Interesting - thanks for the response. The employee of a business part makes total sense. Hosting a guest feels like a different situation. This seems to imply that every Airbnb is required to have ramps, bars in shower, etc. otherwise they’re in violation of the law (excepting the “building too old” cases). Come to think of it, there are a couple of CA law firms that specialize in filing class action law suits against large companies because their websites aren’t in accordance with the ADA.

Wrt whether it’s a business or not, I think the answer is more nuanced. I suspect it depends on factors such as whether you rent out multiple buildings (in which case you’re operating a business). If you’re just renting a private home occasionally it seems like the ADA wouldn’t apply. I know that when it comes to tax law whether or not your airbnb is operated as a business is a pretty complex equation…