Restaurant and hotel websites: menus, booking and the ADA
Image menus, online ordering, the hotel reservations rule, and the pixels on booking flows that wiretap suits target.
Key takeaways
- Restaurants were the largest category of website accessibility suits in 2025, and image menus are a classic target.
- Hotels must describe accessible rooms online, even through a third-party booking engine.
Why restaurants top the list
EcomBack's 2025 report (opens in a new tab) put restaurants, food and drinks at 1,368 of 3,948 suits. Under *Robles v. Domino's* (2019), a site that takes orders or reservations connects customers to the restaurant, so assume yours is covered.
The image menu problem
In *Thurston v. Midvale* (opens in a new tab) (2019), a blind plaintiff couldn't read a lounge's image menu and its PDF link failed. A California appeals court affirmed judgment for her and an order to meet WCAG 2.0.
Hotels: the reservations rule
28 CFR 36.302(e) (opens in a new tab) requires reservations made by any means, third parties included, to:
- book accessible rooms the same way as other rooms;
- describe accessible features in enough detail for a guest to judge them;
- hold accessible rooms until other rooms of that type are rented, and block booked ones across all channels.
*Acheson Hotels v. Laufer*, a tester case over this rule, ended as moot in 2023.
Pixels on reservation and ordering flows
SB 690 leaves Section 631 wiretap claims (opens in a new tab) over pixels on booking and ordering pages at $5,000 per violation.
A checklist for this month
- Add alt text to dish, room and venue photos.
- Test ordering and booking with a keyboard.
- Hold booking and ordering pixels until a guest agrees.
ComplyMo holds the pixels and audits every page on Growth and up, but can't make a third-party booking engine describe your rooms. See ComplyMo for restaurants and hotels.
General information, not legal advice. Confirm your obligations with counsel.