On July 26, 1990, President George H.W. Bush signed the Americans with Disabilities Act into law. The Senate had passed it 91 to 6. The House voted 377 to 28. It was, by any measure, one of the most bipartisan pieces of civil rights legislation in American history. And yet, 35 years later, roughly 341 of New York City's 472 subway stations still have no elevator access. A wheelchair user born the day the ADA was signed will be 65 years old before the NYC subway is projected to be mostly accessible. That is not a metaphor. That is the timeline written into a 2022 federal court settlement.
The Federal Transit Administration's All Stations Accessibility Program (ASAP) is the most significant federal attempt to close that gap. The FY2026 round, with $686 million in available funding, is the largest single allocation in the program's history and the final one authorized under the Infrastructure Investment and Jobs Act. Applications closed May 1, 2026. Awards are expected in late 2026 or early 2027. What happens after that depends on Congress.
How the ADA Created a Legal Exemption for Existing Stations
The ADA required that any newly constructed transit station be fully accessible. That part was clear. For existing stations, the law took a different approach. Under 49 CFR Part 37, the regulations implementing the ADA for transit, legacy rail operators did not have to retrofit every station immediately. Instead, they had to make "key stations" accessible by July 26, 1993. Key stations were defined as terminal stations, transfer points, stations with high ridership, and stations at major intersections.
The rest of the existing network was left in place. Agencies that couldn't meet the 1993 deadline could apply for extensions, and many did. The intent was pragmatic: retrofitting century-old underground infrastructure costs enormous amounts of money, and a strict universal deadline would have been financially ruinous. But the consequence of that pragmatism has been a 35-year accessibility gap that millions of Americans live with every day.
The Eno Center for Transportation estimates that bringing all U.S. legacy rail systems into full ADA compliance would cost between $10 billion and $14 billion. ASAP's entire IIJA authorization is $1.75 billion over five years. The Eno Center has characterized the program as a down payment on a much larger obligation -- not a solution in itself.
What ASAP Actually Funds
ASAP was created by Section 3006 of the Infrastructure Investment and Jobs Act (Public Law 117-58), signed in November 2021. It targets fixed-guideway rail systems that were in service before July 26, 1990 -- the pre-ADA legacy systems where the structural accessibility gap is most acute.
Eligible projects include:
- Elevator and ramp installation
- Platform modifications such as gap fillers and level boarding upgrades
- Accessible pedestrian signals
- Wayfinding systems for riders with visual impairments
- Accessible fare payment equipment
Grant recipients are required to provide a 20 percent local match, meaning the $686 million federal allocation leverages an additional $172 million or more in local and state funds.
The FY2026 round's $686 million is the largest single ASAP appropriation. Combined with earlier rounds from FY2022 through FY2025, ASAP has now directed $1.75 billion to legacy rail accessibility improvements. That is historically significant. It is also, measured against the scale of the problem, a fraction of what full compliance would require.
Where the Money Is Going: System by System
New York City Transit
The NYC subway is the starkest example of the legacy rail accessibility gap. The IRT (Interborough Rapid Transit) opened its first lines in 1904; BMT subway lines followed from around 1915; the IND (Independent Subway System) opened in 1932. Retrofitting stations built across more than a century of transit history means digging new elevator shafts through bedrock, acquiring air rights on the street above, and coordinating with utility corridors and building foundations. It is slow and expensive work.
Of the system's 472 stations, approximately 131 -- about 28 percent -- have elevator access. The remaining 341 do not. In 2022, Disability Rights Advocates reached a settlement with the MTA requiring that 95 percent of stations be accessible by 2055. The settlement also mandates elevator repairs within 24 hours of a breakdown and real-time outage notifications to riders. The MTA has an accelerated plan to add elevator access to 30 or more stations by 2030 and has indicated it will apply for FY2026 ASAP funding to support that program.
The MTA's stated goal is to ensure that 50 percent of riders live within two stops of an accessible station. Disability advocates have criticized that benchmark as insufficient -- a metric designed around the network's geometry rather than around actual access for riders who cannot use stairs.
Chicago Transit Authority
The CTA operates 145 stations, with approximately 37 -- about 26 percent -- still lacking full accessibility. Some of the system's elevated structures date to 1892. The Loop 'L' and sections of the Blue Line present the greatest engineering challenges. The CTA estimates that completing accessibility improvements system-wide would cost roughly $2 billion. The agency received approximately $55 million in ASAP grants during earlier funding rounds (FY2022 through FY2024) and has announced plans to apply in FY2026.
Washington Metro
WMATA's 98-station system, which opened in 1976, is among the more accessible legacy rail networks in the country. But accessibility and reliability are not the same thing. The system operates approximately 588 elevators, and chronic maintenance failures have made elevator outages a persistent problem for riders who depend on them. WMATA's FY2026 ASAP application is focused on elevator reliability upgrades and redundant access routes rather than new installations.
MBTA and SEPTA
The MBTA operates the oldest subway in the United States, with its first line opening in 1897. Approximately 70 to 75 percent of its rapid transit stations have accessible platforms, but the Green Line surface and light rail segments represent a significant ongoing gap. The agency has used prior ASAP rounds to fund accessibility improvements and is continuing that work.
SEPTA faces a different kind of constraint. Multiple stations on the Market-Frankford and Broad Street Lines lack full accessibility, but SEPTA is also managing a projected $192 million operating deficit for FY2027. Capital grants like ASAP typically require a local match. A transit agency in financial distress may struggle to commit the matching funds that would unlock federal dollars, even when those dollars are available.
BART
BART, built in the 1970s, is among the more accessible legacy systems. But like WMATA, it faces persistent elevator reliability challenges. BART's FY2027 budget addressed a major structural deficit without a fare increase, and the agency is applying for ASAP funding to improve elevator maintenance capacity and add redundant access at key stations.
Who Depends on Elevator Access
Accessibility advocates sometimes note that elevator access is not just a disability issue -- it is a design issue that affects a much broader population. Researchers call this the "curb cut effect": features designed to remove barriers for people with disabilities tend to benefit everyone. Accessible stations see documented ridership increases from parents with strollers, older riders, travelers with luggage, and workers carrying equipment.
But the primary case for ASAP is the 12 to 13 million Americans with mobility disabilities who have difficulty walking or climbing stairs. Approximately 3.6 million Americans use wheelchairs. Among adults 65 and older, roughly 36 percent have some form of disability. By 2030, every member of the baby boom generation will be 65 or older. The demand for accessible transit is not going to decrease.
APTA data suggests that in some cities, people with disabilities account for 30 to 40 percent of all transit trips. For many of those riders, an inaccessible station is not an inconvenience -- it is a locked door. As TransitCenter has put it: "Every station without an elevator is a locked door for millions of Americans with disabilities."
This is the essence of inclusive design: systems built for the most constrained users tend to work better for everyone.
The Paratransit Catch-22
There is a fiscal argument for accessibility that transit agencies sometimes underemphasize. When a fixed-route rail station is inaccessible, wheelchair users and others who cannot use stairs are legally entitled to ADA paratransit service -- on-demand, door-to-door rides provided at comparable hours and fares to fixed-route service.
Paratransit is expensive. The average cost per paratransit trip runs between $30 and $50. The average fixed-route trip costs $3 to $5. That is a cost differential of six to fifteen times, paid by transit agencies and ultimately by taxpayers. Inaccessible stations do not save agencies money. They shift the cost into a less efficient mode and remove the operational benefits of carrying that rider on fixed-route service.
Investing in elevator access reduces long-term paratransit dependency. The upfront capital cost is real and substantial, but agencies that have completed accessibility retrofits have documented reductions in paratransit demand at those stations. ASAP is structured to accelerate exactly this kind of investment.
The Equity Dimension
Legacy rail networks were not built in a political vacuum. Many of the elevated and underground lines now in need of accessibility retrofits were constructed through Black, Hispanic, and low-income neighborhoods -- communities that were often displaced or divided by the infrastructure built to serve other parts of the city. Today, transit-dependent populations, who skew lower-income and more likely to be people of color, are disproportionately harmed by accessibility gaps in those same corridors.
ASAP funding directed to legacy rail in these neighborhoods is not just a disability rights issue. It is an equity issue, and one that overlaps with the broader question of who transit systems are designed to serve. The promoting equity in transit funding conversation applies directly here: capital programs that disproportionately benefit wealthier, less transit-dependent riders at the expense of accessible service for core riders invert the purpose of public transit.
What Happens After FY2026
The IIJA surface transportation programs expire on September 30, 2026. ASAP's authorization expires with them. The question of whether the program continues, and at what scale, depends on the next surface transportation reauthorization.
The current vehicle is the BUILD America 250 Act, which the House Transportation and Infrastructure Committee advanced in May 2026. The bill proposes $580 billion in total surface transportation funding over five years, including $87.6 billion for transit. Disability advocates are pushing for a standalone ASAP authorization of at least $3 billion over five years in the reauthorization -- more than double the IIJA's total ASAP investment, and still well short of the Eno Center's $10 to $14 billion full-compliance estimate.
The broader fiscal cliff facing transit agencies adds urgency to the reauthorization timeline. Agencies managing operating deficits while trying to commit local capital matches for federal grants are in a genuinely difficult position. A reauthorization that expands ASAP funding while providing flexibility on local match requirements would do more for legacy rail accessibility than a larger authorization with conditions agencies cannot meet.
A Down Payment, Not a Solution
The FTA has described ASAP as a program that "will help transit agencies close the gap between the promise of the ADA and the reality faced by millions of transit riders with disabilities every day." That framing is accurate but incomplete. Closing a gap that took 35 years to accumulate will require sustained, multi-cycle investment at a scale the IIJA alone cannot provide.
The $686 million FY2026 round is the largest federal accessibility investment in legacy rail history. It will add elevators, install ramps, and modernize platforms at systems that have been inaccessible since before most of their current riders were born. That is real and meaningful progress.
But the arithmetic is unavoidable. Against a $10 to $14 billion compliance gap, $1.75 billion over five years is a beginning. Whether Congress treats this as the start of a sustained program or a one-time check will determine whether the ADA's promise is finally fulfilled -- or whether the transit riders who depend on elevators are asked, again, to wait another generation.