Does the ADA apply to a restaurant's or a hotel's website?

The statute. Title III covers places of public accommodation, and its list names inns, hotels and motels, and restaurants, bars and other places serving food or drink, with an exception for owner-occupied lodging of five rooms or fewer (42 U.S.C. § 12181(7)).

The Department of Justice. Its guidance of March 18, 2022 says the ADA's requirements apply to the goods and services public accommodations offer on the web, that no DOJ regulation sets a detailed web standard for them, and that businesses have flexibility in how they comply (DOJ).

The courts. In Robles v. Domino's Pizza the Ninth Circuit relied on the link between Domino's website and app and its physical restaurants, and said it was not deciding cases where a site's barriers do not impede access to a location's goods and services (opinion, January 15, 2019). The Supreme Court declined review on October 7, 2019 (docket 18-1539).

For hotels, there is a specific rule. A hotel's reservations, including those made through third parties, must let guests reserve accessible rooms the same way as other rooms and must describe accessible features in enough detail for a guest to judge whether a room meets their needs, for reservations made since March 15, 2012 (28 C.F.R. § 36.302(e)).

What about the 2024 rule? The rule with a set web standard and deadlines, adopted in 2024, is for state and local governments (28 C.F.R. § 35.200). DOJ extended its deadlines by interim final rule, effective April 20, 2026, to April 26, 2027 and April 26, 2028, as of November 1, 2026 (Federal Register).