In Texas, a commercial building with an estimated construction cost of $50,000 or more has its plans registered with the Texas Department of Licensing and Regulation for accessibility review. The Texas Accessibility Standards then set how many storage units must be accessible, by a table written for self-service storage.
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Filing is also a gate: a city may not accept the building permit application until the project is registered.
Step 5 of 10: TDLR review
- 01 Land and zoning
- 02 Special use permit
- 03 Plat
- 04 Site plan
- 05 TDLR review
- 06 Aquifer plan
- 07 Stormwater
- 08 Driveway access
- 09 Building permit
- 10 Occupancy
A local official may not accept a building permit application for a covered project of $50,000 or more unless the official verifies it is registered with TDLR. Registration, not approval, is what opens the permit desk.
SourceTexas Legislature, Government Code Chapter 469, Sec. 469.102(c) and (d), read 2026-09-23.
Does a self storage facility have to register with TDLR?
Yes, where the estimated construction cost is $50,000 or more. Government Code Chapter 469 reaches privately funded buildings that the federal Americans with Disabilities Act treats as a public accommodation or a commercial facility, and the ADA defines a commercial facility as any facility intended for nonresidential use whose operations affect commerce. At that cost, the plans go to TDLR for review and approval.
Under $50,000, TDLR says the project is not registered or reviewed but still has to comply with the Texas Accessibility Standards. A small addition at an existing facility can fall under the line.
SourcesTexas Legislature, Government Code Chapter 469, read 2026-09-23; Office of the Law Revision Counsel, U.S. House of Representatives, United States Code, 42 U.S.C. 12181 Definitions, read 2026-09-23; Texas Department of Licensing and Regulation, Architectural Barriers Frequently Asked Questions, read 2026-09-23.
Who files, and when?
The design professional, not the owner. The architect, interior designer, landscape architect or engineer with overall design responsibility submits the plans no later than the 20th business day after issuing them, and each separate issue date starts its own clock.
The owner carries the other end. The owner may not apply for a local building permit or start construction until the plans have been submitted, and shows the permit office proof of submission. Within one year after construction is complete, the owner has the building inspected by TDLR, a TDLR contract entity or a Registered Accessibility Specialist.
SourceTexas Legislature, Government Code Chapter 469, read 2026-09-23.
How many storage units have to be accessible?
Texas Accessibility Standards section 225.3 answers it with a table written for self-service storage, the same table as the federal 2010 ADA Standards. Accessible units are spread across the classes of units offered, but the count never has to exceed the table, and a facility with several buildings does not have to put accessible units in every building. TDLR has published no technical memo about self-service storage facilities or TAS 225.3.
The accessible units also have to connect to the rest of the accessible site: TAS says they must connect to accessible routes, accessible means of egress and accessible parking, and that any public or common-use toilet rooms, drinking fountains and telephones must comply.
Exhibit AAccessible storage spaces required, TAS 225.3
| Total spaces in the facility | Accessible spaces required |
|---|---|
| 1 to 200 | 5 percent, at least 1 |
| 201 and over | 10, plus 2 percent of spaces over 200 |
SourcesTexas Department of Licensing and Regulation, 2012 Texas Accessibility Standards, Chapter 2 Scoping Requirements, Section 225.3, read 2026-09-23; Texas Department of Licensing and Regulation, 2012 Texas Accessibility Standards, Chapter 1 (106.5.58) and Chapter 2 (206.4.5 exception, Advisory 225.3), read 2026-09-23; U.S. Department of Justice, ada.gov, 2010 ADA Standards for Accessible Design, read 2026-09-23; TDLR's technical memo list was read; none covers self storage. Texas Department of Licensing and Regulation, Architectural Barriers Technical Memoranda (index) and TM 2013-23, read 2026-09-23.
What does TDLR charge?
TDLR publishes a $175 project filing fee, a $300 late filing fee for a project registered after construction is complete, and $215 an hour, one hour minimum, for special review or inspection. Plan review and inspection fees are based on the estimated construction cost, excluding site acquisition, furnishings and equipment that is not part of the building's mechanical systems. All fees are nonrefundable.
SourceTexas Department of Licensing and Regulation, Architectural Barriers Fee Schedule, read 2026-09-23.
Questions about TDLR registration and accessibility for a storage facility
Does a self storage facility need TDLR registration?
Yes, where the estimated construction cost is $50,000 or more. Texas Government Code 469.101 requires plans for covered buildings at that cost to be submitted to TDLR, and a self storage facility is a nonresidential commercial facility.
How many accessible units does a self storage facility need?
Texas Accessibility Standards 225.3 requires 5 percent of spaces, at least one, in a facility of 1 to 200 spaces, and 10 plus 2 percent of the spaces over 200 in a larger facility, dispersed across the classes of spaces offered.
Can the city issue a building permit before TDLR approves the plans?
The statute ties the building permit to registration, not approval. A local official may not accept a building permit application for a covered project of $50,000 or more unless the project is verified as registered with TDLR.
Who files the TDLR registration?
The architect, interior designer, landscape architect or engineer with overall design responsibility, no later than the 20th business day after issuing the plans.
Six questions, no cost to ask
Price a storage project on your land
Where the land is tells a contractor which zoning code and which permit office the project answers to. The product and the timing tell them what to price first.
Last reviewed 2026-09-23.