "adaptable dwelling unit"?

An "adaptable dwelling unit" is a dwelling unit in a building with a building entrance on an accessible route designed in such a manner that the public and common use areas are readily accessible to and usable by a person with a disability, and all doors are designed sufficiently wide to allow passage into and within all premises by persons who use wheelchairs as required by the building code.

What are the general requirements of the California Building Standards Code accessibility regulations?

Accessibility to buildings or portions of buildings shall be provided for all occupancy classifications except as specifically modified by the building code. Individual occupancy requirements in the code may modify the general requirements for accessibility, but never to the exclusion of them entirely — unless the requirements for an individual occupancy specifically overrides a general requirement. Multistory buildings must provide access by ramp or elevator, with elevator exceptions available for some buildings. Generally, two story office buildings are not required to have elevators, although all other accessible features are still required on upper floors.

Accessibility requirements can be difficult to understand. Can DSA help me determine what I must do in my construction project?

Construction law is quite difficult, and takes experienced professional expertise. The Division of the State Architect functions as a building oversight agency on state-funded construction projects, and can only direct you to general resources at your local building department. If DSA is the jurisdictional authority, our "California Access Compliance Reference Manual" has all of the building code accessibility regulations and policies used on projects under DSA approval authority. The Manual is available as a free download as an Adobe Acrobat (PDF) file.

What privately funded multistory buildings do not require a ramp or elevator?

The following types of privately funded multistory buildings do not require a ramp or elevator above and below the first floor:
Multistoried office buildings (other than the professional office of a health care provider) and passenger vehicle service stations less than three stories high or less than 3,000 square feet (279 m2 ) per story.

Any other privately funded multistoried building that is not a shopping center, shopping mall, or the professional office of a health care provider, and that is less than three stories high or less than 3,000 square feet (279 m2 ) per story if a reasonable portion of all facilities and accommodations normally sought and used by the public in such a building are accessible to and usable by persons with disabilities.

Can I have all the accessible seating in the back or front row?

Accessible seating or accommodations in places of public amusement and resort, including theaters, concert halls and stadiums, but not including hotels and motels, shall be provided in a variety of locations so as to provide persons with disabilities a choice of admission prices otherwise available to members of the general public. When there are over 300 seats, dispersal is required, and when there are less, no dispersal is clearly indicated in the code. However, some trial courts have found that lack of dispersal creates a highlighted area — generally considered discriminatory. The building code does mention this, and further changes in the code to clarify this is quite likely.

Does a factory need to be accessible?

Yes, the following areas are required to be accessible:

1. Major or principal floor areas shall be made accessible.
2. Office areas shall be made accessible.
3. Sanitary facilities serving these areas shall be made accessible.

What about access to hotels?

Hotels, motels, inns, dormitories, resorts, and similar places of transient lodging shall provide access for persons with disabilities in accordance with the provisions of the accessibility requirements of this California Building Code. Accessible guest rooms or suites shall be dispersed among the various classes of sleeping accommodations to provide a range of options applicable to room sizes, costs, amenities provided, and the number of beds provided.

Must I provide separate accessible toilet facilities?

The California Labor Code requires separate facilities whenever there are more than four employees. Where separate facilities are provided for nondisabled persons of each sex, separate facilities shall be provided for persons with disabilities of each sex also. Where unisex facilities are provided for persons without disabilities, at least one unisex facility shall be provided for persons with disabilities within close proximity to the non-accessible facility.

What accessible routes are required on a site?

When a building, or portion of a building, is required to be accessible or adaptable, an accessible route of travel shall be provided to all portions of the building, to accessible building entrances and between the building and the public way. Except within an individual dwelling unit, an accessible route of travel shall not pass though kitchens, storage rooms, restrooms, closets or other spaces used for similar purposes.

At least one accessible route within the boundary of the site shall be provided from public transportation stops, accessible parking and accessible passenger loading zones, and public streets or sidewalks, to the accessible building entrance they serve. The accessible route shall, to the maximum extent feasible, coincide with the route for the general public. At least one accessible route shall connect accessible buildings, facilities, elements and spaces that are on the same site.

At least one accessible route shall connect accessible building or facility entrances with all accessible spaces and elements and with all accessible dwelling units within the building or facility. An accessible route shall connect at least one accessible entrance of each accessible dwelling unit with those exterior and interior spaces and facilities that serve the accessible dwelling unit.

COMPARISON & INCORPORATION OF THE AMERICANS WITH DISABILITIES ACT (ADA) WITH THE CALIFORNIA BUILDING STANDARDS CODE

What is ADA Certification of State Accessibility Requirements?

Title III of the Americans with Disabilities Act (ADA) authorizes the United States Department of Justice to certify that state laws, local building codes, or similar ordinances meet or exceed the ADA Standards for Accessible Design for new construction and alterations. Title III applies to public accommodations and commercial facilities, which include most private businesses and non-profit service providers.

Congress, by authorizing the certification of state and local accessibility requirements under Title III, recognized the important role that state and local building codes and standards may play in achieving compliance with the building-related aspects of accessibility. State and local building officials who are involved in plan approval and construction inspection processes may provide important assistance to construction and design professionals through their oversight of the accessibility requirements of a certified state code.

Why is ADA Certification Important?

California Government Code Section 4459(c) indicates that the scope of accessibility regulations in the California Building Standards Code shall not be less than the application and scope of accessibility requirements of the federal Americans with Disabilities Act of 1990 as adopted by the United States Department of Justice. ADA certification by the Department of Justice provides the most effective, recognized, and legal method for demonstrating that the California Building Code meets or exceeds the ADA requirements.

Voluntary compliance is an important component of an effective strategy for implementing Title III of the ADA. Private businesses that voluntarily comply with ADA accessibility requirements help to promote the broader objectives of the ADA by increasing access for persons with disabilities to the goods, services, and facilities available in our respective communities. Certification facilitates voluntary ADA compliance by assuring that certified state accessibility requirements meet or exceed ADA requirements. In this regard, business owners, builders, developers, architects, and others in the design and construction industry are benefited because, once a code is certified, they can refer to certified code requirements and rely upon them for equivalency with the ADA.

Certification is advantageous for the following reasons:

1. When an entity is designing, constructing, or altering a building in accordance with an applicable state code that has been certified by the Department of Justice, the designer or contractor will need to consult only that one code, in order to determine the applicable federal and state accessibility requirements.
2. The covered entity will have some degree of assurance in advance of construction or alteration that the ADA requirements will be met.
3. In a legal challenge that might be brought under the ADA to facilities constructed in compliance with an ADA certified code, compliance with the certified code constitutes rebuttable evidence of compliance with Title III of the ADA.
4. A state or local agency enforcing a certified code is for practical, but not legal purposes, facilitating compliance with the ADA and helping to eliminate confusion and possible inconsistencies in standards.
5. The amount of unnecessary litigation can be reduced, particularly if a state or local code agency has an administrative method of effectively handling complaints concerning violations of its code.

Certification of a state accessibility code also allows business owners, builders, developers, and architects to rely on their state or local plan approval and building inspection processes for assistance with ADA compliance through the implementation of certified accessibility requirements. Should a mistake occur in the design or initial construction phase of a project, the mistake can be identified early through the plan approval and inspection processes and corrected at a time when adjustments can easily be made and the costs for doing so remain low. In this manner, state and local building code officials in jurisdictions with an ADA-certified code can play an important role in checking to determine whether accessibility requirements have been met. Also, jurisdictions that provide accessibility "check points" such as those described above through the implementation of a certified code provide a significant benefit to private industry and an incentive for growth and development.

OVERVIEW OF THE CERTIFICATION PROCESS

The Department of Justice provides technical assistance to jurisdictions that are in the process of adopting or amending their accessibility requirements and would like the Department's views regarding the extent to which the proposed requirements comply with or exceed ADA accessibility requirements. To obtain technical assistance, the jurisdiction submits a written request to the Department along with the proposed accessibility requirements and any appropriate supporting materials (for example, information concerning any model code or statute on which the proposed requirements are based; copies of any statute, standard, or regulation referenced in the proposed requirements; and any relevant manuals, guides, or other interpretive information about the proposed code or about provisions of the proposed code that are carried over from a pre-existing code or requirement). The same Department of Justice staff who review certification requests for finally enacted accessibility requirements will undertake a review of the proposed code for technical assistance purposes only. ADA certification, however, can only be granted for finally enacted codes and requirements that are capable of administration under state law.

Throughout the certification review process, Department of Justice staff provide assistance and guidance to representatives of state and local governments that request certification of their accessibility requirements. Upon receipt of a complete certification submission, a team of experienced staff (architects, accessibility specialists and attorneys) undertake a detailed comparison of the submitted accessibility code to the Title III requirements for the design, construction, and alteration of buildings and facilities, including the ADA Standards for Accessible Design. The staff may contact submitting officials during this process to gain additional information about the correct interpretation and application of the submitted code.

Prior to making a preliminary certification determination, the Department often provides written technical assistance to the submitting jurisdiction. In its technical assistance letter, the Department could point out provisions of the submitted code that raise concerns or questions about equivalency with the ADA and may suggest possible changes or revisions to achieve compliance with the ADA. Once a preliminary determination is made that a submitted code meets or exceeds ADA requirements, the submitting jurisdiction is notified, members of the public, including persons with disabilities, are notified, and the public is provided an opportunity to comment. If the preliminary determination of equivalency is sustained, the Department will issue a certification of equivalency.

STATE AND LOCAL CODE ENFORCEMENT EFFORTS

There are thousands of code jurisdictions in the United States that enforce some combination of state building codes. Some, but not all of these include accessibility requirements. Although many are based on a model code, there are major variations among the state codes. Design and construction in accordance with these codes will not constitute compliance with the ADA, unless the codes impose requirements equal to or greater than those of the ADA.

The enforcement of these codes is the responsibility of state or local officials. They usually review building plans and inspect projects at specific intervals during construction to ensure that the construction complies with state law. State and local officials do not have the authority to enforce the ADA on behalf of the Federal government.

Architects, builders, and others involved with design and construction are accustomed to the state and local enforcement system, which lets them know prior to construction whether they need to make changes to their plans in order to achieve code compliance. The ADA relies on the traditional method of case-by-case civil rights enforcement in response to complaints. It does not contemplate federal ADA inspections similar to those done at the state or local level. ADA certification will help to moderate the effects of these differences in enforcement procedures and standards.

CERTIFICATION OF THE CALIFORNIA BUILDING CODE

In 2002, the Department of General Services, Division of the State Architect submitted the 2001 edition of the California Building Code along with a side-by-side analysis of the ADA Standards for Accessible Design to the United States Department of Justice. The side-by-side analysis contained proposed revisions and additions to California Building Code regulations that were considered necessary in order to establish equivalency with the ADA Standards for Accessible Design.

In October 2004, the Division of the State Architect received from the United States Department of Justice, an initial response to the request for certification that the California Building Code meets or exceeds the new construction and alterations requirements of Title III of the Americans with Disabilities Act of 1990, and the United States Department of Justice's regulation implementing Title III, including the ADA Standards for Accessible Design.

THE INITIAL RESPONSE FROM THE UNITED STATES DEPARTMENT OF JUSTICE (October 1, 2004)

The links below provide public access to the initial response from the United States Department of Justice regarding the ADA certification of California Building Code. The response includes a cover letter, side-by-side analysis, and three attachments.

It should be understood that the initial response from the Department of Justice is preliminary. The process for ADA certification will undoubtedly take time; include public participation meetings, interaction with the United States Department of Justice, and rulemaking for building standards. It should therefore be assumed that the side-by-side analysis, including comment from the Department of Justice, is subject to revision. These documents are preliminary, are provided for informational purposes only, and should not be considered as final determinations by the United States Department of Justice and/or the Division of the State Architect.

• Cover Letter with Attachment A Summarizes comments from the side-by-side comparison document.
• Attachment B List of sections in Chapter 11B that provide "unreasonable hardship" exceptions.
• Attachment C List of specific provisions in Chapter 11B for which there appears to be no similar provision in the ADA Standards.
• Side-by-Side Analysis

This portion is currently undergoing updates, please check back soon.

This portion is currently undergoing updates, please check back soon.

The guide provided by DSA offers guidance for understanding the application of Chapter 11B of the California Building Code (CBC) for public housing projects. Selected parts of Federal standards and guidelines are reproduced in this document only to show consistency of those standards and guidelines to the definition of "public housing" in Chapter 2 of CBC. This is document referenced in the definition of public housing that is effective as of July 1, 2021.  

• Guide to Public Housing Regulated by Chapter 11B of the California Building Code