What does the ADA require of a hotel booking website? In short, two things. First, under the Department of Justice's reservations rule, the site must let guests with disabilities reserve accessible rooms the same way as everyone else, and it must describe your accessible rooms and common areas in enough detail for them to decide for themselves. Second, the site itself has to be usable by people who rely on assistive technology, or the first requirement is meaningless. Most hotel accessibility complaints we see in published cases touch on one or both.

The ADA reservations rule in plain English

The rule sits in the Title III regulations at 28 C.F.R. § 36.302(e). The text, reproduced by the ILRU research center, covers reservations made by phone, in person or through a third party, and applies to reservations made on or after March 15, 2012. It requires a place of lodging to:

1. Offer equal access to booking. Guests needing accessible rooms must be able to reserve them during the same hours and in the same manner as other guests.
2. Identify and describe accessible features of the hotel and its guest rooms "in enough detail to reasonably permit individuals with disabilities to assess independently" whether a room meets their needs.
3. Hold accessible rooms for people who need them until all other rooms of that type have been rented.
4. Reserve and block a requested accessible room so it is removed from all reservation systems.
5. Guarantee that the specific accessible room booked is held for that guest.

The last three points don't apply to individual units that the operator doesn't own or substantially control, which matters for some condo-hotel and rental-pool arrangements. Your lawyer can confirm how that applies to you.

How much detail your website needs

The rule doesn't list exact fields, which is why it has been litigated. In Love v. Marriott Hotel Services (9th Cir. 2022), the Ninth Circuit found the rule ambiguous on detail and deferred to the Department of Justice's guidance. It held that the hotel's website was compliant because it stated the hotel was accessible, listed accessible room types, beds, bathing facilities and communication features, described accessible routes and areas, and gave a phone number for more information. The court also said a site doesn't need to repeat the technical specifications behind the word "accessible" where that term is defined in the ADA Standards.

A summary of that guidance by attorneys at K&L Gates, published on Today's Hotelier, suggests that older properties built before the 1991 Standards should go further, describing the accessible entrance and route to check-in, the route to accessible rooms, and any features that fall short (for example, a narrower door with its measured width).

Accessible-room information checklist

Make sure the same details appear on the OTAs and channel managers you use. The rule covers reservations made "through a third party", so it is worth keeping one master description and syncing it everywhere.

Make the booking journey itself accessible

A perfect room description doesn't help a blind guest who can't operate your date picker. Booking flows are where hotel sites tend to fail, because they combine calendars, pop-ups, room selectors and payment forms. Test these against WCAG 2.2 AA:

• Date pickers work with the keyboard, announce the selected dates and allow typing dates directly.
• "Accessible room" filters are labeled clearly and are not hidden behind an icon with no text alternative.
• Room cards have descriptive alt text on photos and headings that a screen reader can jump between.
• Guest and payment forms have visible labels, clear error messages and no time-outs that can't be extended.
• Pop-ups and cookie banners can be closed with Escape and never trap keyboard focus or hide the focused item.
• Confirmation pages and emails state the accessible features of the room booked, so the guest has a record.

If your booking engine is a third-party product, ask the vendor for its accessibility conformance report and roadmap. Guests experience it as your website, whoever built it. Our guide to boutique hotel website design covers how to keep the booking path short, which helps every guest.

Why hotels are frequent targets

Hotel reservation pages are easy to review remotely, which made them a focus for "tester" lawsuits. The issue reached the US Supreme Court in Acheson Hotels v. Laufer, but, as Consumer Finance Monitor reported, the Court dismissed the case as moot on December 5, 2023 without deciding whether testers have standing. The practical lesson is that the question remains open, so publishing clear, accurate accessibility information is the sensible baseline. For the wider picture, see our article on ADA website lawsuits in 2026.

A practical plan for your property

1. Walk the property with a tape measure and record accessible features, routes and any limitations room by room.
2. Write one master accessibility description and a dedicated accessibility page, then add the room-level details to each room page.
3. Sync the details to your booking engine, channel manager and OTA listings.
4. Check inventory rules so accessible rooms are held and blocked correctly when reserved.
5. Audit the site and booking flow against WCAG 2.2 AA, fixing issues in the code rather than adding an overlay widget.
6. Re-check after every change, including renovations, new room types and booking engine updates.

Our website accessibility service can take the website side off your hands: an audit from US$690, then ongoing monitoring and fixes through Monitor (US$99/month), Care (US$249/month) or Care Plus (US$499/month). No service can promise you will never receive a complaint, but a tested, maintained site serves guests far better and puts you in a stronger position.

This article is general information, not legal advice. Please consult a lawyer about your obligations under the ADA and any state or local law.

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