public-service · 2010 ADA Standards definition
What "the 2010 ADA Standards" Actually Names
The 2010 ADA Standards are a two-part combined document that differs by title II vs. title III, per federal regulation text.
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What matters now
- Under title II, "2010 Standards" is defined as the 2004 ADAAG plus § 35.151.
- Under title III, "2010 Standards" is defined as the 2004 ADAAG plus subpart D of 28 CFR part 36.
- The 2004 ADAAG is the one component shared by both title II and title III definitions.
- DOJ's official online version of the Standards is organized into four sections: an introduction plus three substantive parts covering title II, title III, and the shared 2004 ADAAG.
- Advisory notes, appendix notes, and figures inside the 1991 and 2010 Standards illustrate the rule; by regulation, they do not themselves establish enforceable requirements.
When a regulation or a DOJ document refers to “the 2010 ADA Standards,” it is naming a combined, two-part document, not one self-contained text. The definitions in 28 CFR 35.104 (title II) and 28 CFR 36.104 (title III) each say the 2010 Standards consist of the 2004 ADAAG plus one additional regulatory component — and that added component is different depending on which title applies. That is also why the Department of Justice’s own online version of the Standards is organized into four sections rather than one, and why citing “the 2010 Standards” without saying which title applies is ambiguous on its face.
This original record-reading guide is a general reading aid, not cited evidence. It does not depict a source record; the article text and source links provide the facts.
Key points
Each point is sourced in the matching section below.
- Under title II, “2010 Standards” is defined as the 2004 ADAAG plus § 35.151. (28 CFR 35.104)
- Under title III, “2010 Standards” is defined as the 2004 ADAAG plus subpart D of 28 CFR part 36. (28 CFR 36.104)
- The 2004 ADAAG is the one component shared by both title II and title III definitions. (28 CFR 35.104, 28 CFR 36.104)
- DOJ’s official online version of the Standards is organized into four sections: an introduction plus three substantive parts covering title II, title III, and the shared 2004 ADAAG. (DOJ Standards)
- Advisory notes, appendix notes, and figures inside the 1991 and 2010 Standards illustrate the rule; by regulation, they do not themselves establish enforceable requirements. (28 CFR 36.406)
The title II definition
The regulation that governs state and local government facilities defines the term directly: “2010 Standards means the 2010 ADA Standards for Accessible Design, which consist of the 2004 ADAAG and the requirements contained in § 35.151” (https://www.ecfr.gov/current/title-28/section-35.104). Under this definition, the 2004 ADAAG by itself is not “the 2010 Standards” for a title II facility — it becomes part of the 2010 Standards only in combination with § 35.151.
The title III definition
The parallel regulation for public accommodations and commercial facilities defines the same term differently: “2010 Standards means the 2010 ADA Standards for Accessible Design, which consist of the 2004 ADAAG and the requirements contained in subpart D of this part” (https://www.ecfr.gov/current/title-28/section-36.104). Here the second component is not a single section but an entire subpart of part 36. The shared element across both definitions is the 2004 ADAAG; the added element is title-specific.
DOJ’s assembled document
This same two-part regulatory structure is reflected — in a more granular, four-section breakdown — in how DOJ assembled its own reference copy of the Standards. The agency states: “The Department has assembled this online version of the official 2010 Standards to increase its ease of use” (https://www.ada.gov/law-and-regs/design-standards/2010-stds/). That assembled version is broken into an introduction plus three substantive parts matching the two definitions: a section covering title II facilities, a section covering title III facilities, and a section covering the shared 2004 ADAAG (https://www.ada.gov/law-and-regs/design-standards/2010-stds/). Reading the document’s own table of contents confirms the same split found in the two CFR definitions: a title II part, a title III part, and one shared ADAAG part underneath both.
Advisory notes and figures
Separately, a related regulation addresses how much legal weight to give the explanatory material printed alongside the Standards’ technical text. It states: “Unless specifically stated otherwise, the advisory notes, appendix notes, and figures contained in the 1991 Standards and 2010 Standards explain or illustrate the requirements of the rule; they do not establish enforceable requirements” (https://www.ecfr.gov/current/title-28/section-36.406). In other words, when a reader is trying to determine what the Standards actually require, the enforceable requirement is the rule text itself — the notes and figures are explanatory aids to that text, not a separate source of obligations, unless a specific provision says otherwise.
Scope limits
This article explains only what “the 2010 Standards” refers to as a document and how DOJ’s regulations define and organize it. It does not describe any technical accessibility requirement contained within the 2004 ADAAG, § 35.151, or subpart D — those are substantive design and construction rules that sit inside the combined document this article identifies, and reading them requires going to the specific section that applies. It also does not address, and offers no opinion on, whether any specific building, facility, or design meets the 2010 Standards; that is a fact-specific determination that depends on the applicable technical provisions and the conditions of the particular facility, neither of which this article evaluates.