Disabled people have legal protections in housing—yet many don't know what rights apply in their country or how to enforce them. This page starts with universal frameworks that apply globally, then shows how different countries and regions implement these principles through their own laws.
All disabled people worldwide share the same fundamental right: to live independently in the community with support if needed. This is established by the UN Convention on the Rights of Persons with Disabilities (CRPD) Article 19, ratified by 186 countries.
For detailed explanation of how CRPD Article 19 works, how different legal systems interpret it, and the international frameworks protecting disabled people's housing rights, see International Housing Rights.
In brief: CRPD Article 19 establishes that disabled people have:
These principles apply universally, regardless of your country. What differs is how each country implements them through national law.
Choose your location to see detailed information about housing rights, protections, and resources in your area:
The U.S. has not ratified CRPD (though it signed it), so CRPD is not legally binding. However, Olmstead v. L.C. (1999), a Supreme Court case interpreting the Americans with Disabilities Act, established the same principle as CRPD Article 19: unjustified segregation of disabled people in institutions violates the ADA. Housing rights in the U.S. are primarily implemented through federal law, state law, and local ordinances.
The Fair Housing Act (FHA), passed in 1968 with disability protections added in 1988, prohibits discrimination in housing based on disability. It covers most rentals and sales but has limited exemptions: owner-occupied buildings with four or fewer units where the owner lives, and housing exclusively for people 55+ (though disability provisions still apply). For full legal text, see Fair Housing Act.
The FHA prohibits three main categories of violations:
Refusal to rent or sell based on disability means landlords cannot discriminate based on disability status. They cannot refuse to show accessible units, charge higher deposits, require unnecessary medical documentation, or refuse based on disability. Source-of-income discrimination (refusing Section 8 vouchers) is prohibited in 23 states and some cities.
Different terms and conditions means landlords cannot have different rules for disabled versus non-disabled tenants. Examples include different deposits, lease terms, visitor policies, or service availability based on disability.
Failure to make reasonable accommodations is the most common violation. Landlords must modify rules, policies, or practices to provide equal access. Examples: allowing service animals in no-pet buildings, reserving accessible parking, permitting medical equipment storage, modifying visitor policies for live-in attendants, or providing extended response time for lease signing.
Reasonable modifications are physical changes to units (grab bars, doorway widening, threshold removal) that landlords must allow. In federally-funded housing, landlords pay; in private housing, tenants typically pay but landlords cannot charge extra fees or refuse to allow modifications.
Section 504 applies to any housing receiving federal funding: public housing, Project-Based Section 8, HOPWA, supportive housing, programs funded through CDBG or HOME. This covers substantial U.S. housing stock. For details, see Section 504.
Section 504 provides stronger protections than FHA: landlords must pay for reasonable modifications, must proactively offer accommodations to known disabled residents, and must ensure accessibility in all common areas and services. New construction must include 5% mobility-accessible and 2% sensory-accessible units.
Determine if your housing is Section 504-covered: Check your lease, contact your landlord or housing authority and ask: "Is this building Section 504-covered?" If yes, you have stronger modification and accommodation rights.
Many states and cities provide protections exceeding federal law. Examples:
California uses broader disability definition, covers smaller buildings than FHA, prohibits source-of-income discrimination, and provides longer filing deadlines. State agency (DFEH) investigates separately from HUD.
New York covers smaller buildings, uses broad disability definition, and the 2024 Equal Rights Amendment added constitutional protection. Longer filing deadlines than federal.
Massachusetts, Connecticut, Illinois, and 20 others prohibit source-of-income discrimination (Section 8 voucher refusal).
Cities (San Francisco, Washington DC, New York City, others) often have local protections exceeding state/federal law.
Contact your state housing agency or disability rights organization to learn about protections in your area.
Write to your landlord clearly stating disability-related need (without disclosing diagnosis):
"I am a person with a disability as defined by the Fair Housing Act. Due to my disability, I need [specific accommodation] to have equal use and enjoyment of housing. Please respond within 14 days."
Examples: "I need an exception to the no-pets policy for my service animal." "I need reserved accessible parking near my unit." "I need a longer timeline for lease signing due to disability-related processing differences." "I need permission to install grab bars in the bathroom."
Keep all communications in writing. Document dates, who you spoke with, what was said.
If landlord requests verification: They can ask if disability exists and whether accommodation is disability-related. Verification should come from any licensed healthcare provider you see (doctor, therapist, nurse practitioner). Landlords cannot ask about diagnosis, treatment, or medical details. Red flags for illegitimate requests: demands for specific disease names, online ESA letter websites, requiring old documentation.
Write to your landlord:
"I am requesting a reasonable modification to my unit/common area to accommodate my disability. Specifically, I need [modification] to ensure accessibility. I propose [how/timeline]. Please respond within 14 days."
Examples: "I need grab bars installed in the bathroom to prevent falls." "I need the entry doorway widened from 28 to 36 inches for wheelchair access." "I need a ramp installed at the entrance."
In federally-assisted housing, landlords pay. In private housing, you typically pay but landlords cannot refuse, charge extra fees, or demand higher deposits.
Structural modifications should be discussed before work begins. Simple modifications (grab bars, raised toilet seats, lever handles) often don't require advance approval but should be requested.
If you experience housing discrimination, file with HUD within one year of violation:
Call HUD: 1-800-669-9777. Bilingual staff available. You can file by phone without lawyer or formal complaint.
File online: hud.gov, Fair Housing section.
File by mail: Your HUD regional office (address at hud.gov).
Gather documentation: dates, names of people involved, what was said, lease/rental agreement, any written communications, attempts to resolve informally, witnesses.
HUD investigates at no cost. They attempt conciliation within 30 days. If conciliation fails, HUD charges the landlord and case proceeds to administrative hearing or federal court. You don't pay.
State and local agencies often investigate faster and have longer deadlines. File with both HUD and your state/local agency for maximum enforcement.
Fair housing organizations can help you file, provide legal assistance, and represent you. Contact: nationalfairhousing.org.
Many issues resolve through direct communication before formal complaints:
Write to landlord: "On [date], you [describe violation]. This violates Fair Housing Act. I need [resolution] by [date]. If unresolved, I will file HUD complaint."
Some landlords respond to clear documentation. Fair housing organizations offer mediation, which can resolve issues faster than formal investigation.
HUD Fair Housing Hotline: 1-800-669-9777
National Fair Housing Alliance: nationalfairhousing.org (find local organizations)
Your state disability rights organization: dol.gov directory
Centers for Independent Living: ncil.org directory (free housing advocacy)
Legal aid: lawhelp.org, 211.org
Canada ratified CRPD in 2016 and implements Article 19 through multiple frameworks. Housing rights vary by province.
The Accessible Canada Act (2019) applies to federally regulated entities and requires them to proactively identify, remove, and prevent accessibility barriers, including in housing. The principle is "Nothing About Us Without Us" — disabled people must be involved in decisions affecting them.
The Canadian Human Rights Act prohibits discrimination based on disability and requires accommodation to the point of "undue hardship." This applies federally regulated organizations.
Each province has its own human rights code and residential tenancy act with disability protections. These vary significantly:
Ontario: AODA (Accessibility for Ontarians with Disabilities Act) requires organizations with 50+ employees to meet accessibility standards. Residential Tenancies Act protects tenant rights.
British Columbia, Alberta, Manitoba, Saskatchewan, Quebec, Nova Scotia, New Brunswick, Prince Edward Island, Newfoundland and Labrador: Each has disability rights protections and tenant protections. Contact your provincial human rights commission or disability rights organization for details.
Housing First approach: Canada has increasingly adopted Housing First models for people experiencing homelessness, particularly veterans through HUD-VASH equivalent programs.
Process is similar to U.S. but templates and legal language may differ. Write to landlord/housing provider clearly stating need.
Document all communications. If landlord refuses, contact your provincial human rights commission or disability rights organization.
Canadian Human Rights Commission: chrc-ccdp.gc.ca
Your provincial human rights commission: Contact through provincial government
Independent Living Canada: ilcan.ca (equivalent of U.S. CILs)
Provincial disability rights organizations: Search "[province] disability rights"
EU member states are required to implement CRPD Article 19 principles. The EU provides coordinated frameworks, but implementation varies by country.
UN CRPD Article 19 - EU Implementation requires member states to ensure disabled people can live independently with community support. This means:
European Accessibility Act (EAA) (implemented by June 2025) applies to products and services across EU member states, including housing-related services. References EN 301 549 standard (equivalent to WCAG accessibility standards).
Web Accessibility Directive (WAD) applies to public sector websites and apps, requiring WCAG 2.1 Level AA compliance. Affects housing authority websites, tenant portals, etc.
Implementation varies dramatically. Some countries provide strong housing protections and extensive support services; others lag significantly.
Germany: Strong housing protections through General Equal Treatment Act. Extensive disability support services enabling independent living. Well-developed personal care and housing support systems.
Netherlands: Progressive deinstitutionalization. Community-based care services relatively available. Housing discrimination protections strong.
Sweden: Phased out residential institutions by 1970s. Community-based support as standard. 10% of housing stock must be wheelchair accessible.
UK (post-Brexit but still relevant): Equality Act 2010 requires landlords to make reasonable adjustments. 2023 Supreme Court ruling: local authorities cannot escape duties due to lack of resources. Disabled Facilities Grants provide modification funding (though reaching only 6% of eligible renters). See United Kingdom section below.
France, Spain, Italy, Poland: Varying levels of CRPD implementation. Deinstitutionalization ongoing but progressing slowly. Housing protections exist but enforcement varies.
Eastern European countries (post-2004 EU expansion): Deinstitutionalization just beginning, often using EU structural funds. Concerns about "trans-institutionalization" into smaller segregated settings rather than true community living.
Contact your national disability organization or housing authority. Process varies by country. Some countries have housing ombudspersons or disability-specific complaint mechanisms.
European Court of Human Rights: If national remedies are exhausted, disabled people can petition ECHR for violations of housing and dignity rights. This is slow but creates precedent.
European Disability Forum: edf-feph.org (coordinates disability organizations across EU)
Your country's disability organization: Contact through national government
UN CRPD monitoring: ohchr.org (track your country's CRPD implementation progress)
The UK ratified CRPD in 2009 (post-Brexit but CRPD obligations remain). Housing rights are implemented through UK law.
The Equality Act 2010 is the primary housing rights law. It prohibits discrimination based on disability in all aspects of housing and requires landlords to make "reasonable adjustments" to policies, practices, and physical features.
A 2023 Supreme Court ruling established that local authorities cannot escape duty to provide suitable housing due to lack of resources. This strengthened housing rights enforcement.
Residential Tenancies Act and common law protections apply. Landlords must:
The Disabled Facilities Grant provides £711 million annually for home modifications. Eligibility and amounts vary by local authority. Typically covers ramps, grab bars, widened doorways, bathroom modifications, and other accessibility improvements.
However, DFGs reach only ~6% of eligible people; waiting lists are long. Private renters particularly underserved.
UK follows similar frameworks to U.S./Canada. Service animals and emotional support animals must be accommodated in housing. Landlords cannot refuse or charge additional fees.
Contact your local council's housing department or housing ombudsman. Cases can also be brought to employment tribunals for disability discrimination.
Equality and Human Rights Commission: equalityhumanrights.com (provides guidance and enforcement)
Disability Rights UK: disabilityrightsuk.org (housing information and advocacy)
Equality and Human Rights Commission: equalityhumanrights.com
Housing ombudsman: Housing ombudsman.org.uk
Citizens Advice: citizensadvice.org.uk (housing rights information)
Australia ratified CRPD in 2008. Housing rights are primarily implemented through the Disability Discrimination Act and the National Disability Insurance Scheme (NDIS).
The Disability Discrimination Act (DDA) prohibits discrimination in all areas of public life, including housing. It applies to rental housing, real estate transactions, and housing services.
The Australian Human Rights Commission recommends WCAG 2.1 Level AA accessibility standards as best practice (though not legally mandated).
The NDIS provides individualized funding for eligible disabled people, including housing support through Specialist Disability Accommodation (SDA). SDA provides housing specifically designed for people with extreme functional impairment.
While not perfect (significant criticism exists around access criteria, control, and adequacy), NDIS represents substantial implementation of CRPD Article 19 support requirement.
Each Australian state/territory has residential tenancy legislation. Generally:
NDIS participants can access funding for home modifications through their plans. Non-NDIS eligible disabled people may access funding through state/territory programs (vary by location).
Contact the Australian Human Rights Commission (humanrights.gov.au) or your state's anti-discrimination body.
State-based disability organizations also provide advocacy and complaint support.
Australian Human Rights Commission: humanrights.gov.au
NDIS: ndis.gov.au
Disability Rights Australia: disabilityrightsaustralia.org.au
State disability organizations: Search "[state] disability rights"
Many countries worldwide have ratified CRPD and are implementing housing protections, though progress and resources vary dramatically.
Brazil: Strong disability rights movement. Housing protections exist; deinstitutionalization efforts ongoing. Disability organizations advocate for CRPD implementation.
South Africa: Constitution guarantees adequate housing. Disability organizations advocate for accessible housing and deinstitutionalization. Limited resources constrain implementation.
India: RPwD Act 2016 mandates accessible housing in public and private sectors. Disability organizations push for enforcement. Informal economy and informal settlements present challenges for most disabled people.
Mexico, Colombia, Argentina, Chile and other Latin American countries: Varied CRPD implementation. Housing protections exist on paper; enforcement and resource availability inconsistent.
Kenya, Uganda, Ghana and other East/West African countries: Disability organizations emerging. Housing rights advocacy growing. Limited public resources constrain implementation.
New Zealand: Ratified CRPD. Disability Rights Commissioner oversees CRPD implementation. Housing protections exist; independent living supports available.
Japan: Promotes digital accessibility and equal participation for disabled people. National standard JIS X 8341-3 aligns with WCAG 2.0 Level AA. Traditional family care models influence housing approaches.
South Korea: Disability Discrimination Act exists. Growing independent living movement. Housing issues increasingly in focus of disability organizations.
Common barriers to housing rights implementation globally:
Despite barriers, disabled people's organizations in every country are advocating for housing rights:
Disabled Peoples' International (dpi.org): Global federation with members in 150+ countries, focused on disability rights including housing.
SABE International (sabeint.org): International organization of self-advocates with intellectual/developmental disabilities.
Regional disability organizations: Europe (EDF, ENIL), Americas, Africa, Asia, Pacific - coordinating advocacy and sharing strategies.
Strategic litigation: Disability organizations increasingly using courts to enforce housing rights, creating precedent and accountability.
Despite different laws and resources, CRPD Article 19 creates consistency in core principles that disabled people worldwide are fighting for:
Principle 1: Community living as default
Disabled people should live in regular community (neighborhoods, towns, cities), not segregated settings. Institutions are not acceptable housing solutions.
Principle 2: Choice and control
Disabled people have the right to decide where to live, with whom, and what arrangements work for them. Support should enable choice, not restrict it.
Principle 3: Support as right
Governments have obligation to fund and provide support services enabling disabled people to live independently. This is not charity; it's a right.
Principle 4: Accessibility
Housing itself and broader environment (transportation, services, communication) must be accessible. Accessibility is prerequisite for community living.
Principle 5: Anti-discrimination
Landlords, governments, and service providers cannot discriminate based on disability. This is consistent across all legal systems that have implemented CRPD.
Disabled people worldwide are organizing to enforce housing rights:
UN Committee on Rights of Persons with Disabilities reviews state reports on CRPD implementation and issues recommendations. While not directly enforceable, creates public accountability.
Regional human rights mechanisms (European Court of Human Rights, Inter-American Court, African Court) increasingly recognize housing and community living rights.
Disabled people's organizations (DPOs) in every country advocate for CRPD implementation, deinstitutionalization, and community living. DPOs are often more effective than governments in advancing rights.
Strategic litigation by disability organizations has increasingly forced governments to recognize housing rights—examples in Europe, Latin America, Asia, Africa.
Peer-led monitoring by disabled people documenting housing rights violations creates accountability outside formal systems.
Whether you're in a country that has ratified CRPD, in a country like the U.S. that hasn't, or in a country with weak enforcement:
Know the international standard: Article 19 establishes your right to live independently in community with support. This applies universally regardless of your government's CRPD status.
Understand your national laws: Use this page to find country-specific information about what rights exist in your country and how to enforce them.
Connect globally: Disabled people worldwide are organizing. International disability networks, regional organizations, and global solidarity strengthen local advocacy.
Document violations: If your government violates CRPD obligations, document them. Evidence supports advocacy, litigation, and international accountability mechanisms.
Organize collectively: Disabled people's organizations are powerful. If one doesn't exist in your area, others exist regionally and globally, and may support your local organizing.
International Housing Rights: See International Housing Rights for detailed explanation of CRPD Article 19, global frameworks, and how different legal systems implement housing rights.
UN Convention on Rights of Persons with Disabilities: ohchr.org. Full text in multiple languages; General Comment 5 on Article 19 provides in-depth interpretation.
Disabled Peoples' International: dpi.org. Global federation of disabled people's organizations in 150+ countries.
SABE International: sabeint.org. International organization of self-advocates with intellectual/developmental disabilities.
European Disability Forum: edf-feph.org. Coordinates disability organizations across Europe.
Your country's disability rights organization: Search "[country] disabled people's organization" or contact through national government.
Centers for Independent Living (U.S. and equivalents internationally): These peer-led organizations provide housing assistance and community living advocacy. Find yours through national directories (ncil.org in U.S., ilcan.ca in Canada, etc.).
Have housing rights resources, research, or country-specific information to contribute? Contribute to DisabilityWiki
Last updated: November 2025