A Texas build-out with an estimated construction cost of $50,000 or more has to be registered with the Texas Department of Licensing and Regulation (TDLR) through its TABS system, reviewed by a Registered Accessibility Specialist (RAS) against the Texas Accessibility Standards, and inspected by a RAS within one year of completion. The filing fee is $175. The city will not accept the building permit application until the registration is verified, so registration belongs at the start of the project, not the end. Below $50,000 the work still has to comply with the standards; it just does not have to be registered.
What is TABS?
Texas has its own accessibility law for buildings, the architectural barriers law in Chapter 469 of the Texas Government Code, and its own standard, the 2012 Texas Accessibility Standards (TAS), which TDLR's rules still adopt as the edition in force. TABS is TDLR's online system for registering projects under that law and tracking their review and inspection.
Every registered project becomes a public record. Anyone can look it up on TDLR's TABS project search by project, owner, city, design firm or RAS, which is why TABS records turn up when you search for a contractor or a build-out in your city. A record there means a project was registered. It says nothing about who built it well.
When does a build-out have to be registered?
When the estimated construction cost is $50,000 or more, for a privately owned building used as a public accommodation or a commercial facility. Offices, retail, restaurants, medical and salon suites all fall in that group. TDLR's rules leave land, architect and engineer fees, furniture, and equipment that is not part of the building's mechanical, electrical or plumbing systems out of the estimated cost, so the number that matters is the construction scope, not the whole project budget.
Under $50,000, registration is optional, but compliance is not. TDLR's FAQ is plain that a smaller project is still required to comply with TAS. A $8,000 to $12,000 each restroom refresh that does not move a fixture and a $18,000 to $30,000 each single-user ADA restroom are very different scopes for exactly that reason.
Who registers the project, and when?
- The owner is responsible, and TDLR's rules define the owner as whoever holds title to the property. In a leased suite that is usually the landlord, though a tenant can act through TDLR's designated agent form, and TABS lets owners, agents, designers and tenants enter a project
- When an architect or engineer prepares the construction documents, the design professional submits them for review within 20 days of issuing them, not counting weekends and holidays
- The owner may not allow a building permit application to be filed, or construction to begin, before the plans are submitted
- The filing fee is $175, on TDLR's fee schedule. A project registered after construction is already complete is a late filing, at $300
The practical rule for a tenant: settle in the lease and in the design contract who registers the project and who hires the RAS, before drawings go out for permit. A registration nobody owned is a permit application the city cannot accept.
What is the difference between RAS plan review and RAS inspection?
A Registered Accessibility Specialist is licensed by TDLR to review and inspect projects against TAS. The RAS does the job twice:
- 1.Plan review, before construction. The RAS reviews the construction documents and reports what does not meet TAS, so the drawings can be corrected while changes are only lines on paper
- 2.Inspection, after construction. The owner has to get the project inspected by a RAS no later than one year after completion, which TDLR's rules define as occupancy or the issuance of a certificate of occupancy
If the inspection finds deficiencies, the owner responds within 30 days and completes the corrections by the 270th day after the inspection report. RAS fees are set by each RAS and paid privately, not to TDLR, so get them quoted when you hire one.
The most common problem is not a grab bar. In TDLR's own complaint statistics for fiscal 2025, an owner failing to have the project inspected within one year accounted for 100 of the 142 alleged violations at case opening. Put the inspection on the closeout schedule the day the space opens.
Written Scope
Planning this type of project?
Tell us your space, city, and timeline. We return a written scope with lump-sum pricing, no obligation.
What commonly fails a TAS inspection?
Not the big-ticket items, usually. Accessibility deficiencies in a build-out tend to be small, dimension-driven and easy to get wrong in the field when nobody is checking against the drawings. TDLR's help sheet for subcontractors focuses on exactly these: objects that protrude into a path, operable parts like handles and controls, reach ranges, and where accessories such as toilet paper dispensers are mounted. On a typical suite the places to watch are:
- Restrooms: clear floor space at the fixtures, grab bars, lavatory and mirror heights, and where every accessory is mounted
- Doors: hardware that can be operated without tight grasping or twisting, clear width, and maneuvering clearance on both sides
- Counters: a section of reception, sales and service counters at an accessible height
- The accessible route: changes in level at thresholds and transitions, protruding objects, and a route that stays clear once furniture arrives
- Signage and controls: room signs where they are required, and switches, thermostats and dispensers within reach
Restrooms are where the money is. When a layout change means a restroom has to be rebuilt to the standard, it is a $18,000 to $30,000 each line on our card, and the restrooms in our Longview state office project were rebuilt with accessible stall layouts for that reason.
How does TABS fit with the city permit and certificate of occupancy?
They are separate tracks that touch at two points. At the start, state law ties registration to the permit: the building official may not accept a permit application for a covered project until the registration is verified. At the end, the city issues the certificate of occupancy after its own inspections, and the RAS inspection is a separate state obligation due within a year of completion. We have not found a state rule that makes the RAS inspection a condition of the city's certificate of occupancy, so ask your building official how your city handles it rather than assuming either way.
The certificate of occupancy guide covers the city's side of closeout, and the permit timeline guide covers review times.
A TABS checklist for a DFW build-out
- 1.Estimate the construction cost early. At $50,000 or more, the project is registered
- 2.Decide in writing who registers the project, who pays the filing fee and who hires the RAS: landlord, tenant or design professional
- 3.Register and submit the construction documents for RAS review before the permit application is filed
- 4.Build the RAS review comments into the drawings before bidding, not as field changes
- 5.Check the accessibility details during construction, not after: mounting heights, clearances and hardware
- 6.Book the RAS inspection as part of closeout, within a year of occupancy or the certificate of occupancy
- 7.Respond to any inspection report within 30 days and finish corrections by day 270
Planning a build-out over the threshold?
We build to the RAS-reviewed drawings and schedule the accessibility items so they are right the first time. Call (469) 721-0146, or see what a tenant improvement costs.
Frequently Asked Questions
Common questions about this topic from DFW tenants, landlords, and business owners.
Does my build-out need TABS?
If the estimated construction cost is $50,000 or more and the space is a commercial facility or public accommodation, yes. That covers most office, retail, restaurant, medical and salon build-outs over the threshold. Land, design fees, furniture and equipment that is not part of the building systems are left out of the estimate.
Who pays the RAS?
Whoever the lease and contracts say. The owner is responsible for registration and inspection under TDLR's rules, and the RAS sets and collects its own fees, separate from TDLR's $175 filing fee. In a leased suite, decide who carries both before drawings go out.
Can I get a CO before the RAS inspection?
The two are separate. TDLR's rules start the one-year inspection clock at occupancy or the issuance of a certificate of occupancy, so the inspection commonly comes after the CO. We found no state rule that holds the CO for it, but cities run their own closeout, so confirm with your building official.
What if we're under $50,000?
Then registration is optional, but the work still has to comply with the Texas Accessibility Standards. A project can be registered voluntarily. Make sure the estimate is honest, because a scope that grows past $50,000 during design needs to be registered before the permit application is filed.
About the author
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General contractor, Royse City, TX
Commercial tenant improvement, build-out and renovation, and residential outdoor living, fencing, additions and high-end kitchens and baths across Dallas-Fort Worth and East Texas.