Summary
The Department of Justice's manual on Title III of the ADA, explaining that religious organisations and the entities they control, including places of worship, are exempt from Title III.
Key findings
- States that religious entities are exempt from the requirements of Title III of the ADA, and that a religious entity is still subject to the employment duties of Title I if it has enough employees.
- Defines a religious entity as a religious organisation or an entity controlled by one, including a place of worship, and says the exemption is intended to have broad application: an organisation with a lay board can still qualify.
- Says the exemption covers all of a religious entity's activities, "whether religious or secular"; its example is a congregation that runs a day care centre and a private school for members and non-members alike, which remains exempt.
- A private, non-religious organisation that rents a congregation's premises to run a place of public accommodation is covered by Title III, while the congregation as landlord stays exempt; a non-religious organisation using donated space, with no lease under which rent or other consideration is paid, is exempt.
- Lists assistive listening systems and devices among the auxiliary aids that Title III requires covered businesses to provide where needed for effective communication, a duty from which the exemption frees religious entities.
- Section III-1.2000 lists pharmacies, professional offices of health care providers and hospitals among the service establishments that count as places of public accommodation under Title III.
Limits
A 1993 explanation of the law, not the statute or regulation itself, and it says nothing specific about places of worship beyond the exemption. It does not discuss state or local building codes or other laws that may still apply to a place of worship. ada.gov shows the manual as "Last updated: November 01, 1993"; it is cited here by month.
Read the original
www.ada.gov/resources/title-iii-manual
Cited in
- What works in places of worship, and what do the rules ask of them?Partly answered
- What works in hospitals, clinics and pharmacies, where a misheard word can matter most?Partly answered
Cite this source
US Department of Justice, Civil Rights Division. ADA Title III Technical Assistance Manual, section III-1.5000 Religious entities. US Department of Justice (ada.gov). November 1993. https://www.ada.gov/resources/title-iii-manual/ (accessed 9 October 2026).
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