Key Takeaways

  • The ADA (Americans with Disabilities Act) applies to commercial properties and public accommodations
  • The Fair Housing Act applies to residential properties with 4+ units built after March 1991
  • Landlords must allow reasonable modifications at the tenant's expense
  • Landlords must make reasonable accommodations to rules and policies
  • Service animals and emotional support animals must be allowed (no pet deposits)
Last updated: January 2026

ADA & Accessibility Requirements

Understanding disability accommodations is essential for NY real estate practice.

ADA vs. Fair Housing Act

LawApplies ToKey Focus
ADACommercial, publicAccessibility
Fair Housing ActResidentialNon-discrimination
NY Human Rights LawBothBroader protections

Fair Housing Act - Disability Provisions

New Construction Requirements

Buildings with 4+ units built after March 13, 1991 must have:

FeatureRequirement
Accessible entranceAt least one route
Accessible common areasLobbies, laundry, etc.
Accessible doors32" minimum clearance
Accessible routesThroughout unit
Reinforced wallsFor grab bar installation
Accessible switchesReachable height

Reasonable Modifications

Tenants with disabilities have the right to modify units:

Modification TypeWho Pays
Interior changesTenant
Common area changesUsually tenant
Restoration requiredIf reasonable

Examples of Modifications

ModificationPurpose
Grab barsBathroom safety
RampsWheelchair access
Lower countersAccessibility
Visual doorbellsHearing impaired

Reasonable Accommodations

Landlords must accommodate by changing rules or policies:

AccommodationExample
Reserved parkingCloser to entrance
Service animalNo-pet policy exception
Support animalEmotional support
Early lease terminationMedical necessity

Service Animals vs. Support Animals

TypeDefinitionDocumentation
Service AnimalTrained for specific taskNone required
Emotional SupportProvides comfortLetter from provider

Key Rules

RuleDetails
No pet depositsFor service/support animals
No breed restrictionsFor service animals
Limited questionsOnly: Is it needed? What task?
LiabilityOwner responsible for damage

ADA Commercial Requirements

Public Accommodations

The ADA requires accessibility in:

TypeExamples
Places of lodgingHotels, motels
RestaurantsFood service
EntertainmentTheaters, stadiums
RetailStores, malls
Professional officesDoctors, lawyers
Real estate officesBroker offices

Barrier Removal

Existing buildings must remove barriers if:

ConditionRequirement
Readily achievableNot too difficult/expensive
Alternative availableIf removal not achievable
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Disability Accommodations Framework
Test Your Knowledge

A tenant with a disability wants to install grab bars in the bathroom. Under fair housing law, who pays for this modification?

A
B
C
D
Test Your Knowledge

A landlord has a strict "no pets" policy. A tenant with anxiety disorder has an emotional support animal. Can the landlord refuse?

A
B
C
D