Accessibility · October 11, 2026 · 4 min read

Accessibility in a California tenant improvement: the path-of-travel rule.

When you remodel a commercial space in California, the route that serves it usually has to be made accessible too. How the 20% rule works, and the 2026 valuation threshold of $209,208.

Article

By the Builteck team

Many owners and tenants are surprised to learn that a tenant improvement in California can require accessibility upgrades outside the area being remodeled. The requirement comes from the California Building Code, Chapter 11B, Section 11B-202.4, and it is often called the path-of-travel rule.

What is the path of travel?

The path of travel is the route a person with a disability uses to reach and use the altered area. It includes a primary entrance to the building, the accessible route to the altered area, and the restrooms, drinking fountains, public telephones and signs that serve it.

The valuation threshold and the 20% rule

Each year the Division of the State Architect publishes a valuation threshold. For 2026 it is $209,208.

  • At or below the threshold: the cost of path-of-travel upgrades can be limited to 20% of the adjusted construction cost of the project.
  • Above the threshold: the path of travel must be brought fully into compliance. A building department may accept an unreasonable-hardship request, but the decision is theirs.

The order of priority

When the 20% limit applies, the money is spent in a set order, so the most important barriers are removed first:

  • An accessible entrance
  • An accessible route to the altered area
  • At least one accessible restroom for each sex, or a single unisex restroom
  • Accessible telephones
  • Accessible drinking fountains
  • Other elements, such as parking, signs and storage

Why it matters early

Path-of-travel work can change a budget and a schedule, especially in older buildings. Meeting the building code also does not protect an owner from claims under the federal ADA or California’s Unruh Act if barriers remain. A survey by a Certified Access Specialist (CASp) before design gives the clearest picture of what the space needs.

Our in-house architect and engineers check path-of-travel scope during preconstruction, before it can surprise a budget. Request a bid to have your space reviewed.

This article is a general summary, not legal advice. Our architect reviews accessibility on every Builteck tenant improvement, and we coordinate CASp inspections when a project needs one.

Sources

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