ADA Requirements for Retail and Restaurant Buildouts in Illinois

By Sam Bader, Horizon Construction Team LLC | 20+ years building retail, restaurant, and franchise projects across Chicagoland | Published September 21, 2026

Quick Answer

Every new retail store and restaurant in Illinois must meet three sets of accessibility rules: the federal ADA, the Illinois Accessibility Code, and the local building code. In Chicago, that local code is Chapter 14B-11, and the city enforces whichever rule is stricter. For new construction, the whole space must comply. For a buildout in an existing space, the area you change must comply, and you may need to spend up to 20 percent of that cost fixing the path to it, including the entrance and restrooms. The items that fail inspection most often are restrooms, entrance doors, counter heights, and parking.

Accessibility is not a finish item. It shapes your floor plan from day one.

Where the restroom goes. How wide the aisles are. Where the counter sits. Whether the front door works at all. These are layout decisions. Get them wrong on paper and you pay for them twice: once to build it, and again to tear it out when the inspector says no.

This guide walks through what Illinois retail and restaurant owners actually need to know before a buildout starts. It covers the rules, the numbers, and the mistakes that cost the most money.

The Three Layers of Accessibility Rules in Illinois

Most owners think “ADA” is one rule. In Illinois, it is three.

1. The federal ADA (2010 ADA Standards for Accessible Design). This is the national baseline. It is a civil rights law. It applies to every business open to the public, and it can be enforced through lawsuits, not just inspections.

2. The Illinois Accessibility Code (IAC). Illinois updated its code in 2018 to line up more closely with the 2010 ADA Standards. But in some areas, Illinois still goes further. Parking is a good example, and we cover it below.

3. Your local building code. In Chicago, accessibility is covered by Chapter 14B-11 of the Chicago Building Code. The city applied it to permit applications starting December 1, 2019. Chicago drafted it to be at least as strict as the Illinois code, and the Department of Buildings enforces the stricter rule when the two differ. Suburbs like Naperville, Schaumburg, and Orland Park enforce the Illinois code along with the building code each village has adopted.

What this means for you: Passing a permit review does not protect you from an ADA lawsuit. A building inspector checks local code. The ADA is enforced separately. Your plans need to satisfy all three.

New Construction vs Buildouts in Existing Spaces

The rules change based on what you are building.

New construction

A ground-up building must be fully accessible. No shortcuts. This covers the site, parking, entrances, every public area, and restrooms. If you are building a new strip mall or shopping plaza, accessibility is designed into the site plan from the start.

Alterations and tenant buildouts

Most retail and restaurant projects are buildouts inside an existing space. Here, two rules apply:

• The area you alter must comply with current standards.
• The path of travel to that area must be made accessible, up to a cost limit.

That cost limit is called the 20 percent rule.

The 20 Percent Rule, Explained Simply

When you alter a “primary function area,” you must also make the path of travel to it accessible. A primary function area is where the main business happens. For a store, that is the sales floor. For a restaurant, it is the dining room and service counter.

The path of travel includes:

• The route from parking and the sidewalk to the entrance
• The entrance itself
• The route inside to the altered area
• The restrooms, drinking fountains, and phones that serve that area

Under federal rules, you are not required to spend more than 20 percent of your alteration cost on path of travel upgrades. But you must spend up to that amount if the path is not already accessible.

Example: You spend $300,000 renovating a restaurant dining room. The existing restrooms are not accessible, and there is a step at the front door. You may need to spend up to $60,000 more on those fixes.

If the fixes cost more than 20 percent, you do not get a pass. You must still spend up to the 20 percent limit, in this order of priority:

1. An accessible entrance
2. An accessible route to the altered area
3. At least one accessible restroom for each sex, or a single-user restroom
4. Accessible phones
5. Accessible drinking fountains
6. Other items like parking and storage

Budget tip: Owners often forget this rule until plan review. By then, the budget is set. Build it into your numbers before you sign a lease. Our commercial lease build-out checklist covers what to check first, and our guide to the hidden costs of retail construction shows where else budgets go wrong.

What if you are not renovating at all?

Existing businesses still have a duty under the ADA. They must remove barriers when it is “readily achievable,” meaning it can be done without much difficulty or expense. Adding a grab bar, moving a display rack, or installing a portable ramp are common examples. This duty is ongoing, even with no construction planned.

Parking: Where Illinois Is Stricter Than the ADA

Parking is one of the clearest places where Illinois rules differ from the federal baseline.

Illinois parking space size: Each accessible space must be 16 feet wide total, including the access aisle. You can build it one of two ways:

• An 8-foot space with an 8-foot access aisle, or
• An 11-foot space with a 5-foot access aisle

Markings: Access aisles must have diagonal striping in yellow pavement paint.

Slope: Spaces and aisles must be nearly level, with slopes no steeper than 1:50 (2 percent) in any direction.

Signs: Illinois requires a specific R7-8 “Reserved Parking” sign plus a fine plate, mounted on a permanent post at least 5 feet above the pavement. The post goes in the center of the space, no more than 5 feet from the front of it.

How many spaces: The required count scales with lot size.

Under the ADA, at least 1 of every 6 accessible spaces must be van accessible.

Location: Accessible spaces go on the shortest accessible route to an accessible entrance. A curb ramp can never sit inside the striped access aisle.

For multi-tenant centers, parking and site work usually fall on the landlord. But if your buildout triggers path of travel work, parking can end up in your scope. Clarify this in your lease. Our post on retail site development covers how parking ratios shape a site plan.

Entrances and Doors

The front door is where most accessibility problems start. It is also the first thing a customer, inspector, or attorney notices.

Key requirements:

• Clear width: At least 32 inches of clear opening when the door is open 90 degrees.
• Thresholds: No more than 1/2 inch high, and beveled if over 1/4 inch.
• Hardware: Handles must work without tight grasping or twisting. Lever handles and push bars work. Round knobs do not. Mount hardware between 34 and 48 inches above the floor.
• Clear space around the door: You need level floor space on both sides, with extra room on the pull side next to the latch. This is called maneuvering clearance. It is often lost when a vestibule or display is squeezed too close to the door.
• Opening force: Interior doors can require no more than 5 pounds of force to open. Chicago also sets a limit of 8.5 pounds for exterior hinged doors, which the federal ADA does not cover.

Older storefronts: Many older Chicago retail spaces have a step at the entry. Fixing it may mean a ramp, a sloped walk, or lowering the entry slab. This can be expensive. Find out before you sign. It is one of the biggest reasons we tell clients to walk a space with a contractor first. Our retail renovation team handles storefront entry upgrades often.

Accessible Routes Inside the Space

An accessible route is a clear path a wheelchair user can travel. It must connect the entrance to every public area.

Key requirements:

• Width: At least 36 inches clear. It can narrow to 32 inches for short stretches of 24 inches or less.
• Turning space: A 60-inch circle or a T-shaped space where a wheelchair needs to turn around.
• Slope: Any walking surface steeper than 1:20 counts as a ramp and must meet ramp rules.
• Cross slope: No steeper than 1:48.
• Floor surfaces: Firm, stable, and slip resistant. Carpet must be tightly secured with a low pile.

Ramps:

• Maximum slope of 1:12 (1 inch of rise for every 12 inches of length)
• No more than 30 inches of rise per run
• Handrails on both sides when the rise is over 6 inches
• Level landings at the top and bottom, at least 60 inches long

Design note: Ramps eat floor space fast. A 30-inch rise needs a 30-foot ramp run, plus landings. In a small storefront, that can take out a dining section or a full aisle of merchandise. Plan level changes early.

ADA Requirements for Retail Stores

Sales and service counters

At least one portion of each type of counter must be accessible. That portion must be:

• No higher than 36 inches above the floor
• At least 36 inches long
• Located on an accessible route

This applies to checkout counters, jewelry cases, pharmacy counters, and customer service desks. A 42-inch high counter across the entire front is one of the most common plan review failures we see in retail design.

Aisles and displays

Aisles along the accessible route must stay at least 36 inches clear. The problem is rarely the plan. It is the display fixtures, sale bins, and seasonal stock that end up in the aisle after opening. Design aisles with some extra room so staff do not squeeze them later.

Self-service shelving

At least one of each type of self-service shelf must be on an accessible route. Reach ranges are not required for all shelving, but keep the most important items within easy reach where you can.

Fitting rooms

Where fitting rooms are provided, at least 5 percent (and no fewer than one) of each type must be accessible. An accessible fitting room needs a turning space, a bench of the right size and height, and coat hooks within reach.

Reach ranges

Controls, card readers, and items a customer must use should be within 15 to 48 inches above the floor when there is no obstruction.

Planning a store? See our retail shop construction services.

ADA Requirements for Restaurants and Cafes

Restaurants carry more accessibility items than almost any other retail use. Seating, counters, restrooms, and outdoor areas all have their own rules.

Dining tables and seating

At least 5 percent of seating spaces and standing spaces at dining surfaces must be accessible. These tables must:

• Have a top between 28 and 34 inches above the floor
• Have knee clearance at least 27 inches high, 30 inches wide, and 19 inches deep
• Be spread across the different seating areas and types, not grouped in one corner

Common mistake: Pedestal tables with a center base often block knee space. Four-leg tables or wide-base pedestals usually work better. Choose furniture before finishes are locked.

Booths and high-tops

If most of your seating is booths or high-top tables, you still need accessible seating in the same area. You cannot put every wheelchair user at one lowered table near the kitchen door.

Bars and counters

If you serve food or drinks at a bar that is higher than 34 inches, you need an accessible portion of the bar, or accessible dining in the same area. The accessible portion must be at least 60 inches long and between 28 and 34 inches high.

Raised and sunken dining areas

Split-level dining rooms look great. They also create accessibility problems. In most cases, raised or sunken dining areas need an accessible route to them. Before you design a raised platform, talk to your architect about whether it creates a ramp or lift requirement.

Self-service stations

Condiment stations, drink fountains, utensil stands, and self-serve counters must be within reach and on an accessible route. This matters for fast casual and cafe buildouts, where most service is at the counter.

Ordering counters and queue lines

The order and pickup counter must have an accessible section. Queue lines formed by rails or stanchions must be wide enough for a wheelchair and have room to turn at the end.

Outdoor patios

Outdoor dining areas count as dining space. The patio needs an accessible route from the restaurant or sidewalk, and accessible seating that matches the 5 percent rule.

Kitchens and employee areas

Employee-only work areas have lighter rules. In general, a person using a wheelchair must be able to approach, enter, and exit the work area. Full access to every kitchen station is not required under the standard. This gives you more design freedom in back-of-house.

For full restaurant builds, see our restaurant and cafe construction services.

Restrooms: The Most Common Failure Point

Restrooms cause more plan review comments and field corrections than any other room. The space is small, the rules are exact, and a few inches matter.

Room layout:

• A 60-inch turning space inside the room
• The door cannot swing into the clear space needed at any fixture, in most cases
• Enough clear floor space in front of the toilet, sink, and any urinal

Toilet:

• Centerline 16 to 18 inches from the side wall
• Seat height 17 to 19 inches above the floor
• Flush control on the open side of the toilet

Grab bars:

• Mounted 33 to 36 inches above the floor
• Side wall bar at least 42 inches long
• Rear wall bar at least 36 inches long
• Walls must have blocking behind them. Plan blocking before drywall goes up. Adding it later means opening finished walls.

Sink:

• Rim no higher than 34 inches
• Knee and toe clearance underneath
• Exposed pipes under the sink must be insulated or covered

Accessories:

• Mirror bottom edge no higher than 40 inches when mounted over a sink
• Soap, paper towel dispensers, and hand dryers within reach
• Coat hooks within reach

Design tip: Single-user restrooms are often easier to make fully accessible in a small restaurant or shop. They can also save floor space compared to two multi-stall rooms. Ask your architect to compare both layouts early.

Signage and Alarms

Room signs: Permanent room signs, like restroom signs, need raised letters and Braille. They are mounted on the latch side of the door, with the raised characters between 48 and 60 inches above the floor.

Directional signs: If some entrances or restrooms are not accessible, signs must point to the ones that are.

Fire alarms: Where a fire alarm system is required, visible alarms (strobes) are required in public and common use areas, including restrooms. Coordinate this with your fire alarm contractor during design.

How the Permit and Inspection Process Handles Accessibility

In Chicago and most suburbs, accessibility is reviewed at two points.

1. Plan review. Your architect’s drawings must show accessible routes, door clearances, counter heights, restroom layouts, seating counts, and parking. Missing details get flagged here. Each round of comments can add weeks to your permit timeline.

2. Field inspection. The inspector checks the built work against the plans. Grab bar heights, door hardware, thresholds, mirror heights, and counter heights are easy to measure. Small field errors are one of the most common reasons a final inspection fails.

Our advice: Walk the space with your contractor at framing, before drywall. That is the cheapest point to catch a door that is 2 inches too narrow or a missing grab bar backer.

The Most Expensive Accessibility Mistakes

These are the issues that cost owners the most time and money:

1. Signing a lease without checking the entrance. A step at the door can turn into a major cost.
2. Ignoring the 20 percent rule in the budget. It shows up at plan review and blows the budget.
3. Designing restrooms too tight. A few missing inches can mean moving walls and plumbing.
4. Forgetting grab bar blocking. Fixing it means opening finished walls.
5. High counters with no low section. A common plan review comment in both retail and restaurants.
6. Choosing furniture last. Tables with no knee clearance can fail the seating count.
7. Raised dining platforms with no access plan. A late ramp or lift can wipe out seats.
8. Letting displays block aisles after opening. A compliant plan can become a lawsuit problem.
9. Assuming the landlord handled it. Many older spaces were never brought up to code. Confirm in writing.
10. Treating franchise prototypes as automatically compliant. National brand plans still need to meet Illinois and local rules. Our franchise construction team adapts prototype plans for local code.

Tax Breaks for Accessibility Work

Two federal tax incentives can help offset the cost of accessibility upgrades:

• Disabled Access Credit (IRS Form 8826): A tax credit for eligible small businesses that spend money on accessibility. The credit can be up to $5,000 per year.
• Architectural Barrier Removal Deduction (Section 190): A deduction of up to $15,000 per year for removing barriers in existing facilities.

Eligibility rules apply, and new construction usually does not qualify. Talk to your accountant before you budget for these.

ADA Buildout Checklist for Illinois Retail and Restaurant Owners

Use this before you sign a lease and again before you submit for permit.

Plan Accessibility Before You Design Anything Else

Accessibility works best when it is built into the first sketch. When it is added at the end, it costs more and takes space away from the things that make you money: seats, shelves, and sales floor.

If you are still choosing a space, compare the cost of fixing an older unit against a newer one. Our guide on retail build-out vs ground-up construction walks through that choice. For a look at what is being built across the region right now, see Chicago Retail Construction 2026.

Frequently Asked Questions

Does the ADA apply to small restaurants and shops in Illinois?

Yes. The ADA applies to businesses open to the public, no matter their size. Illinois and local building codes also apply to new construction and buildouts. Small size does not create an exemption.

What is the 20 percent rule for ADA alterations?

When you alter the main area of a business, you must also make the path to it accessible, including the entrance and restrooms. You are not required to spend more than 20 percent of the alteration cost on those path of travel upgrades, but you must spend up to that amount if the path is not already accessible.

How wide does an accessible parking space need to be in Illinois?

Each accessible parking space in Illinois must be 16 feet wide total, including the access aisle. It can be an 8-foot space with an 8-foot aisle, or an 11-foot space with a 5-foot aisle. Aisles must have diagonal yellow striping.

How many accessible tables does a restaurant need?

At least 5 percent of seating and standing spaces at dining surfaces must be accessible. Accessible tables must be 28 to 34 inches high with proper knee clearance, and they must be spread across the different seating areas.

How high can a checkout counter be under the ADA?

At least one section of each type of sales or service counter must be no higher than 36 inches above the floor and at least 36 inches long. The rest of the counter can be higher.

Does passing a Chicago building inspection mean my space is ADA compliant?

Not always. A building inspection checks local code. The ADA is a federal civil rights law that is enforced separately, including through lawsuits. Your space should be designed to meet the ADA, the Illinois Accessibility Code, and local code together.

Do existing businesses need to make ADA upgrades if they are not renovating?

Yes, in many cases. Existing businesses must remove barriers when it is readily achievable, meaning it can be done without much difficulty or expense. Examples include adding grab bars, moving displays out of aisles, or installing a small ramp.

Build It Right the First Time

Horizon Construction Team has built retail, restaurant, and franchise projects across Chicago and the suburbs for more than 20 years. We review accessibility with your architect before design is locked, flag path of travel costs before you commit, and check the work in the field before the inspector does.

Call (773) 858-3214 or request a free quote to talk through your buildout.