Updated October 2026. This replaces the 2020 checklist; verify current agency directions before relying on an old form or deadline.
Passenger accessibility is not one checklist for every fleet. Your obligations depend on the service you provide, the vehicles you use, and whether you operate fixed-route or demand-responsive trips. Start by separating three jobs: service to passengers, treatment of employees and applicants, and accessibility of your website.
1. Match the passenger-service rule to your operation
For transportation service, start with 49 CFR Part 37. Over-the-road bus operators should also read FMCSA’s OTRB overview and the applicable provisions of Subpart H. Do not apply a fixed-route bus rule or a 48-hour demand-responsive rule to every sedan, limousine, or bus trip without checking the operator and service category.
Give dispatchers and chauffeurs a workable process for accessibility requests: record what the passenger needs, identify a suitable vehicle and trained staff, communicate the arrangement, and document any request that cannot be met. Train staff on equipment and passenger assistance under the rule that applies to the service. Our OTRB ADA guide goes deeper into fixed-route versus demand-responsive service and the related records.
2. Keep employment and website questions separate
Employment accommodations are a different ADA lane from passenger service. EEOC guidance explains Title I coverage for employers with 15 or more employees and the accommodation process for applicants and employees. State or local requirements may also apply.
For the customer-facing website, review the U.S. Department of Justice’s web accessibility guidance. A readable request path and accessible booking flow matter alongside the vehicle and staff process.
3. Verify reports and forms before filing
This page previously listed 2020-era OTRB forms, a mailing address, and a blanket October filing date. Do not use those as current filing instructions. Check FMCSA’s current OTRB page and the applicable regulation for the report, collection status, deadline, and submission method that fit your operation. Keep your service-request, training, and equipment records organized while you confirm the current agency directions.
If your carrier needs help organizing its own compliance records and responsibilities, see LBC Fleet’s compliance services. LBC can help with the administrative process; the carrier must still determine its own legal applicability and service decisions.
