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ADA Title I: employment rights and reasonable accommodation

ADA Title I is the part of the Americans with Disabilities Act that bans disability discrimination in employment. It applies to employers with 15 or more employees (ADA statute (42 U.S.C. 12101 et seq.), 12111(5)), and it counts a failure to make reasonable accommodations for a qualified applicant or employee as discrimination, unless the employer can show that the accommodation would be an undue hardship (ADA statute (42 U.S.C. 12101 et seq.), 12112(b)(5)(A)). A charge generally has to be filed with the EEOC within 180 calendar days of the discrimination, or 300 where a state or local agency enforces a law on the same basis (EEOC, time limits for filing a charge).

This guide summarizes the sources it cites; it is not legal advice. The official texts are the reference.

Which employers Title I covers

Under Title I, an employer is a person engaged in an industry affecting commerce who has 15 or more employees for each working day in each of 20 or more calendar weeks in the current or preceding calendar year (ADA statute (42 U.S.C. 12101 et seq.), 12111(5)). ADA.gov lists employment agencies and labor unions next to employers as covered by Title I (ADA.gov introduction to the ADA).

Who is and is not an employer under Title I.
Employer Where it stands
Private employer with 15 or more employees Covered, if it meets the 15-employee test for 20 or more calendar weeks (ADA statute (42 U.S.C. 12101 et seq.), 12111(5))
State or local government Covered, according to the EEOC (EEOC, visual disabilities in the workplace); ADA.gov lists state and local governments among Title I employers (ADA.gov introduction to the ADA)
Private employer with fewer than 15 employees Outside the definition of employer. Some state laws may apply to smaller employers (EEOC, visual disabilities in the workplace)
Federal agency The United States is not an employer under Title I (ADA statute (42 U.S.C. 12101 et seq.), 12111(5)). The EEOC says Section 501 of the Rehabilitation Act gives federal applicants and employees similar protections (EEOC, visual disabilities in the workplace)
Indian tribe, wholly owned U.S. government corporation, private membership club Not employers under Title I; the club exception is for bona fide private membership clubs exempt from tax under section 501(c), other than labor organizations (ADA statute (42 U.S.C. 12101 et seq.), 12111(5))

Title I covers the job relationship. How a government or a business has to treat the public is the subject of ADA Title II and ADA Title III. The EEOC also notes that most states have their own laws against disability discrimination in employment, and some of them may apply to smaller employers and give protections beyond the federal ones (EEOC, visual disabilities in the workplace).

Who Title I protects: a qualified individual with a disability

Title I protects a qualified individual: someone who, with or without reasonable accommodation, can perform the essential functions of the job they hold or want. The employer’s judgment about which functions are essential counts, and a written job description prepared before advertising or interviewing is evidence of them (ADA statute (42 U.S.C. 12101 et seq.), 12111(8)). The regulation defines essential functions as the fundamental job duties of the position, and says they do not include its marginal functions (29 CFR part 1630, 1630.2(n)).

A disability, under the regulation, is a physical or mental impairment that substantially limits one or more major life activities, a record of such an impairment, or being regarded as having one, and a person can rely on any one of these three prongs (29 CFR part 1630, 1630.2(g)). For blindness the regulation is direct: it should easily be concluded that blindness substantially limits seeing (29 CFR part 1630, 1630.2(j)(3)(iii)), and the EEOC says a person who is blind should easily be found to have an actual disability (EEOC, visual disabilities in the workplace).

Two rules matter for people with low vision. The effect of mitigating measures is not counted when deciding whether an impairment substantially limits a major life activity, except that the effect of ordinary eyeglasses or contact lenses is counted (29 CFR part 1630, 1630.2(j)(1)(vi)). And a person who is covered only because an employer regards them as disabled has no right to an accommodation (29 CFR part 1630, 1630.2(o)(4)).

What Title I prohibits, stage by stage

The general rule is that a covered employer may not discriminate against a qualified individual on the basis of disability in job application procedures, hiring, advancement, discharge, compensation, job training and the other terms, conditions and privileges of employment (ADA statute (42 U.S.C. 12101 et seq.), 12112(a)). The rules that matter most to a person who is blind or has low vision are the ones on tests and on medical questions.

What the statute and the regulation say at each step of getting and keeping a job.
Step What the rules say
Selection criteria and tests Standards, tests or other criteria that screen out or tend to screen out people with disabilities must be job-related for the position and consistent with business necessity (ADA statute (42 U.S.C. 12101 et seq.), 12112(b)(6)). A test must be selected and given so its results reflect the skill it measures, not the applicant’s impaired sensory, manual or speaking skills, unless those skills are what the test measures (ADA statute (42 U.S.C. 12101 et seq.), 12112(b)(7))
Uncorrected vision A standard or test based on uncorrected vision must be shown to be job-related and consistent with business necessity (29 CFR part 1630, 1630.10(b))
Before a job offer No medical examination and no questions about whether an applicant has a disability or about its nature or severity. Questions about the ability to perform job-related functions are allowed (ADA statute (42 U.S.C. 12101 et seq.), 12112(d)(2))
After an offer, before work starts A medical examination may be required if all entering employees get one regardless of disability; the information goes in separate, confidential medical files (ADA statute (42 U.S.C. 12101 et seq.), 12112(d)(3))
On the job A medical examination or a question about disability is allowed only if it is job-related and consistent with business necessity (ADA statute (42 U.S.C. 12101 et seq.), 12112(d)(4))

The EEOC adds that applicants do not have to disclose a visual disability before a job offer unless they are asking for an accommodation in the application process, such as large print or braille (EEOC, visual disabilities in the workplace). It also says that algorithmic or AI decision-making tools can screen out people with visual disabilities, and that the employer then has to provide a reasonable accommodation, such as an alternative testing format, absent undue hardship (EEOC, visual disabilities in the workplace).

Retaliation is prohibited: an employer may not discriminate against someone for opposing an unlawful practice or for making a charge, testifying or taking part in an investigation, and may not coerce or interfere with someone exercising their rights (29 CFR part 1630, 1630.12). The EEOC says this includes retaliation for requesting a reasonable accommodation (EEOC, visual disabilities in the workplace).

What a reasonable accommodation is, with examples for blind and low-vision workers

The regulation defines a reasonable accommodation as one of three kinds of change: to a job application process so a qualified applicant can be considered; to the work environment or to the way the job is usually done, so a qualified person can perform its essential functions; or to what lets an employee enjoy the same benefits and privileges of employment as similar employees without disabilities (29 CFR part 1630, 1630.2(o)(1)). The law’s own examples include making facilities readily accessible, job restructuring, modified schedules, reassignment to a vacant position, acquiring or modifying equipment, adjusting exams and training materials, and qualified readers (ADA statute (42 U.S.C. 12101 et seq.), 12111(9)).

The EEOC’s 2023 document on visual disabilities says its list is not exhaustive and gives these examples (EEOC, visual disabilities in the workplace):

Accommodations the EEOC lists for applicants and employees with visual disabilities.
Need Example the EEOC gives
Reading a screen Screen readers or text-to-speech software that turn on-screen text into speech or a braille display; screen magnification software, an external magnifier, or a larger monitor with a high-contrast theme (EEOC, visual disabilities in the workplace)
Reading print Materials in large print, braille, a recorded format or an accessible shared document; optical magnifiers, video magnifiers or CCTV (EEOC, visual disabilities in the workplace)
Applying and testing An alternative way to complete an application a screen reader cannot use; a test in a more accessible format, with a qualified reader, in an accessible setting or with more time (EEOC, visual disabilities in the workplace)
Getting around the workplace Accessible maps for navigation and evacuation, audible or tactile signs and warning surfaces, brighter or lower lights, sighted guides (EEOC, visual disabilities in the workplace)
Getting to work and staying there A guide dog in the work area; a modified start time on days the paratransit ride is late; telework beyond the usual policy; unpaid leave once paid leave is used up, in an example about guide dog training (EEOC, visual disabilities in the workplace)
Tasks that rely on sight A qualified reader or sighted assistance; changing marginal functions; reassignment to a vacant position (EEOC, visual disabilities in the workplace)
Training Individualized instruction and accessible training on assistive technology (EEOC, visual disabilities in the workplace)

Some things are not required. An employer does not have to provide personal use items, such as eyeglasses or other devices used both on and off the job, eliminate an essential function, or tolerate performance that does not meet its standards (EEOC, visual disabilities in the workplace). For the rules on guide dogs outside the workplace, see ADA service animals; for advice on finding work, see our article Jobs for Blind and Visually Impaired People: A Career Guide.

How to ask for an accommodation, and what the employer has to do

  1. Ask. There are no magic words: it is enough to tell the employer that you need an adjustment or change at work because of an impairment. A family member, friend or health professional can ask on your behalf, and you can ask at any time (EEOC, visual disabilities in the workplace). The request does not have to be in writing; an employer may confirm it in writing or ask you to fill out a form, but it cannot ignore the first request (EEOC reasonable accommodation guidance).
  2. Talk it through. To find the right accommodation, the employer may need to start an informal, interactive process with you that identifies the precise limitations and the accommodations that could overcome them (29 CFR part 1630, 1630.2(o)(3)).
  3. Documentation, only if needed. If your visual disability or your need for the accommodation is not obvious or already known, the employer may ask for reasonable documentation, but only what is sufficient to establish the disability and explain why the accommodation is needed. Asking for an entire medical record would be inappropriate (EEOC, visual disabilities in the workplace).
  4. The choice. If more than one accommodation would work, your preference gets primary consideration, but the employer may choose between effective accommodations and does not have to give the one you asked for (EEOC, visual disabilities in the workplace). An accommodation that does not work is not enough: the EEOC’s example is an employer that insists on a braille test for an applicant who is not proficient in braille, when an optically scanned version would work (EEOC, visual disabilities in the workplace).
  5. Speed. The employer should respond expeditiously and act promptly; unnecessary delays can violate the ADA (EEOC reasonable accommodation guidance).
  6. It keeps going. The duty is ongoing, and a person may need more than one accommodation over time, for example when the employer adopts new software and the assistive technology has to be updated (EEOC, visual disabilities in the workplace).

The duty applies to applicants too: in the EEOC’s example, an employer that cancels an interview because the applicant asked to bring a guide dog has violated the ADA, absent a finding of undue hardship based on specific facts (EEOC, visual disabilities in the workplace). One more rule runs the other way: a person is not required to accept an accommodation, but if they reject one that is necessary to perform the essential functions and cannot perform them as a result, they are not considered qualified (29 CFR part 1630, 1630.9(d)).

When an employer can say no: undue hardship and direct threat

The main limits on the duty to accommodate.
Limit What it means
Undue hardship An action requiring significant difficulty or expense, weighed against factors the statute lists (ADA statute (42 U.S.C. 12101 et seq.), 12111(10)). It is judged on the net cost to the employer, after outside funding and tax credits, and cannot be based on coworkers’ or customers’ fears or prejudices or on an effect on morale (EEOC reasonable accommodation guidance)
Direct threat A significant risk of substantial harm to the health or safety of the individual or others that cannot be eliminated or reduced by reasonable accommodation, judged by an individualized assessment of present ability to safely perform the essential functions, looking at the duration, nature and severity, likelihood and imminence of the harm (29 CFR part 1630, 1630.2(r)). The EEOC says an employer may exclude a person with a vision impairment from a job for safety reasons only when they pose a direct threat (EEOC, visual disabilities in the workplace)
Job-related standards Selection criteria and tests that screen people out can be defended if shown to be job-related and consistent with business necessity, and the performance cannot be achieved with reasonable accommodation (29 CFR part 1630, 1630.15(b))
Conflict with another Federal law A challenged action required or necessitated by another Federal law or regulation can be a defense (29 CFR part 1630, 1630.15(e))

An employer also may not justify an adverse action by saying an employee performed poorly when the poor performance was caused by an unlawful failure to accommodate (EEOC, visual disabilities in the workplace).

How Title I is enforced: the EEOC charge

The ADA gives people who allege disability discrimination in employment the powers, remedies and procedures set out in sections 2000e-4, 2000e-5, 2000e-6, 2000e-8 and 2000e-9 of Title 42 of the U.S. Code, which are the ones Title VII of the Civil Rights Act of 1964 provides (ADA statute (42 U.S.C. 12101 et seq.), 12117(a)). In practice, the first step is a charge of discrimination with the EEOC.

Time limits for the first step.
Who Time limit
Applicants and employees of private employers and of state or local governments Generally 180 calendar days from the day the discrimination took place; 300 calendar days if a state or local agency enforces a law prohibiting employment discrimination on the same basis (EEOC, time limits for filing a charge)
Federal employees and applicants A different process: generally contact an agency EEO Counselor within 45 days, a time limit that can be extended in some circumstances (EEOC, time limits for filing a charge)

The deadline generally does not stop while you try an internal grievance, a union grievance, arbitration or mediation. Weekends and holidays count, except that a deadline falling on one moves to the next business day, and each discriminatory event generally has its own deadline; for harassment, it runs from the last incident (EEOC, time limits for filing a charge).

A charge is a signed statement asserting that an organization engaged in employment discrimination. Under the laws the EEOC enforces, except the Equal Pay Act, you have to file a charge before you can file a lawsuit (EEOC, how to file a charge). The EEOC asks you to start in its Public Portal, which leads to a telephone, video or in-person interview at one of its 53 offices; you can also visit an office, and you can call 1-800-669-4000 to start the process, although the EEOC does not take charges over the phone. If a state or local agency also enforces a law, a charge filed with either agency can be filed with both (EEOC, how to file a charge).

If discrimination is found, the remedy can include being placed in the job and back pay and benefits, an order to stop discriminatory practices, and attorney’s fees, expert witness fees and court costs. For intentional discrimination based on disability, compensatory and punitive damages may also be awarded, within limits that depend on the size of the employer (EEOC, remedies for employment discrimination):

Limit on compensatory and punitive damages, by employer size.
Employer size Limit
15 to 100 employees $50,000 (EEOC, remedies for employment discrimination)
101 to 200 employees $100,000 (EEOC, remedies for employment discrimination)
201 to 500 employees $200,000 (EEOC, remedies for employment discrimination)
More than 500 employees $300,000 (EEOC, remedies for employment discrimination)

For help choosing an accommodation before there is a dispute, the EEOC points to the Job Accommodation Network, which it describes as a free, federally funded, confidential service (EEOC, visual disabilities in the workplace).

Title I at work, Braillito Maps on the way there

Title I decides what an employer owes a worker. It does not tell a person walking to an interview whether the entrance has a ramp or a step, whether the door is wide enough or whether the restroom is accessible. Braillito Maps is a free community map that answers ten questions about each place: step-free entrance or ramp, wide doorway, accessible restroom, accessible parking, tactile paving, braille signage, braille menu, audible signals, guide dogs welcome and a quiet environment.

Each question is answered yes, no or no data until someone knows. A yes means that someone who went reported it; it is not an assessment of whether a workplace meets the ADA. The score of a place is the number of yes answers out of ten, always shown with its number, never by color alone. If a place is missing, add it with its answers; if what a place says is wrong, report it. Meet Braillito Maps.

Frequently asked questions

Is blindness a disability under ADA Title I?

Yes. The regulation says it should easily be concluded that blindness substantially limits seeing (29 CFR part 1630, 1630.2(j)(3)(iii)). Title I protects a person who is also qualified, meaning able to perform the essential functions of the job with or without reasonable accommodation (ADA statute (42 U.S.C. 12101 et seq.), 12111(8)).

Does an employer have to give me the exact accommodation I ask for?

No. Your preference gets primary consideration, but the employer may choose between accommodations that are effective (EEOC, visual disabilities in the workplace). In the EEOC’s example, a braille test was not an effective accommodation for an applicant who was not proficient in braille, so the employer had to provide an optically scanned version unless that was an undue hardship (EEOC, visual disabilities in the workplace).

Do I have to tell an employer about my vision loss when I apply?

No, unless you are asking for an accommodation in the application process, such as large print or braille (EEOC, visual disabilities in the workplace). Before a job offer, the employer may not ask whether you have a disability or about its nature or severity; it may ask about your ability to perform job-related functions (ADA statute (42 U.S.C. 12101 et seq.), 12112(d)(2)).

Can I bring my guide dog to work?

Allowing a guide dog in the work area is one of the accommodations the EEOC lists, and in its example an employer that refused to let an applicant bring a guide dog to an interview violated the ADA, absent undue hardship (EEOC, visual disabilities in the workplace). Who counts as a service animal in public places is a different question; see ADA service animals.

How long do I have to file a discrimination charge?

Generally 180 calendar days from the discrimination, or 300 if a state or local agency enforces a law on the same basis. Federal employees generally have to contact an agency EEO Counselor within 45 days (EEOC, time limits for filing a charge).

What counts as an undue hardship?

Significant difficulty or expense, weighed against factors the statute lists (ADA statute (42 U.S.C. 12101 et seq.), 12111(10)). The EEOC’s guidance says it is based on the net cost to the employer, and cannot be based on coworkers’ or customers’ fears or prejudices or on morale (EEOC reasonable accommodation guidance).

Can my employer retaliate if I ask for an accommodation?

No. The EEOC says it is unlawful to retaliate against someone for requesting a reasonable accommodation or to interfere with the exercise of ADA rights (EEOC, visual disabilities in the workplace).

Does Title I apply to a company with fewer than 15 employees?

Not under the federal definition of employer (ADA statute (42 U.S.C. 12101 et seq.), 12111(5)). The EEOC notes that some state laws may apply to smaller employers (EEOC, visual disabilities in the workplace).

More accessibility guides

  • Americans with Disabilities Act: who counts as having a disability, what each of the five titles covers, who enforces it and what it leaves to other laws.
  • ADA Title II: what state and local governments have to make accessible: existing buildings, new construction, streets and curb ramps, parks, programs and the 2024 web rule.
  • ADA Title III: who Title III covers, readily achievable barrier removal, new buildings, alterations and the 20 percent rule, and how it is enforced.
  • Section 504: who has to follow it, how it differs from the ADA, what its regulations ask of schools and public programs, how complaints work and what HHS has changed for the web.
  • ADA service animals: what counts as one, the two questions staff may ask, and when one can be asked to leave.
  • ADA compliance: a checklist for small businesses, with the 2010 Standards section behind each item.
  • Accessibility laws by country: the ADA, the UK Equality Act, the Accessible Canada Act, Australia’s DDA and the EU rules, and what each covers.
  • Equality Act reasonable adjustments: the three requirements of section 20, why the duty is anticipatory, who pays, and what a shop, restaurant or service can change in its building.
  • All accessibility guides

Sources

Every figure in this guide comes from one of these official texts, which we read on November 2, 2026.

  1. Regulations To Implement the Equal Employment Provisions of the Americans With Disabilities Act (29 CFR part 1630). U.S. Equal Employment Opportunity Commission, in the Electronic Code of Federal Regulations, current text, up to date as of October 29, 2026; read November 2, 2026.
  2. Americans with Disabilities Act of 1990, As Amended (42 U.S.C. 12101 et seq.). U.S. Department of Justice (ADA.gov), mirroring the U.S. Code, including the ADA Amendments Act of 2008; read November 1, 2026.
  3. Visual Disabilities in the Workplace and the Americans with Disabilities Act. U.S. Equal Employment Opportunity Commission, issued July 26, 2023; read November 2, 2026.
  4. Time Limits For Filing A Charge. U.S. Equal Employment Opportunity Commission, read November 2, 2026.
  5. Enforcement Guidance on Reasonable Accommodation and Undue Hardship Under the Americans with Disabilities Act. U.S. Equal Employment Opportunity Commission, issued October 17, 2002; read November 2, 2026.
  6. Introduction to the Americans with Disabilities Act. U.S. Department of Justice (ADA.gov), read October 2026.
  7. How to File a Charge of Employment Discrimination. U.S. Equal Employment Opportunity Commission, read November 2, 2026.
  8. Remedies for Employment Discrimination. U.S. Equal Employment Opportunity Commission, read November 2, 2026.

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