The ADA recognizes service animals, screen readers, hearing aids, and AAC devices as accommodations. It does not recognize AI agents. There is no statutory definition, no certification pathway, and no legal protection for a person who depends on an AI tool to think, concentrate, communicate, or work.
DAS fills that gap. It defines what makes a digital agent an accommodation versus a convenience, how agents are certified, what protections users are entitled to, and how accommodation evidence is documented.
Service animals gained ADA protection because they are individually trained to perform specific tasks for a person with a disability. DAS applies the same logic to software.
| Service Animal | DAS Agent |
|---|---|
| Individually trained | Configured for specific user's disability |
| Performs specific tasks | Task-specificity requirement |
| Under handler's control | User controls agent |
| No certification required | Registration is transparency-based |
| Two permissible questions | Two permissible questions |
| Cannot be excluded by breed | Cannot be excluded by AI model |
Task-Specificity. Agents must perform specific, identifiable disability-related tasks. Not "be helpful." Perform tasks. This is the line between accommodation and convenience.
Three Risk Tiers. Tier 1 (standard accommodation): self-certify and publish a conformance report. Tier 2 (critical accommodation: healthcare data, employment advocacy, diagnostic evidence): third-party audit required. Tier 3 (safety-critical: physical robots, emergency systems): continuous monitoring and insurance.
Privacy and Data Sovereignty. The user owns all data about their disability. Local-first storage. Encrypted at rest and in transit. Zero-knowledge option. No consent-for-access: you don't trade your data for the tool.
Healthcare Data Portability. Patient-Owned Health Record. FHIR R4 compliant. Your health data travels with you, not locked in your provider's system.
Evidence System. Every accommodation the agent provides is logged: what task was performed, which ADA major life activity it supported, what would have happened without it. The agent generates formal accommodation request documents on demand.
Two Permissible Questions. Covered entities (employers, schools, government) may ask: "Is this agent required because of a disability?" and "What tasks does it perform?" They may not ask about the nature of the disability or demand access to the agent's data.
DAS maps to: ADA Titles I, II, and III (employment, government, public accommodations). Section 504 of the Rehabilitation Act (federal programs). The 21st Century Cures Act (patient rights to electronic health data). HIPAA (protected health information).
The HAA is the reference implementation of DAS. Open source, Apache 2.0. It performs communication mediation (translating between neurotypes), demand reduction (PDA-aware reframing), context keeping (cross-session memory for brain injury), cognitive load management, and self-documentation that generates its own ADA accommodation evidence.
Built by a disabled person for disabled people.