---
title: "What policy modifications must businesses make for customers with disabilities under the ADA? Answer in under 100 words. Cite only eCFR (www.ecfr.gov) sources."
canonical: https://www.m-i-n-d.ai/minds/ada-accessibility/ada-reasonable-policy-modifications
jurisdiction: "US Federal"
last_verified: 2026-08-27
license: CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/
attribution: "Source: MIND (m-i-n-d.ai)"
---

# What policy modifications must businesses make for customers with disabilities under the ADA? Answer in under 100 words. Cite only eCFR (www.ecfr.gov) sources.

Under 28 CFR § 36.302, public accommodations must make reasonable modifications in policies, practices, or procedures when necessary to afford goods, services, facilities, and privileges to individuals with disabilities, unless the modification would fundamentally alter the nature of those offerings. Businesses must permit service animals (and assessed miniature horses), maintain accessible check-out aisles, and—lodging providers—hold and identify accessible guest rooms through reservations systems on terms equal to other guests.

## Details / How it works

Under 28 CFR § 36.302(a), a public accommodation shall make reasonable modifications in policies, practices, or procedures when necessary to afford goods, services, facilities, privileges, advantages, or accommodations to individuals with disabilities, unless doing so would fundamentally alter the nature of the goods or services.

Under § 36.302(c), a public accommodation must generally modify policies to permit the use of a service animal by an individual with a disability, and may make only two permissible inquiries if the need is not readily apparent. The accommodation may not require documentation, certification, or licensing, and may not impose a surcharge for the service animal.

Under § 36.302(e), a place of lodging must hold accessible guest rooms, identify their features, and accept reservations through the same hours, methods, and stages as other guests.

## Numbers & thresholds

| Requirement | Source | Standard | Effective Date |
|---|---|---|---|
| Reasonable modifications in policies | 28 CFR § 36.302(a) | Required unless it would fundamentally alter the nature of the goods/services | Order No. 1513-91, 56 FR 35592, July 26, 1991 |
| Service animal permitted in all public areas | 28 CFR § 36.302(c)(7) | Required | AG Order No. 3181-2010, Sept. 15, 2010 |
| Lodging reservation rules for accessible rooms | 28 CFR § 36.302(e) | Same hours/manner as other guests; rooms held until rest are rented | March 15, 2012 |
| Permissible inquiries re: service animal | 28 CFR § 36.302(c)(6) | Two: (1) is animal required due to disability, (2) what work/task is it trained to perform | AG Order No. 3181-2010, Sept. 15, 2010 |
| Miniature horse assessment factors | 28 CFR § 36.302(c)(9) | Type/size/weight, handler control, housebroken, legitimate safety | AG Order 3702-2016, Aug. 11, 2016 |

## Exceptions & edge cases

A public accommodation need not provide a reasonable modification if doing so would fundamentally alter the nature of its goods, services, facilities, privileges, advantages, or accommodations (§ 36.302(a)). A service animal may be excluded only if it is out of control and the handler fails to act, or if the animal is not housebroken (§ 36.302(c)(2)). Under § 36.302(g), a public accommodation is not required to provide a reasonable modification to an individual who meets the definition of 'disability' solely under the 'regarded as' prong of § 36.105(a)(1)(iii). For reservations, paragraphs (e)(1)(iii)–(v) do not apply to individual guest rooms not owned or substantially controlled by the entity that owns, leases, or operates the overall facility (§ 36.302(e)(2)).

## Sources

- [1] U.S. Government Publishing Office / Department of Justice — 28 CFR 36.302 — Reasonable modifications in policies, practices, or procedures · https://www.ecfr.gov/current/title-28/section-36.302 · as of 2026-08-27