A service dog in training has no public access under the ADA, and U.S. airlines do not have to treat it as a service dog. The DOJ says the dog "must already be trained before it can be taken into public places." State law is where trainers get access, and it varies a lot: some states cover any trainer, some only professionals, and some require a tag, visible "in training" gear or a minimum age.
Are service dogs in training protected by the ADA?
"No. Under the ADA, the dog must already be trained before it can be taken into public places. However, some State or local laws cover animals that are still in training."DOJ ADA service animal FAQ, question 6
So under federal law, a business may treat a dog in training like any other dog. Whether it must let you in depends on your state, and sometimes on who you are (a professional, a volunteer puppy raiser, or an owner training their own dog).
Service dog in training laws by state
MSU's Animal Legal and Historical Center marks 49 of 50 states as covering dogs in training in some form, but "covered" ranges from full access for any trainer to much narrower protection. The table below lists the states our research has read in the statute itself (or, where noted, from MSU's table). Every state has its own page in service dog laws by state.
| State | Who has access with a dog in training, and conditions |
|---|---|
| California | Trainers, for the purpose of training; the dog must be on a leash and wear an ID tag issued by the county clerk, animal control or another agency (Civil Code 54.2) |
| Colorado | Trainers and handlers with a dog being trained as a service animal, without extra charge (per MSU's table) |
| Florida | Any trainer, while training, has the same access rights (per MSU's table) |
| Georgia | New in 2026 (HB 668): the dog must be at least six months old and reliably housebroken |
| Hawaii | MSU's table marks Hawaii as not covering dogs in training |
| Kentucky | Any assistance dog trainer carrying trainer identification |
| Louisiana | Any trainer or puppy raiser during training |
| Maine | "Specially trained" trainers while actually training |
| Maryland | Any professional or volunteer trainer or raiser |
| Massachusetts | Anyone raising or training a service dog |
| Michigan | Any "animal raiser or trainer" since 2023, with the dog on a harness, leash or tether |
| Minnesota | "Any person training a dog to be a service dog" |
| Mississippi | Professional trainers, or volunteers working with one |
| Missouri | Trainers "from a recognized training center" |
| Montana | Any trainer; the dog must wear gear that says in writing it is a service animal in training, legible from 20 feet |
| Nebraska | A "bona fide trainer" (not defined), public places only |
| Nevada | Any person training a service animal (dog or miniature horse); no ID required |
| New Hampshire | Defined categories of service animal trainers |
| New Jersey | Only trainers employed by a recognized training organization |
| New Mexico | Unclear in the statute |
| New York | Any person engaged in training |
| North Carolina | Any trainer; the dog must wear a collar and leash, harness or cape identifying it as in training |
| Texas | When accompanied by an approved trainer (per MSU's table) |
Who counts as a trainer in your state?
This is where owner-trainers most often get caught out. In Nevada, Minnesota, New York or Michigan, any person training a dog has access. In New Jersey, only trainers employed by a recognized training organization do, and Missouri limits it to trainers "from a recognized training center". If your state limits access to professionals, an owner-trainer may have no access at all until the dog is trained, even though the ADA would cover the finished dog. Check your state page before your first outing.
Tags and gear some states require
Unlike the ADA, some states attach conditions to training access:
- California: the dog must be on a leash and tagged "by an identification tag issued by the county clerk, animal control department, or other agency". A private tag or registry card does not meet this.
- Montana: a leash, collar, cape, harness or backpack that "identifies in writing that the animal is a service animal in training", visible and legible from at least 20 feet.
- North Carolina: a collar and leash, harness or cape "that identifies the animal as a service animal in training".
- Kentucky: the trainer must carry trainer identification.
Where a state asks for visible "in training" gear, an in-training vest can meet that description. It does not create access where your state gives none. See service dog in training vests.
Can a service dog in training fly?
Not as a service dog under federal rules. The DOT form's instructions say "service animals in training are not service animals for purpose of this form." Some airlines go further on their own: in our survey, Alaska and Hawaiian may carry puppy raisers' dogs with an organization ID card at their discretion, Southwest carries Canine Companions puppies, Allegiant decides case by case, and Delta allows only a professional trainer delivering a dog. Otherwise a dog in training flies as a pet, with the pet fee and carrier rules. See flying with a service dog.
Housing, taxis and other places
HUD's May 2026 enforcement memo focuses on animals that are individually trained, and the federal sources we reviewed do not address dogs still in training directly. Some states do: Montana gives a person training a service animal "the same rights" as a person with a disability, which include its housing provisions. Nevada bars public conveyances from charging a fee or deposit for a service animal in training (NRS 706.366). For everything else, read your state's page.
Calling a pet a dog in training is not a loophole
Several states make it a crime to misrepresent a dog as a service animal in training, not just as a service animal. Nevada's NRS 426.805 covers both, with a fine of up to $500, and Michigan's law covers "a service animal, or a service animal in training". A vest that says "in training" on a pet that is not being trained is exactly what those laws target. See fake service dog laws.
Can you pet a service dog in training?
Ask first, and accept "no" as the usual answer. A dog in training is learning to ignore strangers, and every greeting undoes a little of that work. Speak to the handler, not the dog. More in can you pet a service dog?
Common questions
Are service dogs in training protected by the ADA?
No. The ADA covers only dogs that are already trained. Any access for a dog in training comes from state or local law.
Can service dogs in training go anywhere?
No. Where they may go depends on your state, and many states limit access to certain trainers or add conditions such as a tag or visible gear.
Can service dogs in training fly on planes?
Not as service dogs. The DOT form excludes them. A few airlines carry some trainers' dogs at their discretion; otherwise the dog flies as a pet.
Do service dogs in training have to wear a vest?
Not under the ADA, which does not cover them at all. Some states, such as Montana and North Carolina, require gear that identifies the dog as in training.
Do service dogs in training have housing rights?
Federal law does not address them specifically. A few states, such as Montana, give trainers the same rights as handlers, including housing.
Can you pet a service dog in training?
Ask the handler first, and expect a no. Distractions set back the dog's training.
Sources
- DOJ, ADA Requirements: Service Animals FAQ (question 6)
- Nevada NRS 651.075 and 426.805
- California Civil Code 54.2
- Michigan MCL 750.502c
- Montana MCA 49-4-214
- North Carolina G.S. 168-4.2
- Georgia HB 668 (2026)
- MSU Animal Legal and Historical Center, table of state assistance animal laws
General information, not legal advice. Policies and laws change; follow the sources. Last checked September 25, 2026.