Abstract Background Past attempts to characterize the earliest cognitive changes as individuals with Down Syndrome (DS) transition from cognitively stable to mild cognitive impairment (MCI) have been equivocal (Garcia‐Alba et al., 2019; Lautarescu et al., 2017). Difficulties identifying MCI in this population are complicated by variability in pre‐morbid cognitive abilities, the use of neuropsychological tests that were created for the neurotypical population, and participants scoring at floor on the baseline assessment (Krinsky‐McHale and Silverman, 2013). Method We examined data from 151 individuals with Down Syndrome (M age=50.25, SD age=6.94). Their pre‐morbid level of intellectual impairment ranged from mild to severe. All participants received comprehensive evaluations. Following data collection, the clinical status of each participant was rated at consensus review that considered performance on a core neuropsychological test battery and the clinical data for each participant. Data from the non‐demented and MCI groups are examined: Cognitive Stable (N=107, 70.9%) and MCI‐DS (N=44, 29.1%). The full battery consists of 27 subtests that were hypothesized a priori to measure five cognitive domains: language, memory, executive function, visuospatial reasoning, and motor coordination. Result Factor analysis revealed 7 principal components that maximally discriminated between test scores in older adults with DS who have not reached clinical AD status: (1) general intelligence (2) sensorimotor, (3) memory, (4) language comprehension and expression, (5) executive function/speed, (6) attention/language expression, and (7) visuomotor. Cluster analysis for the MCI group produced 3 distinct groups: (1) dysexecutive (n=4), (2) dysnomic/visuospatial impaired (n=28), and (3) amnestic/motor impaired (n=12). Conclusion The neuropsychological battery assesses 7 distinct cognitive functions in older adults with DS. It can also capture cognitive decline, as we were able to empirically identify three distinct neuropsychological subtypes of MCI: amnestic/visuomotor impaired, dysexecutive, and dysnomic. These subtypes are generally consistent with those that have been found within the neurotypical population (Edmonds et al., 2015; Dick et al., 2016), strengthening the evidence that AD has a similar course in the DS population and late onset AD.