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ADA compliance for hotel websites and reservations

What the ADA asks of a hotel website: the reservations rule, describing accessible rooms, third-party booking sites, and WCAG for the booking flow.

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Pavel Charkasau

ADA compliance for a hotel website has two parts, and hotels are unusual in that one of them is written into a federal regulation. Title III lists "an inn, hotel, motel, or other place of lodging" as a public accommodation (42 U.S.C. § 12181(7)(A)). And since March 15, 2012 the Justice Department's reservations rule, 28 CFR § 36.302(e), has covered reservations "made by any means," including through a third party. A guest who needs an accessible room must be able to book it the same way as everyone else, read enough about its features to judge whether it will work, and get the specific room they booked.

The second part is the website itself. No federal regulation sets a technical web standard for private businesses, as the Justice Department's own web guidance admits, so the working target is WCAG 2.2 Level AA across the booking path. The rule tells you what to publish. WCAG decides whether a guest on a screen reader or a keyboard can get to it.

What does the ADA reservations rule require of hotels?

Five things, from § 36.302(e)(1). A place of lodging must:

  1. Let people with disabilities reserve accessible rooms during the same hours and in the same manner as other guests.
  2. Identify and describe the accessible features of the hotel and its rooms "in enough detail to reasonably permit individuals with disabilities to assess independently" whether they meet their needs.
  3. Hold accessible rooms for guests with disabilities until every other room of that type has been rented.
  4. Reserve accessible rooms on request, and remove them from all reservation systems once booked.
  5. Guarantee that the specific accessible room reserved is held for that guest.

Points 1 and 2 land on the website. Points 3 to 5 land on the property management system and the channel manager, and that's where hotels fail without noticing: the guest books the "accessible king," and inventory sync sells the same room again on another channel.

There is one exception. Under § 36.302(e)(2), the rule does not apply to reservations for individual rooms that the operator of the overall facility does not own or substantially control. The guidance gives the example of a resort where some units run as hotel rooms and others are owned individually; the exemption covers only the individually owned ones.

How much detail do you need to give about accessible rooms?

More than the word "accessible." The Justice Department's guidance on the 2010 rule (28 CFR part 36, Appendix A) explains why: rooms that fully meet current standards can still differ, and "an accessible hotel bathroom may meet accessibility requirements with either a bathtub or a roll-in shower." For some guests that one difference decides whether the room is usable.

For a hotel built to the 1991 Standards, the same guidance says it may be sufficient to state that the hotel is accessible and, for each accessible room, describe:

  • the general type of room (for example, deluxe executive suite)
  • the size and number of beds (two queen beds)
  • the type of accessible bathing facility (roll-in shower)
  • communications features in the room (alarms and visual notification devices)

Older properties with limited accessibility get a longer list. At a minimum, the guidance asks for the accessible entrance, the path of travel to check-in and other essential services, and the accessible route to the accessible rooms. It also asks you to name features that fall short of the 1991 Standards, and its example is precise: "door to guest room measures 30 inches clear." That width may still work for a guest with a narrow chair. They can only decide if you tell them.

I think this is the best-written part of the rule, because it treats the guest as the expert on their own needs. "ADA room available" takes the decision away from them. "Roll-in shower with fold-down seat, two queen beds, visual smoke alarm, bathroom door 32 inches clear" gives it back, and costs someone ten minutes with a tape measure.

Does the ADA apply to hotel booking on third-party sites?

Partly, and more narrowly than most summaries claim. The regulation covers reservations "through a third party," and the Appendix A guidance spells out the hotel's share: you "must make reasonable efforts to make accessible rooms available through at least some of these services" and give those services the accessibility information for the hotel and the rooms. If you do that and the online travel agency fails to show it, the guidance says "the hotel or other place of lodging will not be responsible."

So the practical job is a data feed: make sure your channel manager sends the accessible room types and their descriptions to your distribution partners, and keep a record that it does. Boring work. Nobody checks it until a guest arrives to a bathtub they can't use.

Your own booking engine is different. Embedded on your domain, it is your hotel as far as the guest can tell, whoever wrote the code. Title III covers discrimination carried out "directly, or through contractual, licensing, or other arrangements" (42 U.S.C. § 12182(b)(1)(A)(i)).

Why have so many hotels been sued over their websites?

Mostly over the reservations rule, not WCAG, and one serial filer reached the Supreme Court. In Acheson Hotels, LLC v. Laufer, the Court noted that the plaintiff "has filed over 600 lawsuits against hotels" in five years (Supreme Court, 5 December 2023). This case started with the website of the Coast Village Inn, a bed and breakfast in Maine, and 13 third-party booking sites that listed it.

The question the Court agreed to hear was whether a tester who never intends to stay at a hotel has standing to sue over its website. It never answered. After a lower court sanctioned her lawyer, Laufer voluntarily dismissed her pending suits, and the Court vacated the case as moot. Justice Barrett's opinion says plainly that "the circuit split on the issue briefed and argued in this Court is very much alive."

Two lessons, calmly. Nobody can tell you how a given court will treat a tester, because that question is still open. And the defect at the center of those cases, missing room information, is the cheapest thing on a hotel site to fix. Guests need it regardless of how the standing fight ends.

Which parts of a hotel booking flow usually fail WCAG?

The date picker, almost always. Then room cards and the payment step. (Our ADA overview explains why WCAG is the benchmark even though no regulation names it for private businesses.) Patterns I see on hotel booking engines again and again:

  • A calendar widget built from <td> cells with click handlers and no keyboard support, which fails 2.1.1 Keyboard. A keyboard user can't pick a check-in date, so they can't book at all.
  • Room photos in a carousel where the only text alternative is "image 1 of 12," while the bed size and shower type exist only in the photo.
  • "Book now" buttons that pass a contrast checker and still fail 2.5.8 Target Size (Minimum), the WCAG 2.2 criterion that asks for pointer targets of at least 24 by 24 CSS pixels (W3C).
  • A "Special requests" text box as the only way to ask for an accessible room, when it should be a room type you can select and filter by.

Three criteria added in WCAG 2.2 land squarely on the guest-details and payment steps:

  • 3.3.7 Redundant Entry (Level A). Asking for the guest's name and address again after they entered it on the previous step fails it, unless the information is pre-filled or selectable.
  • 3.3.8 Accessible Authentication (Minimum), Level AA. Loyalty sign-in must not depend on a cognitive function test. Blocking paste into the password field is the usual failure.
  • 2.4.11 Focus Not Obscured (Minimum), Level AA. The sticky "Total: $412 for 2 nights" bar at the bottom of the screen must not completely hide the field that has keyboard focus.

Why 2.2 and not 2.1? Content that conforms to 2.2 also conforms to 2.1 and 2.0 (W3C), so one target covers every version older settlements name. The longer answer is in does the ADA require WCAG.

What should a hotel fix first?

The room information, because it's cheap and specific. For each accessible room type, write down beds, bathing type, communication features, and any doorway or route that falls short of the standard. Put it on the room page as HTML text, not in a PDF fact sheet, and send the same descriptions through your channel manager.

Next, put the mouse away and tab from the date picker to the payment confirmation. Where you get stuck is your first engineering ticket. Our WCAG checklist lists the criteria to check along the way.

Then be honest about what automation covers. Deque's study of more than 2,000 audits put automated detection at about 57% of issues by volume (Deque); counted by success criteria rather than by issue, the figure is closer to 30%. Our scanner will flag an unlabeled date field or a room photo with no alt text. It can't tell you whether "accessible room" on your site means a roll-in shower or a tub with a grab bar, because that fact lives in the building, not the HTML. Full conformance needs human review, and at a hotel part of that review is done with a tape measure.

If you also take bookings from EU travelers, the European Accessibility Act reaches e-commerce services too. Our EAA overview covers that scope.

FAQ

Does the ADA apply to hotel websites?

Yes, in two ways. Title III names hotels as public accommodations (42 U.S.C. § 12181(7)(A)), and the reservations rule at 28 CFR § 36.302(e) explicitly covers reservations made by any means, which includes a hotel's own website.

What accessible room information must a hotel website show?

Enough detail for a guest to decide independently whether the room meets their needs. For hotels built to the 1991 Standards, the Justice Department's guidance suggests room type, beds, bathing facility and communications features (28 CFR part 36, Appendix A). Older properties should add entrance, route and measurement details.

Is a hotel responsible for accessibility on Expedia or Booking.com?

Only up to a point. The guidance asks hotels to make reasonable efforts to offer accessible rooms through at least some third-party services and to give them the accessibility information; if a third party then fails to show it, the hotel "will not be responsible" (28 CFR part 36, Appendix A).

Which WCAG level should a hotel website meet?

WCAG 2.2 Level AA. No federal regulation names a web standard for private businesses (ADA.gov), but AA is the level used in settlements and in the Justice Department's public-sector rule, and 2.2 conformance also covers 2.1 and 2.0 (W3C).

Did the Supreme Court decide the hotel tester question in Acheson v. Laufer?

No. The Court vacated the case as moot in December 2023 after the plaintiff dismissed her suits, so whether a tester has standing to sue over hotel website information was left open (Supreme Court).

See which parts of your booking flow fail, with the exact selectors, before you plan the fixes: run a free scan.

Written by Pavel Charkasau, founder of wcagc.com. I read the reservations rule and the Justice Department's 2010 guidance on it, so the room-description advice here follows the regulation's own text.

Last updated: September 24, 2026

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