Reception and Service Counters on US Projects: What Sections 227.3 and 904.4 of the 2010 ADA Standards Say About the Accessible Portion
How many counters, how long and how high the accessible portion is, and what space it needs, read from the text of the 2010 ADA Standards
A reception desk, a concierge counter, a pharmacy or clinic service counter and a bar-side order counter share one feature: someone stands or sits on one side and someone is served on the other. In the United States, the 2010 ADA Standards for Accessible Design set requirements for how many of these counters must have an accessible portion and how that portion is measured.
This article reads the scoping provisions in sections 227.1, 227.3 and 227.5 and the technical provisions in sections 904.1, 904.2 and 904.4 of the 2010 Standards for an FF&E contractor or project buyer who is specifying counters built to a drawing. 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. It does not say whether a particular desk is a sales counter or a service counter, or whether it complies, and it is not legal advice; the project designer decides which standards and which edition apply to the project.
Where the counter requirements sit
Section 227.1 says that where check-out aisles, sales counters, service counters, food service lines, queues and waiting lines are provided, they shall comply with section 227 and section 904. Section 904.1 repeats that check-out aisles and sales and service counters shall comply with the applicable requirements of 904.
The text treats check-out aisles separately in section 904.3, where the counter surface height is 38 inches (965 mm) maximum above the finish floor. This article covers the sales and service counters in section 904.4. Food service lines in section 904.5 and security glazing in section 904.6 are also outside it.
Section 227.3: how many counters
Section 227.3 says that, where provided, at least one of each type of sales counter and service counter shall comply with 904.4, and that where counters are dispersed throughout the building or facility, counters complying with 904.4 also shall be dispersed.
The advisory to 227.3 explains what “type” means. Types of counters that provide different services in the same facility include, but are not limited to, order, pick-up, express and returns. One continuous counter can be used to provide different types of service. The advisory gives an example: order and pick-up are different services, and it would not be acceptable to provide access only to the part of the counter where orders are taken when orders are picked up at a different location on the same counter. Both the order and the pick-up section of the counter must be accessible.
For a schedule, the lesson is about counting by service and not by piece of furniture. A single long counter that serves two purposes can carry two accessible portions, and a hotel that has a front desk and a separate concierge counter has to ask the designer how each is treated. Section 226.1 excepts sales counters and service counters from the dining-surface requirements of section 902; our article on accessible dining surfaces reads those.
Section 904.4: the accessible portion
Section 904.4 says sales counters and service counters shall comply with 904.4.1 or 904.4.2, and that the accessible portion of the counter top shall extend the same depth as the sales or service counter top. The accessible portion is therefore a stretch of the counter top, running the full depth of the counter top.
| Approach | Section | Accessible portion of the counter | Space |
|---|---|---|---|
| Parallel approach | §904.4.1 | A portion of the counter surface 36 inches (915 mm) long minimum and 36 inches (915 mm) high maximum above the finish floor. Where the counter surface provided is less than 36 inches long, the entire counter surface is 36 inches high maximum. | A clear floor space complying with §305 positioned for a parallel approach, adjacent to the 36 inch minimum length of counter. |
| Forward approach | §904.4.2 | A portion of the counter surface 30 inches (760 mm) long minimum and 36 inches (915 mm) high maximum. | Knee and toe space complying with §306 under the counter, and a clear floor space complying with §305 positioned for a forward approach to the counter. |
The two provisions differ in how a person reaches the counter. Section 904.4.1 is written for a parallel approach, with the clear floor space beside the counter, and section 904.4.2 for a forward approach, with knee and toe space under the counter top. The text lets the counter comply with either. The figures for knee and toe clearance are set out in our article on dining surfaces, which reads the same section 306 for tables. Both approaches refer to a clear floor space under section 305, which section 305.3 sets at 30 inches (760 mm) by 48 inches (1220 mm) minimum.
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Approach, position and queues
Section 904.2 says all portions of counters required to comply with 904 shall be located adjacent to a walking surface complying with section 403. The advisory to 904.2 adds a note about layout: if a cash register is provided at the sales or service counter, locate the accessible counter close to the cash register so that a person using a wheelchair is visible to sales or service personnel and to minimize the reach for a person with a disability.
Section 227.5 says queues and waiting lines servicing counters or check-out aisles required to comply with 904.3 or 904.4 shall comply with section 403. The counter and its queue are therefore read together on the plan. The detail of section 403 is outside this article; the designer sets the walking surfaces and queue space, and the furniture schedule needs to show where the accessible portion sits within the desk.
The exception for alterations
Section 904.4 has an exception for alterations. When the provision of a counter complying with 904.4 would result in a reduction of the number of existing counters at work stations or a reduction of the number of existing mail boxes, the counter is permitted to have a portion 24 inches (610 mm) long minimum complying with 904.4.1, provided the required clear floor or ground space is centered on the accessible length of the counter.
The exception sits within section 904.4 and refers to existing counters and mail boxes in alterations. Whether it is relevant to a project is for the designer to say.
Staff work stations and the advisory to 226.1
Reception counters appear in one more place. The advisory to section 226.1 says that in facilities covered by the ADA, the dining-surface and work-surface requirement does not apply to work surfaces used only by employees. It then says that, with respect to work surfaces, employers may need to procure or adjust work stations such as desks, laboratory and work benches, fume hoods, reception counters, teller windows, study carrels, commercial kitchen counters and conference tables to accommodate the individual needs of employees with disabilities on an “as needed” basis, and that work surfaces which are flexible and permit installation at variable heights and clearances should be considered.
That advisory concerns employees and is separate from the public-facing requirement in section 904.4. For a desk that serves both visitors and staff, ask the designer which provisions apply to each side of the desk.
What to put on a counter drawing and schedule line
A reception desk, concierge counter or service counter is built to a drawing, not chosen from a range, and the measurements above are read on the finished unit. Our page on reception desks and concierge counters built to your drawings lists the schedule fields for a counter, including the counter height, any lower or accessible section and the clear space the drawing shows, as the project states it. For a project in the United States, consider adding:
- Which portion is designated. Mark the accessible portion on the elevation and the plan, and say which service it provides (order, pick-up, check-in, returns).
- Its length and height. The length of the portion along the counter and the height from the finish floor to the top, as drawn.
- Its depth. The accessible portion extends the same depth as the counter top, so the depth is drawn along the whole portion.
- Approach. Whether the portion is a parallel approach or a forward approach. For a forward approach, draw the knee and toe space under the counter in section.
- Section joints. If the desk is made in sections, say which section carries the accessible portion and where the joints fall.
- Cut-outs and equipment. Show cable routes, point-of-sale position and any fixed equipment, so the accessible portion is not interrupted by them as drawn.
Questions for the project designer
- Which edition of the accessibility standards does this project follow, and do sections 227 and 904 apply to this facility?
- Which counters on the drawings are sales counters or service counters, and which types of service does each provide?
- Which portion of each desk is designated under 904.4.1 or 904.4.2, and where is it on the plan?
- Does the same desk serve staff and visitors, and are different provisions meant for each side?
- Where are the cash register or point-of-sale positions relative to the accessible portion?
- Does the project alter existing counters, so that the alteration exception is in play?
FBM Sourcing’s note on ADA compliance for hotel FF&E and bathrooms covers ADA specification points for hotel FF&E and bathrooms, and our page on commercial furniture compliance for the United States sets out United States rules relevant to commercial furniture.
Source and date
This article reads the 2010 ADA Standards for Accessible Design, Department of Justice, September 15, 2010, as published on ADA.gov (PDF), sections 226, 227, 305, 306 and 904, read on 21 October 2026. Standards and their adoption by authorities can change; check the edition your project follows with the project designer.
Frequently asked questions
How many sales or service counters must have an accessible portion?
Section 227.3 says that, where provided, at least one of each type of sales counter and service counter shall comply with section 904.4, and that where counters are dispersed throughout the building or facility, the complying counters also shall be dispersed.
How long and how high is the accessible portion of a counter?
For a parallel approach, section 904.4.1 calls for a portion 36 inches (915 mm) long minimum and 36 inches (915 mm) high maximum above the finish floor. For a forward approach, section 904.4.2 calls for a portion 30 inches (760 mm) long minimum and 36 inches (915 mm) high maximum, with knee and toe space under it.
Does the accessible portion have to be as deep as the counter?
Section 904.4 says the accessible portion of the counter top shall extend the same depth as the sales or service counter top.
Is a long counter that serves different purposes one counter or several?
The advisory to section 227.3 says one continuous counter can be used to provide different types of service, and that order and pick-up are different services. Both the order and the pick-up section of the counter must be accessible.
Do these sections cover tables and bar tops where people eat or drink?
No. Dining surfaces are addressed in sections 226 and 902, and section 226.1 excepts sales counters and service counters from section 902. Our article on accessible dining surfaces reads those sections.
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Specifying counters for a US project?
Send your counter drawings, schedule and project location. Our team will review them and get back to you.