When does a metal building project need TDLR registration?
A metal building project anywhere in the San Antonio area, in any of the seven counties and inside or outside a city, needs TDLR registration once the total estimated construction cost reaches $50,000 or more. At that point the construction documents go to a registered accessibility specialist for review under the Texas Accessibility Standards, the finished building is inspected, and the local permit office is barred from accepting your permit application until the project is registered.
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Under $50,000 there is no registration duty, but the standards still apply to a covered building, and a local building official may require registration anyway. TDLR states the law and the standards do not apply to private residences, and the limit on that is business use: the portions of a residence used in operating a business stay covered. The rest of this page is the order the steps run in, what the agency charges, what it does not publish a number for, and where the line sits for a church or a shop behind a house.
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Which metal building projects have to be registered with TDLR?
At a total estimated construction cost of $50,000 or more. The Texas Department of Licensing and Regulation requires a building project at or above that figure to be registered with the department, with a full set of construction documents going to a registered accessibility specialist for review under Administrative Rule 68.50. A project under $50,000 does not have to be registered, still has to comply with the Texas Accessibility Standards, and may be registered on the Special Project Registration form for the project filing fee. TDLR also states that a local jurisdiction or building official may require registration below $50,000.
The same line sits in statute. Government Code 469.101 requires plans and specifications for the construction or substantial renovation of a covered building to go to TDLR for review and approval when the estimated construction cost is at least $50,000. Section 469.102 gives the design professional 20 days from issuing the plans to submit them. Section 469.103 sends plans that are substantially modified after approval back to TDLR.
Source: Texas Department of Licensing and Regulation, Architectural Barriers frequently asked questions, read 2026-09-13.
Source: Texas Legislature Online, Government Code Chapter 469, elimination of architectural barriers, read 2026-09-13.
What counts toward the $50,000 estimated construction cost?
Less than the project budget. TDLR instructs that the estimated construction cost should not include site acquisition, architectural, engineering or consulting fees, furnishings, or equipment that is not part of the building mechanical systems. The agency publishes that list of exclusions rather than a formula, so the number is the project budget with those items taken out, and it is the figure filed at registration.
That matters on a metal building, because the land, the design fees and the equipment that goes inside can be a large share of what an owner thinks the project costs. Settle the figure with the design professional who files the plans before anyone assumes which side of $50,000 the project is on. What drives the price of the building itself is a separate question, covered in what a metal building costs in San Antonio.
Source: Texas Department of Licensing and Regulation, Architectural Barriers special project registration application, read 2026-09-13.
The buildings the Architectural Barriers Act reaches
Government Code 469.003 lists five categories. Two of them are privately funded: a building that meets the federal Americans with Disabilities Act definition of a public accommodation and is constructed, renovated or modified on or after January 1, 1992, and a building that meets the ADA definition of a commercial facility on or after September 1, 1993. The other three are publicly funded buildings, temporary or emergency buildings, and state-leased buildings. The chapter excludes a place used primarily for religious rituals inside a building of a religious organization.
Read that list carefully before deciding your building is outside it. The two private categories borrow their definitions from federal law, and this page does not restate the federal definitions of a public accommodation or a commercial facility, because no primary source for them is recorded here. Which category a building falls in is a question for TDLR or for the design professional on the job, not a question to settle from a website.
The religious exclusion is narrow on its face: it reaches a place used primarily for religious rituals inside a building of a religious organization, not automatically every square foot a congregation builds. A congregation planning a church or community building should settle that question in writing before the plans are drawn, since it changes what the drawings have to show.
Source: Texas Legislature Online, Government Code Chapter 469, elimination of architectural barriers, read 2026-09-13.
Does a shop on your own home lot need TDLR registration?
Not where the building is genuinely part of a private residence. TDLR states that the elimination of architectural barriers law and the Texas Accessibility Standards are relevant to public and commercial buildings and facilities, and do not apply to private residences. A garage, a hobby shop or storage for your own use on your own home lot is the case that sentence describes.
The exception has a limit, and the limit is the business. The 2012 Texas Accessibility Standards state that where a commercial facility or a public accommodation is located in a private residence, the portion of the residence used exclusively as a residence is not covered by the standards, and the portions used in operating the business are. So a shop that customers come to, or that a business runs out of, is not settled by the fact that it sits behind a house.
Where a building lands on that line is a question for TDLR or the design professional, and this page does not answer it for your lot. Ask early: it decides whether the $50,000 test applies at all.
Source: Texas Department of Licensing and Regulation, elimination of architectural barriers at a glance, read 2026-09-13.
Source: Texas Department of Licensing and Regulation, 2012 Texas Accessibility Standards, scoping requirements, read 2026-09-13.
Registration, plan review and inspection, in that order
TDLR describes compliance with the Texas Accessibility Standards as a three-step process: registration, plan review, and inspection. The project is registered online in the TABS system, the filing fee is paid at registration, and the owner names the registered accessibility specialist who will perform the plan review and the inspection. A registered project must have its plan review at some point before the inspection.
One part of that sequence catches owners out: the owner names the specialist, so finding one is the owner side of the job rather than something the department assigns.
Source: Texas Department of Licensing and Regulation, Architectural Barriers program requirements help sheet, read 2026-09-13.
What does TDLR registration for projects over $50,000 cost?
The department publishes a short fee schedule and states plainly that it does not publish everything. These are the amounts it does publish, all of them non-refundable and payable before the service is performed.
Project filing fee: $175.
Late project filing fee: $300.
Special review or inspection fee: $215 per hour, with a one hour minimum.
Variance application fee: $175 each. Variance appeal fee: $200 each.
Source: Texas Department of Licensing and Regulation, Architectural Barriers fee schedule, read 2026-09-13.
Source: Texas Department of Licensing and Regulation, Architectural Barriers special project registration application, read 2026-09-13.
Which TDLR fees are not published as a number?
Two of them, and they are the two that scale with the job. The fee schedule states that plan review and inspection fees collected by the department are determined by the estimated cost of construction, and it publishes no dollar tiers for them. Nothing on this site turns that into a range, because the agency does not publish one.
The registered accessibility specialist is the second. The specialist who performs the plan review and the inspection sets and collects a separate fee, and TDLR publishes no amount for it. The department states that the construction documents and any fees for plan review or inspection go to the specialist, and that specialists set and collect their own fees. Get that quote in writing from the specialist at the same time you get the building priced, so the whole number is on one page.
Source: Texas Department of Licensing and Regulation, Architectural Barriers fee schedule, read 2026-09-13.
Source: Texas Department of Licensing and Regulation, Architectural Barriers special project registration application, read 2026-09-13.
Can you apply for the local building permit first?
No, once the project is at or over the line. Government Code 469.102 bars the owner from applying for a local building permit or starting construction before the plans are submitted to TDLR, and bars a local permitting official from accepting a permit application unless the official verifies that the building is registered with the department. The 20-day clock on the design professional runs from the day the plans are issued.
San Antonio says the same thing from the city side. Its commercial project application guide states that the city does not require accessibility sheets as part of its own review, and that where the valuation is over $50,000 the project must be submitted to the Texas Department of Licensing and Regulation for state review. So the state step is not something the city does for you, and it is not something the city waives. Which local office reviews the rest of the building, and how that path runs inside the city against the unincorporated county, is on metal building permits in San Antonio and Bexar County.
Source: Texas Legislature Online, Government Code Chapter 469, elimination of architectural barriers, read 2026-09-13.
Source: City of San Antonio Development Services, commercial project application guide, read 2026-09-13.
The late filing fee, and what it replaces
TDLR pages state no deadline to register a project before construction starts. What the fee schedule states is that when a project is registered with the department after construction is complete, the $300 late project filing fee applies in place of the $175 project filing fee, it is charged in addition to the plan review fee, and other applicable fees still apply.
The money is the small part. Registering after the building is finished means anything the plan review calls for is a change to a completed building rather than a line on a drawing.
Source: Texas Department of Licensing and Regulation, Architectural Barriers fee schedule, read 2026-09-13.
When does the finished building have to be inspected?
Government Code 469.105 puts the duty on the building owner, not on the builder. A building covered by the $50,000 rule must be inspected for compliance no later than the first anniversary of the date the construction or substantial renovation is completed, by TDLR, a contracted entity, or a person holding a certificate of registration as an accessibility specialist.
The working deadline is much shorter than the statutory one. TDLR procedures for registered accessibility specialists tell the building owner to request the inspection no later than 30 days after the completion of construction, and to notify the specialist in writing if the completion date given at registration changes. Put both dates in the project file at registration.
Source: Texas Legislature Online, Government Code Chapter 469, elimination of architectural barriers, read 2026-09-13.
Source: Texas Department of Licensing and Regulation, 2018 procedures for registered accessibility specialists, read 2026-09-13.
What applies to a project under $50,000?
The standards, but not the registration duty. A project under $50,000 does not have to be registered with TDLR, still has to comply with the Texas Accessibility Standards where it is a covered building, and may be registered voluntarily on the Special Project Registration form for the project filing fee. TDLR also states that a local jurisdiction or building official may require registration below $50,000, so the local office is worth asking before you rely on being under the line.
Source: Texas Department of Licensing and Regulation, Architectural Barriers frequently asked questions, read 2026-09-13.
Who handles the TDLR steps on your project
The duties in the statute sit with the owner and the design professional. The design professional submits the plans within 20 days of issuing them, the owner names the registered accessibility specialist and pays the filing fee at registration, and the owner is responsible for the inspection after completion. The specialist does the plan review and the inspection. TDLR itself registers the project and collects its published fees.
The contractor builds what those drawings show. TDLR registers buildings here, not builders: its list of regulated industries names no builder, general contractor or metal building program, so the credential this page turns on is the registered accessibility specialist, not a license the contractor holds. An independent local metal building contractor who works your county puts up the building and prices the work.
Ask any contractor bidding a commercial metal building who is filing the TDLR registration and who is paying the specialist, and get the answer in the written estimate. The whole path, from the lot through the slab and the frame to the finish, is laid out in building a metal building in San Antonio.
Source: Texas Legislature Online, Government Code Chapter 469, elimination of architectural barriers, read 2026-09-13.
Source: Texas Department of Licensing and Regulation, Architectural Barriers program requirements help sheet, read 2026-09-13.
Source: Sunset Advisory Commission, Texas Residential Construction Commission; TDLR regulated industries list, read 2026-09-13.
Questions people ask
When does a metal building need TDLR registration in Texas?
When the total estimated construction cost reaches $50,000 or more. The Texas Department of Licensing and Regulation requires a building project at or above that figure to be registered with the department, with a full set of construction documents going to a registered accessibility specialist for review under Administrative Rule 68.50. Government Code 469.101 carries the same $50,000 line in statute for the construction or substantial renovation of a covered building. A project under $50,000 does not have to be registered but still has to comply with the Texas Accessibility Standards, and TDLR states that a local jurisdiction or building official may require registration below $50,000. Read at the TDLR Architectural Barriers pages and Texas Legislature Online, Government Code Chapter 469, 2026-09-13.
What does TDLR charge to register a project?
The published fees are a project filing fee of $175, a late project filing fee of $300, a special review or inspection fee of $215 per hour with a one hour minimum, a variance application fee of $175 each, and a variance appeal fee of $200 each. All are non-refundable and must be paid before the service is performed. Two costs are not published as a number: the fee schedule states that plan review and inspection fees collected by the department are determined by the estimated cost of construction without publishing dollar tiers, and the registered accessibility specialist who performs the plan review and the inspection sets and collects a separate fee that TDLR publishes no amount for. Read at the TDLR Architectural Barriers fee schedule and the special project registration application, 2026-09-13.
Does a metal shop at a private home need TDLR registration?
TDLR states that the elimination of architectural barriers law and the Texas Accessibility Standards are relevant to public and commercial buildings and facilities, and do not apply to private residences. The limit on that is the business use: the 2012 Texas Accessibility Standards state that where a commercial facility or a public accommodation is located in a private residence, the portion used exclusively as a residence is not covered and the portions used in operating the business are. A shop that a business is run out of is not settled by the fact that it sits on a home lot, so confirm the answer with TDLR or the design professional before the plans are drawn. Read at the TDLR elimination of architectural barriers overview and the 2012 Texas Accessibility Standards, 2026-09-13.
Can a city issue a building permit before the project is registered with TDLR?
No, at or above the $50,000 line. Texas Government Code 469.102 bars the owner from applying for a local building permit or starting construction before the plans are submitted to the Texas Department of Licensing and Regulation, and bars a local permitting official from accepting a permit application unless the official verifies that the building is registered. The design professional has 20 days from issuing the plans to submit them. The City of San Antonio states the same from its own side: it does not require accessibility sheets in its review, and where the valuation is over $50,000 the project must be submitted to TDLR for state review. Read at Texas Legislature Online, Government Code Chapter 469, and the City of San Antonio commercial project application guide, 2026-09-13.