OBJECTIVE: To characterize the prevalence of functional limitations among older adults with cognitive impairment without dementia (CIND). METHODS: Secondary data analysis was performed using the Aging, Demographics, and Memory Study data set. A total of 856 individuals aged ≥ 71 years were assigned to 3 diagnostic cognitive categories. A questionnaire was completed by a proxy informant regarding functional limitations for 744 of the 856 respondents. RESULTS: Of the 744 patients, 263 (13.9%) had dementia, 201 (21.3%) had CIND, and 280 (64.8%) had normal cognition. Informants reported ≥1 instrumental activities of daily living (ADLs) limitation in 45% of the patients with CIND compared to 13% of the patients with normal cognition and 85% of the patients with dementia (P < .001). The ADL impairments among individuals with CIND were primarily attributed to physical health problems (n = 41; 40%). CONCLUSIONS: Many individuals with CIND have impairment in a range of complex and basic daily activities, largely due to physical health problems.