The ABA Accessibility Standards apply to facilities designed, built, altered, or leased with federal funds, and they are set by four standard-setting agencies from the Access Board’s guidelines: the Access Board says GSA, DoD, and USPS have adopted the current edition, while HUD still applies the Uniform Federal Accessibility Standards (UFAS) to residential facilities under its jurisdiction. To review a set, confirm which agency’s adoption governs and through what document (GSA’s Core Building Standards, DoD’s policy memorandum and UFC criteria, or 39 CFR part 254 for USPS), whether the work is new construction, an addition, an alteration, or a lease, and then trace the ABA scoping in chapters 1 and 2, not the ADA scoping, into the plans, schedules, and details. AI can flag conflicts; the design team and the standard-setting agency decide compliance.
What do the ABA Standards cover?
The Access Board’s ABA page says the standards apply to facilities designed, built, altered, or leased with federal funds, including federal buildings such as post offices, courthouses, and prisons and national parks, and non-federal facilities such as public housing and mass transit built or altered with federal grants or loans. ABA chapters 1 and 2 hold the application and scoping provisions, numbered with an F prefix, and chapters 3 through 10 hold technical requirements shared with the ADA Standards. Scoping covers newly designed and constructed buildings and altered or leased portions of existing ones, and the ABA has its own provisions for leases. The ABA does not permit equivalent facilitation; under F103 a deviation needs a modification or waiver from GSA, HUD, DoD, or USPS on a determination that it is clearly necessary.
The ABA page, checked October 22, 2026, lists the adoptions: USPS on May 17, 2005, GSA on November 8, 2005, and DoD on October 31, 2008 through the DoD policy memorandum, which adopts ABA chapters 1 and 2 and chapters 3 through 10 with DoD special provisions in its attachment. It also notes that GSA adopted PROWAG on July 3, 2024, and that on September 21, 2026 GSA moved ABAAS from the CFR to its Core Building Standards. GSA’s Core Building Standards page links the 2026 PBS Core Building Standards memorandum, dated September 21, 2026, which applies to PBS projects awarded on or after October 1, 2026 and lists ABAAS and 36 CFR part 1190 as adopted by GSA. The eCFR’s 39 CFR part 254, current to October 20, 2026, adopts the ABA chapters verbatim except the advisory notes and defines customer lobbies and workroom areas as USPS primary function areas for alterations. HUD has not adopted this edition.
An ABA project may also carry Section 504, the ADA, or the adopted building code, so record each obligation separately. Compare the 2010 ADA Standards guide, the ICC A117.1 guide, and, for DoD work, the UFC 1-200-01 guide. Pedestrian facilities in the public right-of-way on GSA projects follow PROWAG.
Gather the funding, lease, and scope record with the drawings
Collect the contract or task order that names the accessibility criteria, the agency criteria it invokes (GSA’s Core Building Standards and P100, the DoD policy memorandum and the UFCs the contract cites, or USPS standards), the code analysis, the site plan and accessible route plan, floor plans, enlarged toilet, kitchen, and lodging or housing plans, interior elevations, door, hardware, fixture, and accessory schedules, signage drawings, and the specifications.
For an alteration or a lease, add the existing conditions, the area of work, and the lease terms, and record any modification or waiver the agency has granted, because the drawings cannot show those decisions.
Trace the ABA scoping through the set
| Review question | Sources to compare | Decision to record |
|---|---|---|
| Coverage and agency | Contract or task order, owner and funding information, code analysis | Record why the ABA applies, which standard-setting agency’s adoption governs, and whether the ADA or a building code also applies. |
| Standard cited | General notes, code analysis, specifications, agency criteria | Flag notes that cite only the ADA Standards, UFAS on a project whose agency has adopted the ABA Standards, or the reverse. |
| New, addition, alteration, or lease | Scope of work, existing conditions, lease documents | Define the work type, the altered or leased area, and any route to it the ABA scoping reaches. |
| Scoping differences | Code analysis, accessible unit and room lists, enlarged plans | Check that rooms, units, and elements counted toward the scoping follow ABA chapter 2, not the ADA chapter, and that each has an enlarged plan. |
| Agency special provisions | DoD memorandum attachment, GSA criteria, USPS rule, drawings | List the agency provisions that apply, such as DoD special provisions or USPS primary function areas, and where the drawings address each. |
| Deviations | Notes, narratives, waiver or modification records | Flag any deviation the drawings rely on that has no modification or waiver from the standard-setting agency on record. |
Routes and elements continue in the accessibility checklist, alteration routes in the path-of-travel corrections guide, toilet rooms in the accessible toilet room corrections guide, openings in the door schedule checklist, and DoD interiors in the UFC 3-120-10 interior design guide.
Example: a leased federal office drawn to the ADA scoping
Hypothetical example. A build-to-suit lease for a federal agency office shows an accessibility code analysis that cites only the 2010 ADA Standards and counts accessible elements by the ADA scoping. The lease documents require the ABA Standards, the enlarged toilet plans and the accessory schedule disagree on one accessible toilet room, and a general note relies on an equivalent design for a service counter with no waiver on record.
The code analysis cites only the 2010 ADA Standards and its ADA scoping for a leased federal space whose lease requires the ABA Standards, one accessible toilet room differs between the enlarged plan and the accessory schedule, and the service counter note relies on an equivalent design with no modification or waiver on record. Confirm the governing standard and agency criteria, and coordinate the analysis, plans, and schedules.
The architect revises the code analysis to the ABA scoping and coordinates the sheets, and the agency decides whether to grant a modification for the counter. The finding is a document gap; compliance rests with the design team and the agency.
Review ABA projects with Groundbook
Upload the current drawings and specifications to Groundbook, and state the edition, amendments, and review scope in your instructions. The ABA Standards, the DoD policy memorandum, and 39 CFR part 254 are free federal publications from the Access Board and the eCFR, and GSA publishes its Core Building Standards free: upload the ones the contract invokes, plus any licensed codes the project also uses. See how Groundbook works with local and licensed codes.
Compare the contract accessibility criteria, code analysis, general notes, site and accessible route plans, floor plans, enlarged toilet, kitchen, and unit plans, interior elevations, door, hardware, fixture, and accessory schedules, signage drawings, specifications, and lease or alteration scope documents. Flag a code analysis that cites the ADA Standards or UFAS where the governing agency has adopted the ABA Standards, scoping counted by the ADA chapter rather than ABA chapter 2, altered or leased areas with no defined route, agency special provisions the drawings do not address, elements that differ between plans, elevations, and schedules, and deviations with no modification or waiver on record. Use the supplied ABA Standards and agency criteria and cite both sources.
Groundbook links each potential finding to the sheets and documents involved. It does not determine ABA coverage, grant or evaluate waivers, or measure field conditions.
Document review does not certify ABA, ADA, or Section 504 compliance, and it does not replace the design team, the standard-setting agency, or the Access Board’s complaint process.