Six free ADA and reasonable accommodation policy templates built for small business, with a clear explainer of the federal 15-employee threshold and the state laws that reach lower: a full policy, a one-page version, a request form, a California version, a state-coverage note, and an acknowledgment form. Download as DOCX.
An ADA policy, more fully an ADA and reasonable accommodation policy, sets out how your business handles disability accommodation for applicants and employees under the Americans with Disabilities Act and state disability laws. The question most small businesses actually have is whether it even applies to them. Federally, the ADA starts at 15 employees, but state law often reaches much lower, and a clear accommodation process protects you either way.
These six templates are built for that reality: a full policy, a one-page small-business version, an accommodation request form, a California version, a state-coverage note, and an acknowledgment form. Each downloads as a Word document, free and without an email. This page covers the workplace meaning of ADA (Title I employment), not website accessibility. Because the policy sits alongside your other rules, it pairs with your HR policy manual and EEO policy.
TL;DR
An ADA policy explains how an employer provides reasonable accommodations to qualified people with disabilities through the interactive process, unless doing so causes undue hardship. The federal ADA applies at 15+ employees, but state law reaches lower: California at 5+, New York and Illinois at all sizes. Most accommodations cost little or nothing. Download six free templates as DOCX, including a request form and a California version, then have counsel review. This is general information, not legal advice.
What an ADA Policy Is
An ADA and reasonable accommodation policy is a written statement of how an employer meets its duty to provide reasonable accommodations to qualified individuals with disabilities. It converts a legal obligation into a clear, repeatable process that a manager can actually follow when someone asks for a change at work.
In the workplace this means ADA Title I, the employment provisions enforced by the EEOC, not website accessibility, which is a separate document for web teams. The policy usually lives in the employee handbook and also works as a standalone document signed at onboarding, paired with a request form that documents each accommodation.
The Key Terms to Get Right
An ADA policy rests on a handful of legal terms, and getting them right is what makes the policy usable. These four definitions, drawn from the ADA and EEOC guidance, are the ones every accommodation decision turns on.
Disability
Under the ADA, a disability 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. The 2008 ADA Amendments Act made this definition broad, so most conditions that materially limit an activity qualify. Some state laws, like California's, go further and require only that a condition limit, not substantially limit, a major life activity, which brings more conditions in scope.
Qualified individual and essential functions
The ADA protects a qualified individual: someone who can perform the essential functions of the job, the fundamental duties, with or without a reasonable accommodation. Marginal tasks are not essential functions. A clear, accurate job description that lists the essential functions is the anchor for this analysis, because it defines what the person must be able to do and what the accommodation has to enable.
Reasonable accommodation and the interactive process
A reasonable accommodation is a change to the application process, the job, or the work environment that lets a qualified person with a disability perform essential functions or enjoy equal employment benefits, from a modified schedule to assistive equipment to reassignment. It is identified through the interactive process, a good-faith, back-and-forth conversation between employer and employee, which the EEOC expects employers to engage in promptly once a need is known.
Undue hardship
An employer must provide a reasonable accommodation unless it causes undue hardship, meaning significant difficulty or expense judged against that employer's size, resources, and operations. It is a high, case-by-case standard, and cost alone rarely meets it, since an accommodation that is a hardship for a tiny business may be routine for a larger one. Before claiming hardship, an employer must consider alternatives, outside funding, and tax credits.
Most Accommodations Cost Little or Nothing
In the Job Accommodation Network employer survey, most accommodations cost the employer nothing, and those with a one-time cost have a median of about $300. The ADA requires accommodation unless it causes undue hardship, a high, case-by-case standard that cost alone rarely meets.
With the terms defined, the practical question follows: does the ADA actually apply to your business, and if not, does state law? That is where the small-business analysis begins.
Does the ADA Apply to Your Small Business?
The ADA's employment provisions apply to employers with 15 or more employees. Below that, the federal ADA generally does not cover you as an employer, but state disability law very often does, at much lower thresholds. This is the single most important thing for a small business to get right.
Law
Employer size covered
Federal ADA (Title I)
15 or more employees
California (FEHA)
5 or more employees; broader disability definition
New York (State Human Rights Law)
All employers, any size
Illinois (Human Rights Act)
1 or more employees
Colorado (Anti-Discrimination Act)
Any size, regardless of employee count
Many other states and cities
Varies; often below the federal 15
The takeaway: even if you are below the federal 15-employee line, you may be fully covered by state law, and a disability accommodation policy remains sound practice regardless. The state-coverage note in the template set helps you record exactly where you stand, and the compliance hub covers state specifics.
What to Include
A complete ADA policy moves from a foundation of definitions and non-discrimination, through the mechanics of requesting and processing an accommodation, to how records are kept and the policy is adopted. The sections below are the consensus set a strong policy covers.
Foundation
Purpose and scope
Key definitions everyone shares
A clear non-discrimination statement
The process
How to request an accommodation
The good-faith interactive process
Medical documentation, only when needed
Protect
Confidential, separately stored records
An undue-hardship standard
A non-retaliation clause
Adopt
A request and decision form
A state-coverage note
A signed acknowledgment for the file
The parts small businesses most often miss, and that carry real risk, are the interactive process, confidential handling of medical records, and the state-coverage reality. The templates here build all three in by default.
Which Template Should You Use?
Start with the full policy, or the one-page version if you are early-stage, then add the request form and the state pieces you need. Use the California version if you employ people there, and the state-coverage note to record which law applies to you.
ADA and Accommodation Policy
The flagship
The full policy: purpose and scope, definitions, non-discrimination, how to request, the interactive process, medical documentation and confidentiality, undue hardship, non-retaliation, and an acknowledgment. The version to adapt.
Small-Business Policy
Simple, 1-page
A short, plain-language accommodation policy for a small business, useful whether or not the federal ADA covers you, since state disability laws often reach smaller employers. Simple to adopt and grow from.
Accommodation Request Form
Documents the process
A fill-in form to document the request, the interactive process, and the decision, structured to keep an auditable record while keeping medical details in a confidential file.
California Policy (FEHA)
5+ employees
A California version keyed to FEHA, which covers employers with 5 or more, defines disability more broadly than the ADA, and makes failing to engage in the interactive process its own violation.
State Coverage Note
NY, IL, CO, and more
A note explaining the federal 15-employee threshold and the states that reach lower, so a small business can record which law covers it. What generic ADA templates skip.
Acknowledgment Form
Ready to sign
A standalone form to record that each employee received and agreed to the ADA policy, designed to be collected at onboarding and after updates.
Match the Template to Your Situation
Setting up a real policy: the full ADA and Accommodation Policy, with the Request Form. Small and early-stage: the one-page Small-Business version. Employing people in California: the California version. Operating across states or unsure of coverage: the State Coverage Note. Then use the Acknowledgment Form, add your contacts and state specifics, and have counsel review before adopting.
6 Free ADA Policy Templates
Download all six as a single Word document or copy individual templates. The full policy is the core; the small-business, request-form, California, and state-coverage versions cover specific needs; and the acknowledgment form captures the signature. Fill in your specifics, keep the definitions and process language, and have counsel review before you adopt.
Download All 6 ADA Policy Templates
A full ADA and accommodation policy, a one-page small-business version, an accommodation request form, a California version, a state-coverage note, and an acknowledgment form. All in one DOCX.
Template 1: ADA and Reasonable Accommodation Policy
The full policy: purpose and scope, definitions, non-discrimination, how to request, the interactive process, medical documentation and confidentiality, undue hardship, non-retaliation, and an acknowledgment. The foundation to adapt.
ADA and Reasonable Accommodation Policy
ADA AND REASONABLE ACCOMMODATION POLICY
[Company Name]
Effective date: _ Policy owner: __
Last reviewed: _
1. PURPOSE AND SCOPE
[Company Name] is committed to equal employment opportunity for qualified individuals
with disabilities and complies with the Americans with Disabilities Act (ADA) and
applicable state and local disability laws. This policy explains how we handle
requests for reasonable accommodation. It applies to all applicants and employees.
2. KEY DEFINITIONS
•Disability: 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.
•Qualified individual: a person who can perform the essential functions of the job,
with or without reasonable accommodation.
•Reasonable accommodation: a change to the application process, the job, or the work
environment that lets a qualified person with a disability perform essential
functions or enjoy equal benefits of employment.
•Undue hardship: significant difficulty or expense, assessed case by case against
the employer's size, resources, and operations.
•Interactive process: the good-faith conversation between employee and employer to
identify an effective accommodation.
3. NON-DISCRIMINATION STATEMENT
We do not discriminate against applicants or employees on the basis of disability in
any employment practice, including hiring, firing, pay, promotion, training, or
benefits. We also prohibit retaliation against anyone who requests an accommodation
or asserts their rights.
4. HOW TO REQUEST AN ACCOMMODATION
An employee or applicant may request an accommodation by telling [name / title /
email] that they need an adjustment or change at work for a reason related to a
medical condition. The request does not need to be in writing or use the words ADA or
reasonable accommodation, though we may confirm it in writing.
5. THE INTERACTIVE PROCESS
After a request, we will engage promptly in an interactive process: discuss the
limitation and the barrier, request reasonable medical documentation if the disability
or need is not obvious, identify possible accommodations, and select an effective one.
We will not necessarily provide the exact accommodation requested if another effective
option exists.
6. MEDICAL DOCUMENTATION AND CONFIDENTIALITY
We may request documentation from a health care provider confirming the disability
and the need for accommodation when it is not obvious. All medical information is kept
confidential, stored separately from the personnel file, and shared only with those
who need to know to implement the accommodation.
7. UNDUE HARDSHIP
We will provide a reasonable accommodation unless it would cause undue hardship,
meaning significant difficulty or expense given our size and resources. If a requested
accommodation is an undue hardship, we will work with the employee to identify an
effective alternative.
8. NON-RETALIATION
[Company Name] prohibits retaliation against any applicant or employee who requests an
accommodation, participates in the interactive process, or files a complaint.
9. QUESTIONS
Direct questions to [name / title / email].
ACKNOWLEDGMENT
I acknowledge that I have received and read this ADA and Reasonable Accommodation
Policy.
Employee signature: __ Date: _
DISCLAIMER: This is a sample template for general informational purposes only and is
not legal advice, and not a guarantee of compliance. Federal, state, and local
disability laws vary and change. Have this policy reviewed and adapted by a qualified
A short, plain-language accommodation policy for a small business, useful whether or not the federal ADA covers you, since state disability laws often reach smaller employers. Simple to adopt and grow from.
A fill-in form to document the request, the interactive process, and the decision, structured to keep an auditable record while keeping medical details in a confidential file.
Reasonable Accommodation Request Form
REASONABLE ACCOMMODATION REQUEST FORM
[Company Name]
Use this form to document an accommodation request and the interactive process. The
employee starts the top section; the employer completes the rest. Keep the completed
form in a confidential medical file, separate from the personnel file.
SECTION A: EMPLOYEE REQUEST (completed by employee)
Name: __ Job title: __
Date of request: _
Describe the job function or workplace barrier you are having difficulty with:
_
What change or accommodation are you requesting (if known)?
_
SECTION B: INTERACTIVE PROCESS (completed by employer)
Date request received: _ Handled by: __
Is the disability or need obvious? [ ] Yes [ ] No
Medical documentation requested? [ ] Yes [ ] No Date: _____
If alternative or denied, explain (including any undue hardship basis):
_
Accommodation to be provided: ____
Start date: _ Review date: _
Employer signature: __ Date: _
Employee signature: __ Date: _
DISCLAIMER: This is a sample form for general information only and is not legal
advice. Keep completed forms confidential and separate from the personnel file.
Template 4: California Disability Accommodation Policy (FEHA)
A California version keyed to FEHA, which covers employers with 5 or more, defines disability more broadly than the ADA, and makes failing to engage in the interactive process its own violation.
California Disability Accommodation Policy (FEHA)
DISABILITY ACCOMMODATION POLICY (CALIFORNIA)
[Company Name]
Effective date: _ Last reviewed: _
Use this version if you employ people in California. The California Fair Employment
and Housing Act (FEHA) covers employers with 5 or more employees, below the federal
ADA's 15-employee threshold, and defines disability more broadly than federal law.
These laws change; confirm current rules with counsel.
1. WHO IS COVERED IN CALIFORNIA
FEHA requires employers with 5 or more employees to provide reasonable accommodation
for a known disability. California defines disability more broadly than the ADA: a
condition need only limit a major life activity, not substantially limit it. This
policy applies alongside the ADA where the ADA also applies.
2. COMMITMENT AND INTERACTIVE PROCESS
[Company Name] provides reasonable accommodations to qualified employees and
applicants with disabilities, and engages in a timely, good-faith interactive process
to identify them, unless doing so would cause undue hardship. Failing to engage in the
interactive process is itself a violation under California law, so we treat every
request seriously and document the conversation.
3. HOW TO REQUEST
Tell [name / title] that you need a change at work for a reason related to a medical
condition. No special wording is required. We will discuss options and request
documentation only where the disability or need is not obvious.
4. CONFIDENTIALITY AND NON-RETALIATION
Medical information is kept confidential and separate from the personnel file. We
prohibit retaliation for requesting an accommodation or asserting rights. A complaint
may be filed with the California Civil Rights Department (CRD).
ACKNOWLEDGMENT
I acknowledge that I have received and read this California Disability Accommodation
Policy.
Employee signature: __ Date: _
DISCLAIMER: This is a sample template for general information only and is not legal
advice. California law changes frequently; confirm current FEHA requirements and have
this policy reviewed by a qualified California employment attorney before adopting it.
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A note explaining the federal 15-employee threshold and the states that reach lower, so a small business can record which law covers it. What generic ADA templates skip.
State Disability Law Coverage Note (NY, IL, CO, and more)
STATE DISABILITY LAW COVERAGE NOTE
[Company Name]
Attach this note to your accommodation policy to record which law covers you. The
federal ADA starts at 15 employees, but many state disability laws reach much smaller
employers, so a business below 15 can still be legally required to accommodate. The
obligation follows where the employee works. Confirm current rules with counsel.
FEDERAL BASELINE
The ADA (Title I) applies to employers with 15 or more employees. Below 15, the
federal employment provisions generally do not apply, but state law often does.
STATES THAT REACH SMALLER EMPLOYERS (EXAMPLES)
•California: FEHA covers employers with 5 or more employees, and defines disability
more broadly than the ADA.
•New York: the New York State Human Rights Law covers employers of all sizes, with no
employee-count threshold.
•Illinois: the Illinois Human Rights Act covers employers with 1 or more employees;
disability discrimination has long applied at 1 or more.
•Colorado: the Colorado Anti-Discrimination Act protects employees with disabilities
regardless of employer size.
Many other states and cities set their own thresholds. Identify the rule for every
state and city where your employees work, and adopt the accommodation policy even if
you are below the federal 15-employee line.
OUR COVERAGE (fill in)
States where we employ people: ____
Laws that apply to us: ______
Lowest applicable employee threshold: _____
DISCLAIMER: This is general information only and is not legal advice. State and local
disability laws vary and change. Confirm current requirements for every location where
your employees work with a qualified employment attorney.
Template 6: ADA Policy Acknowledgment Form
A standalone form to record that each employee received and agreed to the ADA policy, designed to be collected at onboarding and after material updates.
ADA Policy Acknowledgment Form
ADA POLICY ACKNOWLEDGMENT FORM
[Company Name]
Use this form to record that an employee received and agreed to the ADA and
reasonable accommodation policy. Keep the signed form in the employee file, and
collect it at onboarding and after material updates.
EMPLOYEE ACKNOWLEDGMENT
I, __ (print name), acknowledge that:
•I have received a copy of the [Company Name] ADA and Reasonable Accommodation Policy
dated _____.
•I have read and understand it, and I have had the opportunity to ask questions.
•I understand how to request a reasonable accommodation and that the company engages
in an interactive process.
•I understand that the company keeps medical information confidential and prohibits
retaliation for requesting an accommodation.
•I agree to follow this policy as a condition of my employment.
DISCLAIMER: This is a sample form for general information only and is not legal
advice. Adapt it to your company and recordkeeping practices.
ADA for a Small Business
A large company has an HR and legal team to write an ADA policy and run every accommodation. A small business has an owner or an office manager facing the same law, and the same confusion about whether it applies, without that support. Here is what matters most at that scale.
You may be under 15 employees and still legally required to accommodate
The most common small-business assumption about the ADA is that the federal 15-employee threshold means a smaller business is exempt. Federally, the ADA's employment provisions do start at 15 employees. But state disability laws frequently reach much lower. California's FEHA covers employers with 5 or more, New York's Human Rights Law covers employers of all sizes, Illinois covers 1 or more, and Colorado protects employees with disabilities regardless of employer size. So a six-person California company or a two-person New York company has a real accommodation obligation the federal reading would miss entirely. This template is built around that reality, with a state-coverage note so you know where you actually stand.
Accommodations cost far less than most small employers fear
Cost anxiety stops many small businesses from handling accommodations well, and the data says that fear is mostly misplaced. In the Job Accommodation Network's employer survey, most accommodations cost nothing at all, and those that do carry a one-time cost have a low median. Many accommodations are schedule changes, a piece of equipment, or a workspace adjustment, not a major expense. Framing accommodation as an expensive burden usually gets the facts wrong, and a calm, structured interactive process is almost always cheaper than losing a valued employee or facing a complaint.
The policy only protects you if the process is documented and the records stay confidential
An ADA policy earns its value in the paperwork: a clear request path, a documented interactive process, medical information kept confidential and separate from the personnel file, and a signed acknowledgment on file. Two things trip small businesses up, missing documentation and mishandled medical records, and both are exactly where an HR platform helps honestly. FirstHR captures the policy acknowledgment with e-signature during onboarding, stores the signed policy and the accommodation request form in the employee profile with access controls so medical details stay need-to-know, and runs the interactive process as a task workflow so each step is recorded. To be clear about scope, FirstHR is an onboarding and HR platform, not a law firm, and it does not run payroll or administer benefits, so pair it with counsel and those providers. The templates below work on their own; FirstHR is how you adopt, document, and store them.
Adopt, Sign, and Apply
An ADA policy delivers its value when it is adopted, acknowledged, and applied through a documented process with confidential records. That means adapting the template, delivering it on day one, running the interactive process when a request comes, and storing medical records separately.
Adapt the policy
Fill in your contacts, keep the definitions and interactive-process language, add your state coverage, and have counsel review before adopting.
Deliver and sign
Share the policy at onboarding and collect a signed acknowledgment with e-signature, the same flow as your handbook.
Run the process
When a request comes in, engage in the interactive process promptly, document each step on the request form, and decide in good faith.
Store confidentially
Keep medical documentation separate from the personnel file with need-to-know access, and retain the signed acknowledgment.
The templates above work on their own. To adopt and apply them without paper, FirstHR captures the policy acknowledgment with e-signature during onboarding, the same flow it uses for the employee handbook, stores the signed policy and request form in the employee profile with document management and access controls that keep medical details need-to-know, and can run the interactive process as a task workflow. FirstHR is an onboarding and HR platform, not a law firm, and it does not run payroll or administer benefits, so connect those separately and consult employment counsel. Applicant tracking is coming soon to FirstHR.
Key Takeaways
An ADA policy explains how an employer provides reasonable accommodations to qualified people with disabilities through the interactive process.
The federal ADA applies at 15 or more employees, but state law reaches lower: California at 5+, New York and Illinois at all sizes, Colorado at any size.
Even below the federal threshold, a written accommodation policy is sound practice and often legally required by state law.
Most accommodations cost little or nothing; undue hardship is a high, case-by-case standard that cost alone rarely meets.
Keep medical information confidential and stored separately from the personnel file, and document the interactive process.
This is the employment meaning of ADA (Title I), not website accessibility. These templates are starting points; have counsel review. This is general information, not legal advice.
Frequently Asked Questions
What is an ADA policy?
An ADA policy, more precisely an ADA and reasonable accommodation policy, is a written company policy explaining how the business meets its obligations to qualified individuals with disabilities under the Americans with Disabilities Act and applicable state disability laws. A complete policy defines key terms like disability, reasonable accommodation, and undue hardship, states that the company does not discriminate based on disability, explains how an employee or applicant requests an accommodation, describes the interactive process the company follows, addresses medical documentation and confidentiality, and includes non-retaliation language and an acknowledgment. In the workplace this refers to ADA Title I, the employment provisions, not website accessibility. For a small business, the policy turns a legal obligation into a clear, repeatable process. This is general information, not legal advice.
Does the ADA apply to small businesses?
The employment provisions of the ADA (Title I) apply to employers with 15 or more employees, so a business with fewer than 15 is generally not covered by the federal ADA as an employer. However, that is not the end of the story, because state disability laws often reach much smaller employers. California's Fair Employment and Housing Act covers employers with 5 or more, New York's Human Rights Law covers employers of all sizes, Illinois covers 1 or more, and Colorado protects employees with disabilities regardless of size. So a small business below the federal 15-employee threshold may still be legally required to provide reasonable accommodations under state law, and adopting an accommodation policy is sound practice even where it is not strictly required. Confirm the rule for every state where your employees work. This is general information, not legal advice.
What is a reasonable accommodation?
A reasonable accommodation is any change to the job application process, to the job itself, or to the work environment that enables a qualified individual with a disability to perform the essential functions of the job or to enjoy the same benefits and privileges of employment as other employees. Common examples include a modified or part-time schedule, assistive equipment or software, an accessible workspace, permission to work from home where the job allows, adjusted training materials, reserved parking, or reassignment to a vacant position. The employer and employee identify an effective accommodation through the interactive process. The employer does not have to provide the exact accommodation requested if another effective option exists, and does not have to provide one that causes undue hardship. This is general information, not legal advice.
What is the interactive process?
The interactive process is the good-faith, back-and-forth conversation between an employer and an employee or applicant to identify an effective reasonable accommodation after a request is made. It typically involves discussing the limitation and the workplace barrier, requesting reasonable medical documentation if the disability or need is not obvious, exploring possible accommodations, and selecting and implementing an effective one. The EEOC expects employers to begin this process promptly and act without unnecessary delay. Documenting each step matters, both to reach a good outcome and to show good faith. In some states, notably California, an employer's failure to engage in the interactive process is itself a separate legal violation, so a structured, recorded process is especially important. This is general information, not legal advice.
How much do accommodations usually cost?
Far less than most employers expect. According to the Job Accommodation Network's ongoing employer survey, the majority of workplace accommodations cost the employer nothing at all, and among those that do carry a one-time cost, the median expenditure is modest, around a few hundred dollars. Many accommodations are simply schedule adjustments, a piece of equipment, software, or a change to how a task is done, rather than a significant expense. Cost also factors into the undue-hardship analysis case by case, weighed against the employer's size and resources, and employers must consider outside funding and tax credits before claiming hardship. For a small business worried about cost, the data is reassuring: accommodations are usually low cost and high impact. This is general information, not legal advice.
How should an employer handle medical information in an accommodation request?
Confidentially and separately. Under the ADA, any medical information an employer obtains about an employee, including documentation supporting an accommodation request, must be kept confidential and stored separately from the regular personnel file, with access limited to those who need to know to implement the accommodation. An employer may request reasonable documentation from a health care provider confirming the disability and the need for accommodation when the disability or need is not obvious, but should not ask for more than necessary. Supervisors and managers may be told about necessary restrictions and accommodations, and first aid or safety personnel may be informed if the condition might require emergency treatment, but the underlying medical details stay protected. Mishandling medical records is a common and avoidable mistake. This is general information, not legal advice.
What is undue hardship?
Undue hardship is the legal standard that limits an employer's obligation to provide a reasonable accommodation. It means significant difficulty or expense, judged case by case against the specific employer's size, financial resources, and the nature and structure of its operations. An accommodation that would be an undue hardship for a very small business might be routine for a large one, so the analysis is individualized. It is a high bar: cost alone rarely justifies denial, and before claiming undue hardship an employer must consider whether outside funding or tax credits could offset the cost, whether the employee would cover part of it, and whether a different, effective accommodation would avoid the hardship. If one accommodation is an undue hardship, the employer must still provide an effective alternative that is not. This is general information, not legal advice.
Is an ADA policy the same as a website accessibility policy?
No, they are different documents for different purposes, and the distinction matters because the term ADA policy is used for both. This template, and the workplace meaning of ADA policy, refers to ADA Title I, the employment provisions: how an employer handles disability accommodation for applicants and employees. A website or digital accessibility policy, sometimes tied to ADA Title III or Title II and to WCAG standards, is about making a website or app usable by people with disabilities, and is aimed at web and digital teams. If you are an HR manager or small-business owner adopting a disability accommodation policy for your workforce, the employment policy on this page is what you need. A web-accessibility statement is a separate document. This is general information, not legal advice.
