Accessible Hotel Guest Rooms on US Projects: What Sections 224 and 806 of the ADA Standards Mean for Beds, Turning Space and Room Layouts
Room counts, bed clear floor space and turning space, read from the text of sections 224, 806, 304 and 305
A hotel FF&E package is bought against a guest room schedule, and the schedule carries a line that decides how the furniture is laid out: which rooms are the accessible ones. For a project in the United States, the room counts sit in section 224 of the ADA Accessibility Standards and the room requirements in section 806. Neither section names a nightstand, a desk or a luggage bench. What they set is floor space and the number of rooms, and those two things decide where the bed, the nightstands, the desk and the wardrobe can go.
This article reads sections 224 and 806, and the dimensions they borrow from sections 304 and 305, as published on the US Access Board website, which we read on 24 October 2026. FBM Furniture works with companies only: Developers · General Contractors · Builders · Commercial Project Owners · Interior Design & Construction Companies · FF&E Solution Providers. It sets out what the text says and does not decide whether any room or piece of furniture complies. We did not read sections 804, 225 or 603 to 610, the Department of Justice regulation itself, or any state or local code, which can add to or replace these requirements; your architect or accessibility consultant confirms what applies to the project. Our earlier notes read sections 226 and 902 for dining surfaces and sections 227.3 and 904.4 for service counters.
How many guest rooms need mobility features
Section 224.2 says that in transient lodging facilities, guest rooms with mobility features complying with 806.2 shall be provided in accordance with Table 224.2. The table is driven by the total number of guest rooms provided.
| Total number of guest rooms provided | Minimum rooms with mobility features, without roll-in showers | Minimum rooms with roll-in showers | Total required |
|---|---|---|---|
| 1 to 25 | 1 | 0 | 1 |
| 26 to 50 | 2 | 0 | 2 |
| 51 to 75 | 3 | 1 | 4 |
| 76 to 100 | 4 | 1 | 5 |
| 101 to 150 | 5 | 2 | 7 |
| 151 to 200 | 6 | 2 | 8 |
| 201 to 300 | 7 | 3 | 10 |
| 301 to 400 | 8 | 4 | 12 |
| 401 to 500 | 9 | 4 | 13 |
| 501 to 1000 | 2 percent of total | 1 percent of total | 3 percent of total |
| 1001 and over | 20, plus 1 for each 100, or fraction thereof, over 1000 | 10, plus 1 for each 100, or fraction thereof, over 1000 | 30, plus 2 for each 100, or fraction thereof, over 1000 |
Reading the table with a hypothetical 120-room hotel: the row for 101 to 150 rooms requires 5 rooms without roll-in showers and 2 with roll-in showers, 7 in total. The count is a minimum for the whole facility; section 224.1.1 adds that where guest rooms are altered or added, section 224 applies only to the rooms altered or added until the number of rooms complies with the minimum for new construction.
A note on the page quotes the Department of Justice rule that facilities on a common site under the same permit application that each have 50 or fewer guest rooms may be combined for the purpose of determining the required number of accessible rooms and type of accessible bathing facility, while facilities with more than 50 guest rooms are treated separately. We read only the note as printed on the Access Board page, not the regulation itself.
Beds, communication features and dispersion
Three further provisions in section 224 shape a schedule. Section 224.3 states: “In guest rooms having more than 25 beds, 5 percent minimum of the beds shall have clear floor space complying with 806.2.3.” Section 224.4 sets a second count, for guest rooms with communication features complying with 806.3:
| Total number of guest rooms provided | Minimum rooms with communication features |
|---|---|
| 2 to 25 | 2 |
| 26 to 50 | 4 |
| 51 to 75 | 7 |
| 76 to 100 | 9 |
| 101 to 150 | 12 |
| 151 to 200 | 14 |
| 201 to 300 | 17 |
| 301 to 400 | 20 |
| 401 to 500 | 22 |
| 501 to 1000 | 5 percent of total |
| 1001 and over | 50, plus 3 for each 100 over 1000 |
Section 224.5 requires the rooms with mobility features and the rooms with communication features to be dispersed among the various classes of guest rooms and to offer choices of room type, number of beds and other amenities comparable to the choices offered to other guests. Where the minimum number is too small for complete dispersion, the text gives a priority order: guest room type, number of beds, and amenities. At least one room required to have mobility features must also have communication features, and not more than 10 percent of the rooms with mobility features may be used to satisfy the minimum number of rooms with communication features.
For a furniture package, dispersion has a plain consequence: the accessible rooms are not all of one type. If the hotel has king rooms, twin rooms and suites, the accessible rooms are spread across them, so each of those layouts may need its own accessible variant in the schedule.
What section 806.2 requires inside the room
Section 806.1 says that guest rooms required to provide mobility features shall comply with 806.2 and guest rooms required to provide communication features with 806.3. The Advisory to 806.2 adds that the section does not include requirements common to all accessible spaces; for example, closets in guest rooms must comply with the applicable provisions for storage in the scoping sections. The table sets out section 806.2 as written.
| Section | What the text requires inside a guest room with mobility features |
|---|---|
| 806.2.1 | Living and dining areas shall be accessible. |
| 806.2.2 | Exterior spaces serving the guest room, including patios, terraces and balconies, shall be accessible. |
| 806.2.3 | At least one sleeping area shall provide a clear floor space complying with 305 on both sides of a bed, positioned for parallel approach to the side of the bed. Exception: where a single clear floor space complying with 305, positioned for parallel approach, is provided between two beds, a clear floor or ground space is not required on both sides of a bed. |
| 806.2.4 | At least one bathroom provided as part of the guest room shall comply with 603; no fewer than one water closet, one lavatory and one bathtub or shower shall comply with 603 through 610; required roll-in shower compartments shall comply with 608.2.2 or 608.2.3. |
| 806.2.4.1 | If vanity counter top space is provided in non-accessible guest toilet or bathing rooms, comparable vanity counter top space, in terms of size and proximity to the lavatory, shall also be provided in accessible ones. |
| 806.2.5 | Kitchens and kitchenettes shall comply with 804. |
| 806.2.6 | Turning space complying with 304 shall be provided within the guest room. |
Of these provisions, three bear directly on furniture: 806.2.3 on the clear floor space at the bed, 806.2.6 on turning space, and 806.2.4.1 on vanity counter top space, which the text describes as comparable in size and proximity to the lavatory. The Advisory to 806.2.4.1 states the intent: to ensure that accessible guest rooms are provided with comparable vanity counter top space.
Planning accessible guest rooms for a United States hotel?
Send your guest room schedule and drawings. Our team will review them and get back to you.
The dimensions behind the floor space and turning space
Sections 806.2.3 and 806.2.6 do not give dimensions themselves. They point to sections 305 and 304, which do. The table collects what those sections state.
| Space | Dimension stated in the text | Section |
|---|---|---|
| Clear floor or ground space | 30 inches (760 mm) minimum by 48 inches (1220 mm) minimum | 305.3 |
| Position of that space | Unless otherwise specified, for either forward or parallel approach to an element; one full unobstructed side must adjoin an accessible route or another clear floor space | 305.5, 305.6 |
| Alcove, forward approach | Alcoves shall be 36 inches (915 mm) wide minimum where the depth exceeds 24 inches (610 mm) | 305.7.1 |
| Alcove, parallel approach | Alcoves shall be 60 inches (1525 mm) wide minimum where the depth exceeds 15 inches (380 mm) | 305.7.2 |
| Turning space, circular | 60 inches (1525 mm) diameter minimum; may include knee and toe clearance complying with 306 | 304.3.1 |
| Turning space, T-shaped | Within a 60 inch (1525 mm) square minimum, arms and base 36 inches (915 mm) wide minimum; each arm clear of obstructions 12 inches (305 mm) minimum in each direction and the base 24 inches (610 mm) minimum | 304.3.2 |
| Doors and turning space | Doors shall be permitted to swing into turning spaces | 304.4 |
| Changes in level | Not permitted in clear floor space or turning space; slopes not steeper than 1:48 are permitted | 304.2, 305.2 |
Three details matter for layout. First, section 305.3 gives a clear floor space of 30 by 48 inches, and 806.2.3 requires one on each side of a bed, positioned for a parallel approach, so the long side of the space runs along the side of the bed. Second, the exception in 806.2.3 allows a single clear floor space between two beds, which fits a room with two beds. Third, section 305.7 adds maneuvering clearance where a clear floor space is in an alcove or confined on all or part of three sides, so a bay between the bed and a wardrobe wall, or between a bed and a desk, is something the designer should test against 305.7. Whether a particular bay is an alcove under the text is for the designer to decide.
Reading the text as a furniture package
This is our reading of how the text meets a furniture schedule, not a compliance method. Each item points back to the section that creates the constraint.
- Nightstands and the bed (806.2.3, 305.3, 305.5, 305.6). The 30 by 48 inch space beside the bed has to stay clear, positioned for a parallel approach, and one full side has to adjoin an accessible route or another clear floor space. The nightstand footprint and the bed position are therefore part of the check.
- Desk, chair and luggage bench (806.2.6, 304.3). The 60 inch circle or the T-shaped space, with its 12 inch and 24 inch clear arms and base, has to fit in the guest room with the furniture in place. The text defines turning space as a space of that size and permits the circle to include knee and toe clearance complying with section 306, which we did not read. Section 304.4 allows doors to swing into the turning space.
- Wardrobe and storage. The Advisory to 806.2 refers closets to the storage provisions in the scoping sections, which we did not read, so the text we read does not state a wardrobe size or rod height.
- Vanity (806.2.4.1). Where the standard rooms have vanity counter top space, the accessible rooms need comparable space in size and proximity to the lavatory.
- Telephone and outlet (806.3.2). In rooms with communication features, visible notification devices are required for incoming telephone calls and a door knock or bell, and telephones “shall be served by an electrical outlet complying with 309 located within 48 inches (1220 mm) of the telephone to facilitate the use of a TTY.” Section 806.3 and its subsections concern notification, volume control and the outlet; we did not read sections 702, 704.3 or 309.
The text we read does not set bed height, desk height or the dimensions of nightstands. The furniture itself is not regulated in sections 224 or 806 beyond the floor space around it.
What to put in the brief before you ask for quotations
For a US hotel project, these items keep the accessible rooms from being decided late. They are evidence and drawing requests, not a legal checklist.
- The guest room schedule showing the total number of rooms and which room types carry mobility features and communication features, set against Tables 224.2 and 224.4 by the architect.
- For each accessible room type, a furniture layout drawing that shows the 30 by 48 inch clear floor spaces at the bed, the turning space, and every piece of furniture with its footprint.
- A statement of which edition of the standards and which state or local code the architect is working to.
- For each piece in an accessible room, the overall width, depth and height, so the layout can be checked before production.
- Written confirmation of who checks the final installed layout against the drawing, so that a nightstand moved at install does not occupy the clear floor space.
How this sits with an FBM Furniture order
FBM Furniture builds guest room furniture to your drawings and schedule, so the layout and the dimensions come from your designer and are confirmed in the drawings before production. Our guest room pages cover hotel beds and headboards, guest room casegoods and the hotel guestroom furniture range, and the sourcing notes on bedside tables and nightstands, guestroom desks and luggage racks and benches describe the pieces the layout has to accommodate. Our United States furniture compliance page sets out the other US rules we reference. For the main-site view of ADA scope on hotel FF&E and bathrooms, see FBM Sourcing’s note on ADA compliance for hotel FF&E and bathrooms.
Source and date
This article reads sections 224, 806, 304 and 305 of the ADA Accessibility Standards as published on the US Access Board website (chapter 2, chapter 8 and chapter 3), read on 24 October 2026. The page records that, under the Department of Justice rule, places of lodging subject to the transient lodging requirements shall comply with the provisions of the 2010 Standards applicable to transient lodging, including sections 224 and 806. Standards are amended and local codes differ; check the current text and the code your project is permitted under before you rely on any count or dimension above.
Frequently asked questions
How many hotel rooms need to be ADA accessible?
Under Table 224.2, the minimum depends on the total number of guest rooms. A hotel with 1 to 25 rooms needs 1 room with mobility features; 26 to 50 rooms needs 2; 51 to 75 needs 4, of which 1 has a roll-in shower; 76 to 100 needs 5; 101 to 150 needs 7; and so on up the table. A separate count applies to rooms with communication features in Table 224.4.
What does section 806.2.3 say about the bed?
At least one sleeping area must provide a clear floor space complying with section 305 on both sides of a bed, positioned for parallel approach to the side of the bed. Where a single clear floor space is provided between two beds, a space on both sides of each bed is not required. Section 305.3 sets the clear floor space at 30 inches by 48 inches minimum.
How much turning space does an accessible guest room need?
Section 806.2.6 requires turning space complying with section 304 within the guest room. Section 304.3 allows either a circle of 60 inches (1525 mm) diameter minimum or a T-shaped space within a 60 inch square with arms and base 36 inches wide minimum.
Does the ADA say how big the furniture in a guest room must be?
Not in the sections we read. Sections 224 and 806 set room counts, clear floor space, turning space and other room features. They do not set bed height, desk height or nightstand dimensions, and the Advisory to 806.2 refers closets to the storage provisions in the scoping sections, which we did not read.
Do all accessible rooms have to be the same room type?
No. Section 224.5 requires rooms with mobility and communication features to be dispersed among the various classes of guest rooms and to offer comparable choices of room type, number of beds and amenities. Where the minimum number is too small for complete dispersion, the priority is guest room type, then number of beds, then amenities.
How does FBM Furniture support a hotel guest room package?
We review the brief, collect comparable quotations and manage the package for the project. For suppliers you nominate, we charge a 5% commission; for products we source for you, we quote a direct price. Our own team performs one inspection after bulk production is complete and before shipment, and your team is welcome to attend.
Planning accessible guest rooms for a United States hotel?
Send your guest room schedule and drawings. Our team will review them and get back to you.