Touch one wall in a TI, and you may owe an accessible path to the door

The trigger everyone reads backwards

Here's the thing: most tenant-improvement scopes get CBC 11B-202.4 exactly backwards. The common read is "we're not touching the restroom, so the restroom isn't in scope." The code doesn't work that way.

The section — 11B-202.4, "Path of travel requirements in alterations, additions and structural repairs" — opens with this: "When alterations or additions are made to existing buildings or facilities, an accessible path of travel to the specific area of alteration or addition shall be provided."

Read that again. The trigger is the alteration itself. Once you alter an area, you owe an accessible path of travel to that area — whether or not the restroom, the entrance, or the drinking fountain is anywhere near your work.

What "path of travel" actually covers

11B-202.4 spells out what the primary accessible path of travel includes:

1. A primary entrance to the building or facility,
2. Toilet and bathing facilities serving the area,
3. Drinking fountains serving the area,
4. Public telephones serving the area, and
5. Signs.

So a clean interior office TI can pull the front entrance, the shared restrooms down the hall, and the building signage into your review — because they serve the area you altered, even when they sit outside the lease line.

Verified against the 2025 California Building Code, Part 2, Section 11B-202.4 (with January 2026 Errata), as published on ICC Digital Codes.

The 20% cap, in plain arithmetic

This is where budgets get made or blown. Exception 8 limits the spend: "the cost of compliance with Section 11B-202.4 shall be limited to 20 percent of the adjusted construction cost of alterations, structural repairs or additions."

Twenty percent. That's the number to carry. 20% of a $200,000 adjusted construction cost is $40,000 — the ceiling on what the code can force you to spend bringing the path of travel up to standard. If full compliance would cost more, the code says provide it "to the greatest extent possible without exceeding 20 percent," working down a fixed priority list: accessible entrance first, then the route to the altered area, then at least one restroom for each sex (or a unisex restroom), then telephones, then drinking fountains, then everything else.

Two things people miss:

• Adjusted construction cost is a defined term. Per CBC §202 it covers the labor, materials, and equipment directly related to construction — and it excludes architectural and engineering fees, project-management fees, testing and inspection, and utility-connection fees. It also excludes the cost of the path-of-travel work itself, so you don't double-count.
• The 20% is a ceiling only at or below the valuation threshold. Exception 8 caps compliance at 20% when your adjusted construction cost is at or below the current valuation threshold. Above that threshold, the logic flips: full compliance is the default; only if the jurisdiction records a written unreasonable-hardship finding is full compliance excused — and even then you must still spend at least 20%, a floor, not a ceiling. The threshold is an annually adjusted figure (a $50,000 baseline from January 1981, escalated by a construction-cost index), so confirm the current year's number with your local jurisdiction before you finalize scope.

The de minimis carve-out is narrower than you think

There is a real "small scope" out — Exception 3 — but it is tight. It applies to additions or alterations to meet accessibility requirements consisting of one or more of these items, and it is "limited to the actual scope of work of the project":

1. Altering one building entrance.
2. Altering one existing toilet facility.
3. Altering existing elevators.
4. Altering existing steps.
5. Altering existing handrails.

That's the whole list. Do one of those, by itself, and you don't trigger the full path-of-travel obligation. But a general office or retail buildout is not on this list. Don't assume "it's minor" gets you out — the exception turns on which narrow accessibility items you're touching, not on how small the job feels.

The three-year lookback

Phasing a job to stay under 20% doesn't work either. Exception 8 closes that door: if an area is altered without providing an accessible path of travel, and another alteration on that same path of travel is undertaken within three years of the original, the total cost of the alterations on that path over the preceding three-year period is counted when the jurisdiction decides whether the path-of-travel cost is disproportionate. Split a buildout into two permits a year apart on the same path, and both can be added together.

And note: this isn't only a California rule. The federal ADA carries a parallel 20% path-of-travel requirement at 28 CFR 36.403, and it applies independently of the California analysis — a written California hardship finding does not relieve federal exposure.

What CrossBeam does with it

CrossBeam flags the path-of-travel obligation the moment an alteration is in play — not just when the restroom lands in the drawing set — and points to the entrance, restrooms, drinking fountains, and signage that serve the altered area. It puts the 20% cap, the Exception 3 carve-out, and the three-year lookback in front of you while the scope is still on paper, so the accessibility line item gets budgeted before the TI is priced, not discovered in plan check.