16 Mar Church ADA Compliance in Texas: What Houses of Worship Are and Aren’t Required to Do
Churches in Texas occupy a unique legal position. The federal Americans with Disabilities Act does not apply to them. But Texas state law does, under certain conditions. And that distinction catches a lot of church leaders by surprise.
This guide breaks down exactly what your house of worship is required to do under Texas law, what you are not required to do, and what options exist when you are ready to make your building more welcoming to everyone.
The Federal ADA and Churches: A Complete Exemption
Under Title III of the Americans with Disabilities Act, religious entities are completely exempt. All of their facilities, programs, and activities, whether they are religious or secular in nature, are exempt. That includes churches, mosques, synagogues, temples, and any facility controlled by a religious organization, regardless of whether it is open to the general public.
The equal access exemption for religious institutions has been upheld by courts on the basis that requiring religious entities to comply with the ADA and allowing the government to initiate enforcement proceedings against religious entities would amount to an impermissible government interference with religion.
So are Texas churches completely off the hook? Not exactly.
Where Texas Law Steps In: The Texas Accessibility Standards
Here is where many church leaders get caught off guard.
Even though the federal ADA does not apply to churches, the Texas Accessibility Standards (TAS) do. TAS is administered by the Texas Department of Licensing and Regulation (TDLR) under Texas Government Code, Chapter 469. The program is called the Elimination of Architectural Barriers.
Under 16 Texas Administrative Code, buildings or facilities of a religious organization are subject to the Act, except for areas exempted under specific provisions. TAS does not apply to places primarily used for religious rituals within a building or facility of a religious organization, but the other parts of the building must still maintain compliance.
In plain language, here is what that means:
Exempt under TAS:
- The main sanctuary or worship hall where religious services are held
- Other spaces used primarily for religious ritual
NOT exempt under TAS (when building or renovating):
- Lobbies and common areas
- Restrooms
- Parking lots
- Fellowship halls
- Classrooms and meeting rooms
- Offices
- Kitchens and dining areas
This compliance requirement is triggered by construction activity. Plans for new construction or substantial renovation totaling $50,000 or more must be submitted to TDLR not later than the 20th day after the professional issues the plans, and a local governmental entity cannot issue a building construction permit without proof that the building owner has filed a plan with TDLR.
Two More Things That Can Trigger Compliance
Beyond TAS, there are two other situations worth knowing about.
Federal funding. Under the Rehabilitation Act, any facility that receives federal funding is prohibited from discriminating on the basis of disability, with no exemption for religious entities. If a church receives federal funding for a program or activity, that program or activity must be physically accessible to people with disabilities.
Employment. If a religious entity has at least 15 employees, it is covered as an employer by Title I of the ADA and may not discriminate against qualified applicants and employees with disabilities. This is separate from the physical accessibility question and applies regardless of TAS.
What This Means Practically for North Texas Churches
If your church in the Dallas-Fort Worth area is building a new facility, expanding your campus, or renovating a fellowship hall, restrooms, or classrooms, you are likely subject to TAS. That means accessible routes, accessible parking, compliant restrooms, and in many cases, vertical access between levels.
Multi-story church buildings are where this gets particularly important. If your new building or renovation includes multiple floors, you will need a code-compliant way for people with mobility limitations to access all non-exempt spaces.
A vertical platform lift is often the right solution for split-level entries or raised platforms. A LU/LA elevator is frequently the best fit for multi-story buildings because it provides full elevator-style access at a lower cost than a commercial elevator. For buildings with existing staircases, an inclined platform lift can provide access without requiring major structural changes.
What If Your Church Wants to Improve Accessibility Voluntarily?
Many Texas churches choose to go beyond what the law requires. That is a smart decision for two reasons.
First, it makes your congregation more welcoming. Roughly 12 percent of U.S. adults have a mobility disability, and in an aging DFW metro, that number is growing. A church that is difficult to navigate quietly excludes people who want to be there.
Second, voluntary improvements now reduce the cost of required upgrades later. Making incremental changes during normal maintenance cycles is far less expensive than an emergency compliance retrofit before a building permit is issued.
For a broader look at how TAS compliance works for organizations in North Texas, see our TAS compliance guide for schools and public buildings.
Frequently Asked Questions: Church ADA Compliance in Texas
Does the ADA apply to churches in Texas? No. Religious organizations are fully exempt from Title III of the ADA. The exemption covers all facilities and programs controlled by the religious organization, even those open to the general public.
Does Texas state law require churches to be accessible? Yes, under certain conditions. The Texas Accessibility Standards apply to new construction and renovations estimated at $50,000 or more at religious organization facilities. The main worship space is exempt, but common areas like lobbies, restrooms, classrooms, and parking must meet TAS requirements.
What if our church receives government grants? If your church receives federal funding, Section 504 of the Rehabilitation Act applies to the funded programs and activities. There is no religious exemption under Section 504.
Do we need to file anything with the state before renovating? If your renovation is estimated at $50,000 or more, your design professional is required to file plans with TDLR within 20 days of issuing them. A local building permit cannot be issued without proof of that filing.
Ready to Make Your Church More Accessible?
Whether you are building new, renovating, or simply trying to make your current building work better for every member of your congregation, we can help.
At Lift-Aids, we have been helping North Texas churches, schools, and organizations navigate accessibility since 1968. We are a third-generation, family-owned, and women-owned business based in Euless, Texas. As a fully licensed TDLR Elevator Contractor, we bring certified expertise to every project, not general contractor guesswork.
We serve houses of worship throughout the Dallas-Fort Worth Metroplex and across North Texas. We will assess your building, walk you through your options honestly, and tell you exactly what is required and what it will cost.
Request a free estimate today. We will help you make your church accessible to everyone who wants to be there.