Hello!

I have a question about older two-story office buildings that were built before the ADA and do not have an accessible route to the second floor.

In many of these buildings, the second floor consists mostly of private offices that aren’t considered places of public accommodation. But what if a tenant—like an accountant—operates mainly as an office but occasionally meets with clients upstairs? That would technically make it a place of public accommodation, right?

If the building owner has a fully accessible office or conference room available on the first floor for use by any tenant, would it be considered an acceptable accommodation under the ADA for that accountant to meet clients there, rather than making the second floor accessible? And, if so, would it need to be the area they meet all clients or just clients who need an accessible route to meet?

Thanks in advance for any insights!