Employees in public-facing workplaces can use ADA Titles I and III to advocate for accessibility improvements that benefit both staff and customers with disabilities.

The Association for Equal Access (A4EA) centers its mission on Title III of the Americans with Disabilities Act (ADA), which ensures that places of public accommodation are accessible to people with disabilities. While the ADA’s Title I addresses employment rights and accommodations, Title III sets accessibility standards for physical spaces open to the public. Workplaces that serve the general public are covered by both Title I and Title III.

Knowing how Title III’s accessibility requirements apply to workplaces helps employees with disabilities identify barriers to access and advocate for needed changes. Not only can physical barriers in public-facing work environments affect an employee’s ability to perform job duties, but they can also limit access for customers with disabilities. Advocacy for compliance with Title III accessibility standards within workplaces benefits both employees and the broader community by creating more inclusive environments.

The A4EA offers guidance on recognizing accessibility barriers in public-facing workplaces, how to advocate effectively for improvements based on Title III requirements, and examples of common modifications that support access. We aim to empower employees to promote equitable access at work, aligning with our mission of advancing equal access in everyday public settings.

Who Is Covered by ADA Titles I and III

Titles I and III of the Americans with Disabilities Act apply to different types of entities and protect individuals in distinct contexts. Employees with disabilities who work in public-facing roles benefit from clearly knowing which protections each title provides and how those protections overlap. In many situations, both sets of legal protections may apply in parallel.

Title I applies to private employers, state and local governments, employment agencies, and labor unions with fifteen or more employees. It prohibits discrimination against qualified people with disabilities in all aspects of employment, including hiring, firing, promotions, compensation, job training, and reasonable accommodations. To be covered under Title I, a person must meet the employer’s legitimate skill, experience, education, or other job-related requirements and be able to perform the essential functions of the job, with or without reasonable accommodations.

Title III, on the other hand, applies to private entities that own, lease, lease to, or operate places of public accommodation. These include a wide range of businesses and organizations that serve the public, such as restaurants, retail stores, hotels, banks, theaters, museums, libraries, and private medical or legal offices. Title III prohibits these businesses from discriminating against people with disabilities in the full and equal enjoyment of goods, services, and facilities.

Although Title III does not address employment relationships directly, it still applies to the physical workplace when the workplace is also a public-facing facility. In such cases, both customers and employees may encounter the same architectural or communication barriers, and employees may advocate for changes under Title III when those barriers affect public spaces or shared areas such as entrances, restrooms, and customer service counters.

Employees with disabilities who work in public-facing roles benefit from knowing their ADA rights.

What Title III Requires in Public-Facing Workplaces

Title III of the ADA applies to businesses and nonprofit organizations that offer goods or services to the public. The law requires these entities to remove architectural barriers to access in existing facilities when doing so is readily achievable (i.e., when modifications can be made without significant difficulty or expense) and to design new or altered facilities to be fully accessible. The U.S. Department of Justice (DOJ) enforces Title III and publishes the ADA Standards for Accessible Design, which detail specifications such as:

Doorway width and maneuvering space for mobility devices
Ramp slope and dimensions
Restroom layout and fixtures
Accessible parking requirements
Signage and communication access

When a business undertakes a structural alteration—such as renovating restrooms or installing a new service counter—Title III requires the change to comply with accessibility standards to the maximum extent feasible, meaning that accessibility cannot be sidelined for cost savings. This heightened standard is where many accessibility problems occur: modifications are often made without fully meeting ADA design requirements, leaving newly altered areas still out of compliance.

For employees in public-facing workplaces, these requirements affect the physical environment where they perform their duties, especially in spaces shared with customers. Despite legal requirements, many workplaces fail to provide full access. Typical barriers to access include:

Steps at entrances without ramps or lifts
Narrow aisles and doorways that block mobility device access
Restrooms lacking grab bars or accessible fixtures
Counters that are too high for mobility device users
Poor lighting or inadequate signage that complicates orientation
Emergency exits that are inaccessible or lack visual and audible alarms

Such obstacles can both impede an employee’s ability to work effectively and compromise customer access.

Where Employers Are Expected to Remove Barriers

Businesses that serve the public are covered under Title III of the ADA, and those that also employ staff must consider obligations under Title I as well. This means they must address accessibility from both customer and employee perspectives, along with avoiding practices that constitute disability discrimination.

Physical barriers, such as merchandise displays blocking aisles or malfunctioning automatic doors, can violate Title III if they interfere with consistent access for the public. For employees, similar obstructions may fall under Title I if they hinder a person with a disability from performing their job or accessing workplace facilities.

Maintaining accessible communication is also part of the obligation. Accessibility is not limited to physical access but also includes ensuring both customers and employees can receive information and engage on equal terms. Employers may need to provide auxiliary aids like captioning, assistive listening systems, or alternate-format materials, depending on the context.

While neither Title I nor Title III requires modifications that would impose an undue hardship, employers are expected to consider all reasonable options. Factors like financial resources, staffing, operational impact, and the feasibility of alternative solutions play a role in determining what is reasonable. Even when a specific change isn’t possible, alternate arrangements, such as offering services in accessible areas or adjusting employee workspaces, may still be required.

Whether interacting with the public or accommodating employees, businesses are expected to demonstrate good-faith efforts toward accessibility, particularly when gradual improvements are within reach.

Employees with disabilities face both physical and systemic barriers in public-facing jobs.

How Employees Can Advocate for Accessibility Improvements

Employees can raise concerns and request modifications to improve accessibility in their workplaces under Title III. While employment accommodations fall under the ADA’s Title I, Title III’s focus on physical access applies directly to public areas within the workplace. Here’s how you can begin making changes at work:

Document Accessibility Barriers. Record detailed notes and photos showing how specific features impede access or performance.
Review Relevant ADA Standards. Use the ADA Standards for Accessible Design to understand how your workplace should comply.
Submit a Written Request. Provide a clear, factual letter or email to your employer describing the barriers to access and referencing Title III’s requirements. Include suggestions for possible fixes, such as installing ramps, widening aisles, or adjusting counters.
Keep Records and Follow Up. Track all communications and responses. If no action is taken, a formal complaint may be necessary.
Seek External Support When Needed. Contact the DOJ ADA Information Line or consult advocacy groups like the National Disability Rights Network for assistance with complaints or legal options, which may include pursuing injunctive relief if a resolution cannot be reached and there is evidence of disability discrimination.

Changes can benefit both employees and customers, enhancing accessibility for all. In public-facing workplaces, employees commonly request:

Installation of ramps or lifts at entrances
Widening doorways and aisles to meet accessibility standards
Modification of restrooms to include grab bars and accessible fixtures
Lowering of service counters for mobility device access
Addition of accessible parking spaces with proper signage
Improvements in signage and lighting to aid wayfinding

When Legal or Advocacy Support May Be Necessary

You don’t have to handle persistent inaccessibility alone. If you've exhausted internal channels and your accessibility concerns remain unresolved, it may be time to seek outside support. Legal or advocacy assistance can provide the pressure necessary to compel action, especially when earlier requests have been ignored or dismissed.

Disability rights organizations, particularly state-based protection and advocacy agencies, can help evaluate your situation and recommend next steps. These groups often assist with writing formal demand letters, filing administrative complaints, or preparing for litigation if warranted.

For unresolved employment issues, contacting the U.S. Equal Employment Opportunity Commission (EEOC) may be appropriate. If the problem also affects public access, you may need to pursue a separate Title III complaint or consider a private civil suit.

In some cases, advocacy groups may offer mediation services or help you connect with attorneys who specialize in disability rights. Even if you’re not ready for legal action, having professional support can shift the conversation and lead to results that informal approaches failed to achieve.

Why Workplace Advocacy Matters

Employees in public-facing workplaces are in a unique position to promote change, not only for themselves but for every customer and coworker who may be affected by access barriers. Workers with disabilities can better spot accessibility issues and drive meaningful changes, from installing ramps or lowering counters to improving signage and communication tools, when they have a clear grasp of how the ADA’s Title III governs public workplace spaces.

While Title I protects against employment discrimination, Title III supports efforts to remove structural and communication barriers in spaces open to the public. Raising accessibility concerns asserts the right to full participation and fosters broader inclusion. Effective advocacy leads to real improvements, reduces legal risks for employers, and helps make accessibility part of workplace culture. Here are two notable instances where employee advocacy led to significant changes in public accessibility:

National Federation of the Blind v. Target Corp. — In 2006, the National Federation of the Blind (NFB), along with a blind Target employee, filed a class-action lawsuit alleging that the retail giant’s website was inaccessible to blind users, in violation of the ADA’s Title III. The employee's involvement highlighted internal concerns about accessibility, emphasizing the need for inclusive digital platforms. This case set a precedent for web accessibility, demonstrating how employee advocacy can drive systemic change benefiting both staff and customers with disabilities.
Ruffa et al. v. Society for Human Resource Management (SHRM) — In 2022, three individuals, including an employee, filed a lawsuit against SHRM alleging that its professional development programs were inaccessible to people with disabilities, in violation of Title III of the ADA. The plaintiffs highlighted issues that led to SHRM implementing transcripts for podcasts, captioned video content, and sign-language interpreters at conferences.

Frequently Asked Questions (FAQ)

Does Title III cover employment accommodations?

No. Employment accommodations fall under Title I of the ADA. Title III covers access to public spaces, including customer areas in workplaces. However, if the barrier affects a public-facing area of your workplace, Title III may still apply.

Can I request changes to my workspace under ADA Title III?

Maybe. ADA Title III applies to public-facing areas of a workplace, such as entrances and restrooms used by customers. Requests for job-specific accommodations fall under Title I.

Can I use Title III to request changes to shared areas like restrooms or entrances?

Yes. If the area is open to the public—such as a lobby, entrance, restroom, or customer service counter—Title III requires accessibility, regardless of who uses the space.

What if my employer says accessibility changes are too expensive?

Employers are required to make changes unless doing so causes significant difficulty or expense. They should explore reasonable alternatives to avoid litigation.

What if my employer refuses to make changes?

If earlier requests have been ignored, you may seek assistance from advocacy groups, file a Title III complaint with the DOJ, or explore legal action. You can also contact the EEOC if the issue involves employment discrimination under Title I.

How do I know what’s considered an accessibility barrier?

Compare your workplace to the ADA Standards for Accessible Design. These guidelines include measurements and requirements for features like doorways, ramps, restrooms, and signage.

Is it enough to just make a verbal complaint?

Written requests are more effective. They create a record, clarify your concerns, and allow you to reference specific Title III requirements or suggested improvements.

Have you advocated for accessibility changes at your workplace? Share your experience or questions in the comments below. We want to hear your story!

Working Toward Access: ADA Advocacy in Public-Facing Jobs