Industry Trends & Reports

The Accessibility Gap: How Commercial Washrooms Are Moving Beyond Minimum ADA Compliance

Key Takeaways

• More than 1 in 4 U.S. adults, 28.7 percent, live with a disability. [1]
• ADA compliance sets the baseline for accessible restrooms, but the federal accessibility guidelines contain no requirements for adult changing tables. [4]
• The 2024 International Building Code adds Section 1110.4, requiring adult changing stations where fixture-count thresholds are met in assembly, mercantile, higher-education, and school assembly occupancies, and at highway rest stops. [2]
• Minnesota has enacted dedicated building code legislation. Beginning in fiscal year 2030, medium and large hub airports applying for federal development grants must assure at least one private single room with a universal changing station in each passenger terminal. [3][4]
• Disability rates are at a record high as the population ages, expanding demand for accessible washroom design. [13]

Why We Wrote This Report

We manufacture washroom partitions, accessories, and lockers for commercial, institutional, and hospitality projects across North America. That vantage point gives us a direct view of how accessibility requirements move from advocacy, to code, to the specifications that land on our desks.

What we have watched over the past several years is a change in the order of the conversation. Accessibility used to come up late in a project, after layouts were fixed, as a compliance check against a finished plan. It now comes up earlier, and it comes up as a design question rather than a code question. Specifiers ask what a space should do for the people using it before they ask what the code will accept.

Adult changing facilities are the clearest example. For most of our history they were not part of a standard washroom conversation. They are now a line item architects raise directly, and the projects raising it are the building types we have been outfitting for years.

ADA at 36: What the Law Requires and Where Gaps Remain

What Does the ADA Require in Commercial Restrooms?

The ADA sets minimum accessibility requirements for restrooms in public accommodations and commercial facilities. Signed in 1990 and updated through the 2010 ADA Standards for Accessible Design, it governs the physical components of the toilet stall. [5]

Core ADA Stall Requirements

• Door width and clear floor space sufficient for wheelchair maneuverability. [6]
• Turning space for a wheelchair to enter, close the door, and exit. [6]
• Grab bar placement at required heights and load ratings. [5][6]
• Fixture heights for toilets, lavatories, and dispensers within the reach ranges set at Section 308 of the 2010 ADA Standards. [5]

At the fixture level, the standards also require knee and toe clearance beneath lavatories and sinks, and operable parts that can be used with one hand without tight grasping, pinching, or twisting of the wrist, at Section 309.4. [5]

Why Is Compliance the Floor, Not the Ceiling?

ADA compliance establishes a baseline, but it was built around wheelchair accessibility as its primary framework. The federal ADA and ABA Accessibility Guidelines, last revised in 2004, set requirements for toilet rooms, toilet compartments, lavatories, sinks, and work surfaces, and contain no requirements for adult changing tables. The U.S. Access Board states this directly in its 2026 rulemaking notice on universal changing stations. [4] Several populations still cannot use a code-compliant restroom independently.

Who the ADA Does Not Fully Serve

• People who require caregiver assistance with toileting, dressing, or changing. [4]
• Individuals with cognitive disabilities or complex medical needs. [9]
• People whose physical limitations preclude independent use of a standard accessible stall. [8]

A restroom can meet every dimension on the ADA checklist and still leave some users unable to manage toileting without help. Meeting the code is the starting point. Designing for genuine accessibility goes further, and that is where the market is heading.

The Human Experience Behind the Data

How Many Americans Are Affected?

More than 1 in 4 U.S. adults, 28.7 percent, live with a disability, according to the CDC. [1] The disability types most relevant to restroom access are mobility and self-care.

• 12.2 percent of U.S. adults have a mobility disability involving serious difficulty walking or climbing stairs. [1]
• 3.6 percent of U.S. adults have a self-care disability involving difficulty dressing or bathing. [1]
• 7.7 percent of U.S. adults have an independent living disability involving difficulty doing errands alone. [1]

A note on the two disability rates in this report. The 28.7 percent figure above measures self-reported disability among U.S. adults. The 13.7 percent figure in the Market Outlook section measures disability across the total U.S. population, including children, using a different federal survey instrument. Both are current. They use different denominators and different definitions, and they are not interchangeable. [1][13]

What Does the Research Show About Caregiver Experience?

Caregivers routinely resort to unsafe conditions when adult-sized changing facilities are unavailable. A study in the Disability and Health Journal interviewed five self-advocates and 16 caregivers and documented consistent findings. [9]

• All 16 caregivers had changed a disabled individual in a vehicle or parking lot. [9]
• Eleven caregivers had changed individuals on public restroom floors. [9]
• Caregivers frequently sustained physical injuries in the process. [9]
• Several respondents limited fluid intake or used suppositories to avoid needing a restroom during unavoidable outings. [9]

The U.S. Access Board describes the same pattern in its rulemaking record: in the absence of a universal changing table, individuals with disabilities often have to lie on a bathroom floor to receive assistance, and the transfer between a wheelchair and the floor is difficult and dangerous for the caregiver as well as the user. [4]

The Changing Spaces Campaign uses census data to show that millions of Americans are effectively excluded from public life because suitable changing facilities do not exist where they need them. [8]

The Regulatory Shift Toward Inclusive Design

What Does the 2024 International Building Code Require, and Where?

The 2024 IBC introduces Section 1110.4, Adult Changing Stations. Where an adult changing station is required, it must be accessible and comply with Sections 1110.4.1 through 1110.4.4. The trigger is a required fixture count rather than occupancy type alone, so the requirement scales with the size of the facility. [2]

Where the 2024 IBC Requires at Least One Adult Changing Station

1. Assembly and mercantile occupancies, where family or assisted-use toilet or bathing rooms are required under Section 1110.2.1. That provision applies where an aggregate of six or more male and female water closets are required. [2]
2. Group B occupancies providing educational facilities for students above the 12th grade, where an aggregate of 12 or more male and female water closets are required to serve classrooms and lecture halls. [2]
3. Group E occupancies, where a room or space used for assembly purposes requires an aggregate of six or more male and female water closets for that space. The trigger is the assembly space, such as a school gymnasium with spectator seating, not the school as a whole. [2]
4. Highway rest stops and highway service plazas. [2]

In practice, this lands the requirement on larger venues. A stadium, arena, convention center, airport terminal, large theater, department store, or shopping mall will typically exceed the six-fixture threshold. A small theater, a single-tenant retail space, or a modest restaurant generally will not. The correct question on any given project is not whether the occupancy appears on a list, but whether the required fixture count crosses the threshold under the adopted code. [2]

Technical provisions come from Section 613 of ICC A117.1-2017 with Supplement 1, an ANSI-approved standard developed with participation from the U.S. Access Board and incorporated into the IBC in 2024. [4][7] Because the IBC is a model code adopted at the state and local level, implementation timelines vary. The governing requirement on any project is whichever code cycle the authority having jurisdiction has adopted.

Which States and Federal Laws Now Address Adult Changing Stations?

State action predates the model code, and California moved first. Assembly Bill 662, signed October 10, 2015 and effective January 1, 2016, added Health and Safety Code Section 19952.5, requiring at least one adult changing station in a commercial place of public amusement with a maximum occupancy of 2,500 or more. The duty attaches to facilities newly constructed on or after January 1, 2020, and to renovations on or after January 1, 2025 that require a permit or cost $10,000 or more. That renovation trigger is now live. [16]

Minnesota took the building code route and went further on scope. Governor Tim Walz signed the requirement into law on May 24, 2023. The Department of Labor and Industry adopted implementing rules through expedited rulemaking, and the provisions took effect as a supplement to the 2020 Minnesota Accessibility Code on August 15, 2025. [15] The statute originated in advocacy by Minnesota residents who had been changing family members on public restroom floors. [10]

Key Legislative Milestones

1. Minnesota Accessibility Code Section 1109.2.4.1 requires an adult changing station in eight categories. It matches the IBC on assembly and mercantile, post-secondary Group B, and Group E assembly spaces, then goes further: MnDOT rest areas, state park campgrounds, state park visitor centers, hospitals and ambulatory care facilities, and Group B outpatient clinics. The healthcare categories have no counterpart in the IBC model language. [15]
2. The FAA Reauthorization Act of 2024, at 49 U.S.C. 47107(y), requires that beginning in fiscal year 2030, medium and large hub airports applying for airport development grants provide written assurance that they will install or maintain at least one private single room with a universal changing station in each passenger terminal building. The Access Board is developing the design standards for those tables and rooms. [4]
3. The BABIES Act of 2016 requires restrooms in public federal buildings to be equipped with baby changing facilities determined to be safe and sanitary, subject to specified exceptions. It addresses infant changing rather than adult changing, but it established the federal precedent that changing facilities are a restroom requirement rather than an amenity. [12]

The pattern is consistent. Accessible restroom design is being redefined at the code level to include far more than wheelchair clearances, and the standard is still expanding.

The Universal Changing Station: A New Category of Accessible Space

What Is an Adult Changing Table?

An adult changing table, also called a universal changing table, is an adult-sized, height-adjustable surface on which a person with a disability receives assistance from a caregiver with toileting. That assistance may include changing incontinence garments or dressings, managing colostomy bags or catheters, or other personal care. Users include wheelchair users, older adults, and children, teenagers, and adults with developmental disabilities. [4]

How It Differs From a Baby Changing Table

• Structural capacity. ICC A117.1 Section 613.4 requires the materials, fastenings, mounting devices, and support structure to support a user weight of not less than 400 pounds. ASTM F2285, the consumer safety specification for commercial diaper changing tables, covers children weighing less than 50 pounds. [7][11]
• Height adjustability. Section 613.4.3 requires the changing surface to be adjustable from 17 inches minimum to 38 inches maximum above the floor, measured to the top of the surface. [7]
• Room components. Section 613.2.1 requires the room to include a soap dispenser, a hand towel dispenser or hand dryer, a coat hook near the changing surface, a waste receptacle, and signage identifying the room and stating weight capacity and operating instructions. [7]

Who Does It Serve?

The Universal Changing Station serves a broad population whose needs exceed a standard accessible stall.

• People with physical or cognitive disabilities who require assistance with personal care. [4]
• Individuals managing medical equipment such as catheters or ostomy devices. [4][9]
• Older adults facing age-related mobility decline. [13]

Why Does It Need Its Own Room?

A Universal Changing Station does not belong in a traditional multi-user restroom. The changing surface, surrounding clearance, and privacy needs of the user and caregiver require a dedicated single-occupancy space, similar in concept to a gender-neutral or family restroom.

The 2024 IBC and ICC A117.1 both reflect this by specifying location requirements, accessible routes, and required room components for adult changing stations rather than treating them as stall-level modifications. [2][7]

The precedent for this already exists in projects we have supplied. At PENN 2 in New York, a 1.75 million square foot redevelopment above the busiest transportation hub in North America, MdeAS Architects led a full core restroom redesign that upgraded men’s and women’s restrooms on all 32 floors and added gender-neutral restrooms throughout the building. ASI supplied approximately 2,000 Alpaco™ Classic phenolic partitions, phenolic urinal screens, and stainless steel accessories for that scope. Once a facility accepts that some users need a private single-occupancy room rather than a stall, the planning logic for an adult changing room is already in place. The square footage conversation has been had. What changes is what goes inside.

Our Universal Changing Station

We are introducing our Universal Changing Station as part of a broader commitment to inclusive washroom design. We designed it to be specified as part of a dedicated accessible care room rather than appended to an existing restroom layout.

What We Learned Designing It

The first thing we had to accept was that this product could not be designed as an accessory. Our instinct as a washroom manufacturer is to think in terms of components that mount to a wall inside an existing layout. A Universal Changing Station does not work that way. The moment you account for the surface itself, the clearance a caregiver needs to work on both sides, and the space required to transfer someone onto it, you are no longer specifying a fixture. You are specifying a room.

That reframing drove most of the decisions that followed. Height adjustability mattered less as a comfort feature and more as an injury-prevention one, because the transfer is where caregiver injuries are documented to occur. [4][9] Surface material had to hold up to institutional cleaning protocols without becoming cold or clinical, since the people using it are not patients and the room should not feel like a treatment space. Controls had to be operable by someone whose hands are already occupied.

The harder problem was dignity, which does not appear on any specification sheet. A room that is technically adequate but feels like a utility closet still tells the person using it what the building thinks of them. We treated finish quality, lighting, and the coherence of the room with the rest of the facility as functional requirements rather than aesthetic ones.

What Specifiers Ask Us About Adult Changing Rooms

As the code picture has changed, the questions coming to us have changed with it. The most common one is some version of whether an adult changing station can go in the existing restroom. The answer is usually no, and that answer tends to arrive later in a project than it should. These rooms need their own footprint, and finding that square footage is a planning decision, not a fixture selection. Projects that treat it as a fixture discover the problem during layout review, when moving walls is expensive.

The Questions Worth Asking Earlier

• Where does the room go, and is it on an accessible route from the main circulation path?
• Does the door swing and interior clearance still work once a wheelchair and a caregiver are both in the room?
• Is there a place to set down a bag, a coat, or medical supplies, or does everything end up on the floor?
• Does the room read as part of the facility, or does it read as storage that got repurposed?

The second most common question is whether a baby changing table can be substituted. It cannot. Commercial infant changing tables are specified for children under 50 pounds, while the adult changing standard requires a minimum 400-pound structural capacity and adult surface dimensions, so the two products are not interchangeable. [7][11] The third question is about code, and the best answer is that the requirement depends on which code cycle a jurisdiction has adopted and on the required fixture count for the project, so it is worth confirming locally rather than assuming. [2]

Designing Beyond the Stall

Why Does the Washroom Environment Matter Beyond the Partition?

Accessible design does not end at the stall door. The fixtures outside the partition determine whether a person with a disability can use the washroom independently and with dignity.

• Mirrors positioned for both standing and seated users. [6]
• Soap dispensers operable with one hand, without tight grasping, pinching, or twisting of the wrist. [5]
• Paper towel units and hand dryers within accessible reach ranges. [5][6]
• Combination units that consolidate functions and reduce the number of separate wall-mounted obstructions in the circulation path.

How Does Touchless Technology Improve Accessibility?

Touchless operation benefits users with limited hand strength, grip difficulty, or upper extremity disabilities. The 2010 ADA Standards require operable parts to be usable with one hand and without tight grasping, pinching, or twisting of the wrist. Sensor-activated faucets, soap dispensers, and hand dryers remove that demand entirely rather than accommodating it. [5]

In our own specification work, touchless operation has moved from an upgrade line item to a default assumption on new and renovated commercial washrooms. At Nashville International Airport, touchless technology was part of the restroom standard that the Metro Nashville Airport Authority applied across public areas under the BNA Vision program.

Piatto™ and Velare™: Coordinated Accessible Systems

We designed our washroom accessory collections to treat the restroom as a coordinated system rather than a set of individual fixtures. Two collections are especially suited to accessible washroom projects.

Both collections are built around recessed or concealed mounting, for a reason that is easy to miss if you only ever see a washroom empty. Circulation space is what determines how comfortably a room works for someone navigating in a wheelchair, turning with a mobility aid, or guiding another person. Recessing the dispensers keeps the wall plane flat and returns that clearance to the room, which matters most in compact washrooms where every inch of the floor plan is already committed.

Consistency is the second reason. A flush unit sits where the drawing says it sits and stays there, and predictable placement is part of what makes a washroom usable for someone who relies on knowing where things are. Recessed and surface-mounted accessories both have their place, and we build both. The recessed collections are simply the stronger answer when clearance is tight or when the design intent calls for an uninterrupted wall.

The Piatto™ Collection

The Piatto™ Collection features fully recessed washroom accessories that lie flush with the wall plane. We use concealed hardware and phenolic doors to produce a clean, obstruction-free surface.

• Fully recessed paper towel dispensers.
• Recessed waste receptacles and combination units.
• Phenolic doors in matte black or white with concealed hinges.

The Velare™ Collection

The Velare™ Collection is built around our Velare™ Behind the Mirror system, which integrates multiple dispensing functions into a single stainless steel cabinet concealed behind a mirrored door.

• Hands-free automatic soap or foam dispenser built in.
• Choice of paper towel dispenser or high-speed hand dryer with HEPA filter.
• Etched backlit icons, designed to make each dispensing function identifiable at a glance.

Both collections reduce visual clutter in different ways: Piatto™ integrates accessories into the wall plane, while Velare™ conceals dispensing functions behind the mirror. Both are part of ASI’s broader commercial washroom accessory portfolio.

Accessible Design at Every Project Tier

Accessibility should not be a line item that only premium projects can afford. Our range is built so that a specifier can meet the same accessibility objectives whether the project is a flagship headquarters or a municipal facility working against a tight budget.

• Entry and mid-tier projects: durable solid plastic, plastic laminate, and powder-coated options that meet accessibility requirements at scale, suited to schools, recreation centers, and high-traffic public facilities.
• Premium and design-led projects: phenolic, stainless steel, and fully recessed collections such as Piatto™ and Velare™ where finish quality and an uninterrupted wall plane are part of the design intent.
• Across every tier: the same accessibility standards, so the choice is about material, finish, and budget rather than whether the washroom serves everyone who uses it.

Market Outlook

How Fast Is the Accessible Washroom Market Growing?

We were unable to identify a recognized research firm that sizes accessible commercial washroom products as a discrete category, and published estimates vary widely depending on how the category is drawn. The nearest well-documented adjacent measure comes from Grand View Research, which valued the global bathroom and toilet assist devices market at approximately $4.76 billion in 2023 and projected a compound annual growth rate of roughly 7.2 percent through 2030, with North America accounting for about 37 percent of 2023 revenue. [14] We offer that as directional rather than definitive. The demand signals we consider more reliable are demographic and regulatory, and both are documented below.

What Demographic Trends Are Driving Demand?

An aging population is expanding the user base for accessible washroom design.

• 13.7 percent of the total U.S. population had a disability in 2024, the highest share on record. [13]
• Adults aged 75 and older have a disability rate of approximately 45 percent. [13]
• The baby boomer generation is aging into that threshold over the coming decade. [13]

What Does This Mean for Specifiers?

Adult-capable accessible facilities are moving from optional to required across a growing range of occupancy types. As states adopt the 2024 IBC on their own code cycles, the requirement cascades through new construction and qualifying renovations. [2]

From where we sit, the more telling signal is the range of occupancies now asking the question. Large assembly venues, airports, and schools are where adult changing requirements are landing first, and they are the building types where ASI products are already specified. US Bank Stadium sits in a state that wrote adult changing stations into its accessibility code ahead of the model code cycle. That is not a forecast for us. It is a specification question arriving in projects we are already on.

Where ASI Products Are Specified

Those are not hypotheticals. The projects below are published ASI case studies in exactly those occupancy categories. Scope statements describe what ASI supplied. On large projects, Division 10 scope is frequently divided among multiple manufacturers, and these references do not imply sole-supplier status.

This is how a requirement becomes a standard. Code sets a floor and creates a category. Expectation is what moves that category into projects the code never touched. Accessibility beyond the stall is making that transition now, and the specifiers moving first are the ones treating it as a design decision rather than waiting to be told.

Conclusion: Accessibility as a Design Standard

The commercial washroom has long been designed to serve the majority of users efficiently. For millions of Americans with disabilities and their caregivers, that standard approach has left real needs unmet.

Regulation and demographics are closing the gap. The 2024 IBC, Minnesota legislation, and the federal airport requirements taking effect in fiscal year 2030 are bringing adult-capable accessible facilities into mainstream code, while an aging population expands demand. [2][3][4][13]

We approach that shift as a full-washroom manufacturer. Our Universal Changing Station addresses dedicated adult-capable changing spaces, while our Piatto™ and Velare™ collections extend accessible design into the broader washroom. Across stadiums, airports, hospitals, schools, and workplaces, and across every project tier, the objective stays the same: a washroom that serves everyone who uses it, specified as a design decision rather than a stall-level checkbox.

Works Cited

[1] Centers for Disease Control and Prevention. “Disability Impacts All of Us.” Last updated July 15, 2024. https://www.cdc.gov/disability-and-health/articles-documents/disability-impacts-all-of-us-infographic.html

[2] International Code Council. 2024 International Building Code, Section 1110.4, Adult Changing Stations. https://codes.iccsafe.org/s/IBC2024P1/chapter-11-accessibility/IBC2024P1-Ch11-Sec1110.4

[3] Changing Spaces Campaign, Minnesota Chapter. “Minnesota.” https://www.changingspacescampaign.com/minnesota

[4] U.S. Access Board. “Accessibility Standards for Universal Changing Stations.” Advance Notice of Proposed Rulemaking, 91 FR 7412, February 18, 2026. Docket ATBCB-2026-0001. https://www.federalregister.gov/documents/2026/02/18/2026-03199/accessibility-standards-for-universal-changing-stations

[5] U.S. Department of Justice. “2010 ADA Standards for Accessible Design.” ADA.gov. See §§306, 308, 309, 604, 606, 609. https://www.ada.gov/assets/pdfs/2010-design-standards.pdf

[6] U.S. Access Board. “Guide to the ADA Standards, Chapter 6: Toilet Rooms.” https://www.access-board.gov/ada/guides/chapter-6-toilet-rooms/

[7] International Code Council. ICC A117.1-2017 with Supplement 1, Standard for Accessible and Usable Buildings and Facilities, Section 613, Adult Changing Stations. https://codes.iccsafe.org/content/ICCA117.12017P7/icc-a117-1-2017-with-supplement-1-standard-for-accessible-and-usable-buildings-and-facilities

[8] Changing Spaces Campaign. “About the Campaign.” https://www.changingspacescampaign.com/

[9] Treiman, G., Cheng, M., Oswald, M. “This is not built for me.” Disability and Health Journal, January 2024. https://pubmed.ncbi.nlm.nih.gov/37714764/

[10] CBS Minnesota. “Minnesota Woman Leads Charge on New Law Requiring Adult Changing Tables in U.S. Airports.” May 2024. https://www.cbsnews.com/minnesota/news/minnesota-woman-new-law-requiring-adult-changing-tables-us-airports/

[11] ASTM International. ASTM F2285-22, Standard Consumer Safety Performance Specification for Diaper Changing Tables for Commercial Use. https://store.astm.org/f2285-22.html

[12] Bathrooms Accessible in Every Situation Act (BABIES Act), Pub. L. No. 114-235, 40 U.S.C. § 3314, October 7, 2016. U.S. Government Publishing Office. https://www.govinfo.gov/content/pkg/PLAW-114publ235/html/PLAW-114publ235.htm

[13] USAFacts. “How Many People Have a Disability in the US?” 2024. https://usafacts.org/answers/how-many-people-have-a-disability/country/united-states/

[14] Grand View Research. “Bathroom And Toilet Assist Devices Market Size Report, 2030.” https://www.grandviewresearch.com/industry-analysis/bathroom-toilet-assist-devices-market

[15] Minnesota Department of Labor and Industry. “Adult-sized changing facilities in new building construction,” and Supplement to the 2020 Minnesota Accessibility Code, effective Aug. 15, 2025. https://www.dli.mn.gov/business/codes-and-laws/adult-sized-changing-facilities-new-building-construction

[16] California Assembly Bill 662 (Bonilla), Stats. 2015, Ch. 742, adding Health and Safety Code § 19952.5. Approved October 10, 2015; effective January 1, 2016. California Legislative Information. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201520160AB662