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DOJ Removes ADA Guidance: What Employers Need to Know in 2025

March 24, 20257 min read

In March 2025, the U.S. Department of Justice (DOJ) removed 11 guidance documents from the Americans with Disabilities Act (ADA) website.

These documents provided businesses with practical information on accessibility, COVID-19 policies, and customer service best practices for individuals with disabilities.

This move, part of a broader regulatory rollback under the Trump administration, has left many employers uncertain about how to maintain compliance in this evolving legal environment.

Despite the removal of these resources, core ADA obligations remain in place.

For employers, this is a critical moment to reassess policies, proactively invest in accessibility, and reaffirm their commitment to disability inclusion.

What Did the DOJ Remove and Why Does It Matter?

The DOJ rescinded 11 guidance documents that provided clarity on how businesses could meet ADA obligations in everyday situations — from service animal policies to accessible customer service practices.

While the department described these removals as part of an effort to “reduce regulatory burdens,” disability advocates argue that these guidelines served as crucial resources for small businesses and large employers alike (Justice.gov, 2025).

Summaries of the 11 Rescinded ADA Guidance Documents

  1. COVID-19 and the ADA: Can a business stop me from bringing in my service animal because of the COVID-19 pandemic?
    Clarified that businesses could not deny entry to individuals with service animals due to COVID-19 concerns unless the animal posed a direct health threat.

  2. COVID-19 and the ADA: Does the DOJ issue exemptions from mask requirements?
    Explained that the DOJ does not issue mask exemptions but that businesses should provide reasonable accommodations for those unable to wear masks.

  3. COVID-19 and the ADA: Are there resources that explain my rights as an employee with a disability during the pandemic?
    Provided guidance for employees on requesting reasonable accommodations and understanding workplace protections during COVID-19.

  4. COVID-19 and the ADA: Can hospitals exclude all visitors, even if a patient with a disability needs support from a caregiver?
    Clarified that hospitals must consider reasonable accommodations for patients with disabilities who require support persons for equal access to care.

  5. COVID-19 and the ADA: Does the ADA apply to outdoor restaurants and retail spaces set up during the pandemic?
    Outlined that temporary outdoor structures must still comply with ADA accessibility requirements.

  6. Expanding Your Market: Maintaining Accessible Features in Retail Establishments (2009)
    Provided best practices for maintaining accessibility in retail stores, such as keeping aisles clear and maintaining accessible entrances.

  7. Expanding Your Market: Gathering Input from Customers with Disabilities (2007)
    Encouraged businesses to seek feedback from customers with disabilities to improve services and ensure accessibility.

  8. Expanding Your Market: Accessible Customer Service Practices for Hotel and Lodging Guests with Disabilities (2006)
    Offered guidance to hotel staff on providing respectful, effective service to guests with disabilities, covering check-in procedures and accessible amenities.

  9. Reaching Out to Customers with Disabilities (2005)
    Highlighted the business benefits of serving customers with disabilities and recommended inclusive marketing and customer service practices.

  10. Americans with Disabilities Act: Assistance at Self-Serve Gas Stations (1999)
    Instructed gas stations on providing assistance to drivers with disabilities who may not be able to pump gas independently.

  11. Five Steps to Make New Lodging Facilities Comply with the ADA (1999)
    Outlined simple steps for hotel developers and owners to ensure new lodging facilities met ADA standards.

These documents made ADA compliance more accessible and understandable, especially for businesses that may not have legal teams on staff.

Their removal places the burden on employers to be even more proactive in understanding and meeting legal obligations.

What This Means for Employers

1. Legal Obligations Remain

The Americans with Disabilities Act, passed in 1990, remains in full effect. Businesses are still required by law to provide reasonable accommodations and ensure accessible facilities (ADA.gov, 2025).

2. Risk of Misinterpretation

Without these guidance materials, businesses may inadvertently fall out of compliance. This can lead to lawsuits, civil penalties, and reputational damage.

3. Need for Internal Policy Reviews

Employers should review and update all hiring policies, training materials, workplace accommodation procedures, and customer service practices to ensure they meet ADA standards.

What Employers Should Do Now

  • Consult Legal Experts:
    Work with legal counsel to review all ADA-related policies and ensure ongoing compliance.

  • Train Staff on ADA Requirements:
    HR teams and managers should be trained to recognize accommodation requests and respond appropriately.

  • Update Virtual and Hybrid Work Policies:
    Ensure digital platforms, remote tools, and hybrid setups are accessible for all employees.

  • Invest in Accessibility Improvements:
    Go beyond compliance by proactively upgrading facilities and offering inclusive digital experiences.

Why Staying Proactive Matters

While the removal of these guidance documents reduces official resources, it does not reduce legal responsibility.

Companies that prioritize accessibility not only avoid legal risks but also build stronger employer brands and attract more diverse talent.

Conclusion

The DOJ’s removal of ADA guidance documents is a wake-up call for employers. Now is the time to audit policies, educate teams, and reinforce your commitment to accessibility.

The legal mandates remain — and the ethical obligation to foster inclusive workplaces has never been more important.

FAQs

Does the removal of these documents change the law?
No. The ADA remains in force, and employers must still comply with all federal requirements (ADA.gov, 2025).

Why did the DOJ remove these documents?
The stated reason was to reduce regulatory burdens, though critics argue it could lead to confusion for employers (Justice.gov, 2025).

What are the risks if a business falls short?
Failure to comply with the ADA can result in lawsuits, fines, and damage to a company’s reputation.

Where can employers get updated information on ADA compliance?
Visit ADA.gov and consult with legal counsel for the most current requirements.


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DEI is at a crossroads.

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✔ See what’s changing in DEI hiring and retention and how top companies are responding.

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