If you own or manage commercial property in Texas, accessible parking isn't only a federal ADA matter. It's enforced at the state level by the Texas Department of Licensing and Regulation, and the requirements live in two separate places. That split is the single biggest reason lots fail an inspection, because almost everybody satisfies one and never hears about the other.

The two rules, and why the second one catches people

The Texas Accessibility Standards — TAS — cover the things most people picture when they think about accessible parking: how many spaces you need, how wide they are, the access aisle beside them, and the identification sign. Under TAS 502.6, that sign has to carry the International Symbol of Accessibility.

Then there's a second instrument. TDLR administrative rule 16 TAC §68.104 took effect August 1, 2020, implementing House Bill 3163 from the 2019 legislative session. It adds requirements that live on the pavement rather than on a post — and it applies in addition to everything TAS already required.

What §68.104 adds

Three things, and they're the ones we most often show up to fix:

• The accessibility symbol, painted on the surface. Not on a sign — on the pavement of the space itself, in a color that contrasts the pavement. The rule's word is "conspicuously."
• "NO PARKING" in the access aisle. All capital letters, at least 12 inches tall, with a minimum 2-inch stroke width, centered in the aisle. This one is specified precisely, which means it's easy to get wrong and easy for an inspector to measure.
• A sign stating the consequences of parking illegally. Commonly the "Violators Subject to Fine and Towing" plate, mounted with the identification sign.

Notice what isn't specified: the rule gives no dimension for the painted symbol. It has to be conspicuous and contrasting, and that's it. Contractors typically run 39-inch or 42-inch stencils because that's convention, not because a number is written down. If somebody tells you there's a legally required symbol size in Texas, ask them to show you where.

The counts and dimensions TAS still governs

None of the above replaces the layout requirements. The ones that come up on nearly every lot we walk:

• One accessible space per 25 total spaces for your first 100 spaces. Lots above 100 follow a reduced ratio.
• At least one in every six accessible spaces must be van-accessible.
• Van spaces: 132 inches wide minimum with an adjacent access aisle at least 60 inches wide — or 96 inches wide if the access aisle beside it is also 96 inches.
• Access aisles serving car and van spaces: 60 inches wide minimum.

TAS also says access aisles must be "marked so as to discourage parking in them," but — and this is the part that confuses people — TAS itself doesn't specify the method or color. Its own advisory notes that those may be addressed by state or local rules. In Texas, §68.104 is what fills that gap with the 12-inch lettering spec.

Who this actually applies to

Rule 68.104 applies to projects registered with TDLR on or after August 1, 2020. If you're paving a new lot, reconfiguring an existing one, or doing work that triggers registration, you're in scope.

That's a real limit and I'm not going to overstate it. If you have an older lot that hasn't had registered work done, your obligations are a different conversation — one that involves federal ADA barrier removal and, often, your local jurisdiction. What I'd say honestly is this: the markings are cheap relative to a complaint, and "we were grandfathered" is a harder argument to make after somebody has already filed something.

What we actually find on lots

Four things, over and over:

• Sign present, pavement blank. The most common one by a wide margin. Somebody replaced a sign at some point and nobody repainted the ground.
• Access aisle striped but unlabeled. Diagonal hatching, no "NO PARKING" text — or text far under 12 inches.
• Symbol faded past recognition. Paint doesn't have to be gone to be a problem. It has to be legible to count.
• Van space that isn't one. The space is marked accessible but the aisle beside it was never widened, so the lot has zero compliant van spaces.

Straight answer about what we do and don't do

We stripe to these standards, and we'll walk your lot and tell you plainly where it stands. But we're a striping contractor, not a Registered Accessibility Specialist. If your project legally requires a TAS plan review or a formal inspection, you need an RAS — and we'll tell you that rather than take the job and let you find out later.

What we're good for: telling you today whether your markings would hold up, and putting them right in a single visit if they wouldn't.