ADA Compliance for Restaurant Websites

Restaurants are the second-most targeted industry in ADA web litigation, behind only general ecommerce. The category took off in 2019 when the Supreme Court declined to hear Domino's appeal in Robles v. Domino's, cementing the rule that restaurant websites and apps used to transact with customers fall under Title III. Online ordering is now the single largest source of restaurant ADA cases, followed by inaccessible PDF menus and reservation systems. This guide covers what plaintiffs cite, what the major ordering platforms get wrong, and what realistic remediation looks like for independent restaurants and chains.

This page is informational and is not legal advice. ADA, federal regulations, and state-law obligations vary by jurisdiction and business type — consult qualified counsel for case-specific guidance.

How Robles v. Domino's changed the rules

Guillermo Robles, a blind Domino's customer, sued the company in 2016 because his screen reader could not navigate their website or mobile app to place an order. The Ninth Circuit ruled in 2019 that Title III of the ADA applied to Domino's digital ordering channels because they had a sufficient nexus to the company's physical pizza restaurants. Domino's petitioned the Supreme Court for review, asking the Court to clarify whether websites are covered by the ADA. The Court denied cert, leaving the Ninth Circuit ruling in place and signaling to lower courts across the country that website accessibility for businesses with physical locations is a settled question.

The practical effect: any restaurant with a physical location that maintains a website used for ordering, reservations, menu viewing, gift card purchases, or any other transaction is squarely within Title III. Chains, franchisees, independent restaurants, and ghost kitchens with delivery- only operations have all been sued under this theory.

Online ordering: where most cases originate

Online ordering creates ADA exposure in two ways. First, restaurants that build their own online ordering on their domain are responsible for that site's accessibility. Second, restaurants that use third-party platforms — Toast, Square Online, ChowNow, BentoBox, Olo, Lunchbox — inherit that platform's accessibility, which varies dramatically in quality.

Toast Online Ordering has improved its accessibility significantly since 2022 but still has documented gaps in modifier selection (the screens where customers add toppings, sides, or specials) and in cart management when promotional codes are applied.

Square Online is reasonably accessible on its default templates but breaks frequently when restaurants embed it within their existing website using iframe or JavaScript embeds, because those embeds rarely propagate accessibility events correctly.

BentoBox and ChowNow have native ordering interfaces with mixed accessibility. Both vendors publish VPATs but field testing routinely surfaces missing form labels, inaccessible modifier dialogs, and contrast failures on cart totals and disclaimers.

Third-party marketplaces — DoorDash, Uber Eats, Grubhub — are generally not the restaurant's legal exposure when customers order through the marketplace directly. However, restaurants that link to these platforms from their own site can still face complaints if their site itself is inaccessible.

The PDF menu problem

Approximately 60-70 percent of restaurant websites still link to a PDF menu rather than presenting menu content as HTML. Almost none of those PDFs are accessible. The most common formats:

• Scanned image of a printed menu — completely inaccessible to screen readers; text appears as image data only.
• Photo of a chalkboard or menu sign — same problem, plus decorative styling that is hostile even to OCR.
• Designer-created PDF in InDesign — has text, but the underlying tag structure is missing or scrambled because graphic designers prioritize visual layout over reading order.
• Word document exported to PDF — generally has text but lacks proper heading structure, alt text on photos, and language identification.

The fix is straightforward in principle: present menu content as HTML on the page, using proper heading structure for menu sections, descriptive markup for each menu item, and properly labeled price elements. If a designed PDF must remain available (for printing or for visual brand reasons), it can be tagged in Adobe Acrobat Pro to add reading order, alt text, and structure — but a real HTML version on the site itself is the standard plaintiffs and HHS look for.

Reservation systems: OpenTable, Resy, Tock, SevenRooms

Reservation widgets are the third major category of restaurant ADA exposure. Restaurants embed these widgets on their own sites, so the restaurant inherits whatever accessibility issues the widget has.

OpenTable has the best track record of the major platforms; their widget passes most automated scans and supports keyboard navigation. The most common issue is color contrast on availability tiles and disabled time slots.

Resy has improved significantly but still has documented issues with date picker keyboard navigation and with announcing waitlist status to screen readers.

Tock and SevenRooms tend to have more issues, particularly around prepaid reservations and multi-step booking flows. Both publish VPATs and are actively improving.

If your reservation widget has known issues your vendor cannot or will not fix on your timeline, the practical mitigation is to provide a fully accessible alternative — typically a phone number prominently displayed near the widget — and an accessible contact form that lets a customer request a reservation in writing.

Specific failures restaurant plaintiffs cite

The pattern in restaurant demand letters is consistent enough to predict. The list below covers what shows up in roughly nine out of ten restaurant complaints:

1. Menu PDFs that are scanned images or untagged, making menu content invisible to screen readers.
2. Online ordering modifier dialogs (extra cheese, side choices, dietary modifications) that lack proper labeling and keyboard support.
3. Reservation date pickers and time selectors that are not keyboard-operable.
4. Photo galleries of food and the dining room without alt text describing the images.
5. Hours of operation displayed in low-contrast text on dark hero images.
6. Contact forms with missing labels and inaccessible CAPTCHA challenges.
7. Allergen and ingredient information presented as graphics rather than text.
8. Inaccessible age-verification gates on alcohol-serving establishments.
9. Gift card purchase flows with the same checkout-form issues that drive ecommerce cases.
10. Auto-playing video backgrounds on restaurant homepages that have no pause control (WCAG 2.2.2).

Cost and timeline reality for restaurants

Independent restaurants typically face less complex remediation than ecommerce stores because the site structure is smaller. The main work is converting menus to HTML, fixing the photo gallery alt text, addressing form labeling on contact and reservation pages, and verifying that any embedded ordering or reservation widget works with assistive technology.

Realistic cost ranges:

Specific guidance for franchisees

Franchise restaurants face a peculiar accessibility problem. The franchisor typically controls the brand website and the online ordering system, but the franchisee owns the legal entity that gets sued. Franchisees have been named directly in ADA cases even when the inaccessible component is controlled at the corporate level.

If you operate a franchise, your protection comes from three things: a franchise agreement that requires the franchisor to provide accessible digital infrastructure, documentation of any accessibility concerns you have raised with the franchisor, and an accessible local site for any content you control directly (location pages, your own contact information, any independent gift card or event booking systems).

What to do today

If your menu is a PDF, start there. Convert it to HTML this week — even a basic version on a /menu page that mirrors the PDF content will eliminate the single most common restaurant ADA complaint. Then audit your ordering and reservation flows by trying to complete a full transaction using only your keyboard. If you cannot do it, neither can a screen reader user, and that is the scenario plaintiff attorneys look for.