The duty to make reasonable adjustments is one of the most distinctive features of UK equality law. It’s the legal mechanism that requires employers, service providers, schools and others to take active steps to remove disadvantages faced by disabled people — not just to avoid discriminating against them, but to make positive changes so they can participate on a comparable basis with everyone else.
This guide explains what the duty actually requires, the three situations that trigger it, what counts as ‘reasonable’, how to handle requests and assessments in practice, and the most common reasons employers find themselves in front of an Employment Tribunal on this issue.
What the duty says
The duty is set out in section 20 of the Equality Act 2010, supplemented by Schedule 8 for employment situations and Schedule 2 for service providers. Section 21 makes failure to comply with the duty a form of discrimination — meaning the employer or service provider doesn’t have to have done anything actively unfair; failing to make an adjustment that should have been made is itself unlawful.
Crucially, the duty applies only to the protected characteristic of disability. The other eight protected characteristics under the Act don’t carry a reasonable adjustments duty (though they have their own protections against direct and indirect discrimination). Disability is defined in section 6 of the Act as a physical or mental impairment that has a substantial and long-term adverse effect on a person’s ability to carry out normal day-to-day activities. The fuller treatment of who counts as disabled is in our guide to the nine protected characteristics.
Who the duty applies to
The Equality Act duty applies in Great Britain in employment, services, education, premises, public functions and qualifying associations. Different schedules modify its operation in each context; it is not an identical requirement everywhere.
Employers — including recruitment processes, throughout employment, and in some post-employment situations such as references and pension administration.
Service providers
Shops, restaurants, hotels, banks, transport providers, anyone offering services to the public or a section of the public.
Education providers
Schools, colleges, universities, training providers.
Housing providers
Landlords (residential and commercial), housing associations, estate agents.
Public functions
When public bodies are exercising their public functions, alongside their wider duties under the Public Sector Equality Duty.
Associations — clubs and similar bodies with 25 or more members.
The employer or other duty-holder is responsible for providing reasonable adjustments. Managers act on the organisation’s behalf. Individuals can also face liability under other Equality Act provisions where they personally discriminate or assist unlawful conduct.
The three trigger situations
Section 20 sets out three distinct situations in which the duty arises. Understanding them separately matters because the response to each is different.
Provision, criterion or practice (PCP)
A provision, criterion or practice can place a disabled person at a substantial disadvantage compared with non-disabled people. It may be a formal rule or an established way of working. A one-off decision is not automatically a PCP; whether it demonstrates a practice depends on the facts.
Examples include a requirement to work specific hours that conflict with treatment schedules; an expectation that all communication is by phone, which disadvantages a deaf employee; a rotational shift pattern that disrupts the routine an autistic employee depends on; an attendance policy that triggers warnings based on absence levels without considering disability-related sickness.
Physical features
The second situation arises where a physical feature of premises puts a disabled person at a substantial disadvantage. The feature might be a step at the entrance, the layout of furniture, the height of work surfaces, the brightness or volume of the environment, the absence of accessible toilets.
For employers, the duty extends to physical features of the workplace. For service providers, it extends to physical features of premises from which services are provided.
Auxiliary aids and services
The third situation arises where a disabled person would, but for the provision of an auxiliary aid, be at a substantial disadvantage. An auxiliary aid might be assistive software, a specialist keyboard, voice recognition technology, a screen reader, an induction loop, a BSL interpreter, a support worker.
The three triggers overlap in practice. A disabled employee who can’t access the upper floor of an office because the only route is by stairs is facing a physical feature problem; if there’s a lift available but they need a key to use it, the lack of routine key provision is a PCP problem; if they need an evacuation chair, that’s an auxiliary aid issue.
What ‘reasonable’ means
The Equality Act doesn’t define ‘reasonable’ in detail, but case law and the Equality and Human Rights Commission’s statutory codes of practice identify several relevant factors:
- The effectiveness of the adjustment in removing the disadvantage.
- The practicability of making it.
- The financial cost relative to the employer’s resources.
- The disruption it would cause.
- The availability of financial or other assistance (such as Access to Work funding).
- The nature of the employer’s activities and size.
Reasonableness depends on the particular disadvantage, the adjustment’s effectiveness and practicalities, resources and relevant risks. Size alone does not decide the issue: a small employer may still be required to make an effective low-cost change.
An employer’s preference for its existing arrangements does not settle the question. Cost and disruption are relevant but must be assessed in context, alongside whether the proposed change would address the disadvantage.
Adjustments by functional need, not by condition
Most guidance on reasonable adjustments lists examples by condition: ‘adjustments for dyslexia’, ‘adjustments for autism’, ‘adjustments for chronic fatigue syndrome’. This is useful as a starting point but misleading in practice. The Equality Act doesn’t care about the label; it cares about the impact.
A more useful frame organises adjustments by the functional need they address:
Sensory needs
Quieter spaces, dimmable lighting, noise-cancelling headphones, screen brightness controls, reduced sensory load in shared areas. Relevant for autistic employees, employees with migraines, employees with PTSD, employees with sensory processing differences regardless of underlying diagnosis.
Cognitive load
Written instructions following verbal ones, advance agendas for meetings, breaking complex tasks into smaller steps, reducing context-switching, structured handover documents. Relevant for employees with ADHD, dyslexia, brain injury, long Covid, depression, anxiety — the underlying cause is less important than the cognitive impact.
Communication needs
Email rather than phone, captions on video calls, written rather than verbal feedback, advance notice of changes, BSL interpretation. Relevant for deaf or hard-of-hearing employees, autistic employees who prefer written communication, employees with anxiety, employees whose first language isn’t English.
Physical access
Lifts, ramps, accessible toilets, ergonomic workstations, adjustable desks and chairs, parking close to the entrance, accessible routes. Relevant for wheelchair users, employees with mobility impairments, employees recovering from surgery, pregnant employees, employees with chronic pain.
Flexibility
Adjusted hours, phased return from sickness absence, breaks during the day, working from home some or all of the time, flexible attendance requirements, time off for medical appointments. Relevant across most disabilities.
Focus on the person’s needs and discuss possible changes rather than assuming a diagnosis dictates one solution. Some examples above may also help people who are not disabled, such as pregnant employees or people learning English; that does not itself create a disability reasonable-adjustment duty for those individuals.
Anticipatory duty vs reactive duty
There’s an important distinction in how the duty applies to different contexts.
For service providers, the duty is anticipatory: they should consider disabled people’s likely access needs before a particular customer requests help. The reasonable steps required depend on the circumstances; this is not an unconditional rule that every restaurant must install a particular facility.
In employment, the duty generally depends on the employer knowing, or reasonably being expected to know, about the disability and substantial disadvantage. Premises and landlord duties have their own rules, including request requirements and limits on physical alterations; they should not be treated as identical to employment duties.
In practice, sensible employers operate partly on an anticipatory basis anyway. A workplace designed with accessibility in mind from the start avoids the cost and disruption of retrofitting later.
How to handle requests
A workable process for handling adjustment requests has four stages.
Open the conversation
Requests can arise during recruitment or employment, including when needs change. Provide a clear route and discuss the disadvantage promptly. Employees do not need to use legal terminology to alert an employer to a possible need.
Understand the need
What’s the actual problem? What are the impacts on the employee’s ability to do the job? This often means a conversation with the employee, sometimes supplemented by occupational health advice. The employee is usually the best authority on what works for them. An employer doesn’t need a medical diagnosis to make adjustments — ACAS guidance is clear on this. What’s needed is enough information to understand the impact and the proposed solution.
Decide what’s reasonable
Consider effectiveness, practicality, cost and alternatives. The duty is to take reasonable steps to avoid the substantial disadvantage; it does not guarantee that every disadvantage can be removed or that the exact requested change must be provided.
Document and implement
Record the discussion, the decision, the rationale, and the adjustment itself. Where adjustments will travel with the employee through future role changes, a ‘workplace adjustment passport’ that captures them avoids the employee having to re-explain their needs every time.
Who pays for adjustments
The cost of reasonable adjustments falls on the employer or service provider. The disabled person doesn’t pay for their own adjustments.
In Great Britain, the individual can apply for Access to Work for eligible support beyond the employer’s reasonable-adjustment duty. An employer may be involved and may have to share some costs. Northern Ireland runs a separate scheme. Access to Work does not replace or subsidise the employer’s statutory duty.
The fact that funding is available doesn’t change the employer’s underlying duty. If an adjustment is reasonable, it should be made even where Access to Work funding is delayed or unavailable.
What happens when an adjustment isn’t made
A breach of the applicable duty is discrimination under section 21. Employment claims generally go to an Employment Tribunal; services and premises claims generally go to the County Court in England and Wales or sheriff court in Scotland. Education has specific routes and remedies, including specialist tribunals for some school claims. Do not assume all education claims attract injury-to-feelings compensation.
The outcome depends on the disability, disadvantage, employer knowledge where relevant, and reasonable steps available. Keep records of requests, decisions, implementation and review; a refusal or delay should be assessed against the actual legal duty.
Common mistakes
A few patterns come up repeatedly.
Requiring a formal diagnosis before considering an adjustment
The Equality Act doesn’t require a diagnosis to consider someone disabled, and ACAS guidance is clear that employers should engage with adjustment requests even without one. Insisting on diagnosis can itself be discriminatory where the practical need is clear.
Treating the duty as optional
Some employers approach adjustments as a ‘nice to have’ that they’ll do if it’s convenient. The duty is a legal obligation, and failure is actionable.
Confusing ‘reasonable’ with ‘convenient’
What’s reasonable depends on cost, practicability and disruption — not on whether the adjustment fits the employer’s existing way of doing things.
Failing to keep records
Adjustment requests, the rationale for decisions, and the adjustments themselves should be documented. Tribunals routinely look at how decisions were made, not just at what was decided.
Withdrawing adjustments without consultation
An adjustment that’s been agreed shouldn’t be withdrawn unilaterally because of a management change, an office move or a policy refresh. Adjustments are part of the employment relationship and need to be reviewed in dialogue.
Frequently asked questions
What is a reasonable adjustment?
A change an employer, service provider, school or other duty-holder makes to remove a substantial disadvantage faced by a disabled person — for example providing assistive technology, changing working hours, adjusting policies, modifying physical premises, or supplying an auxiliary aid.
Who has to make reasonable adjustments?
Employers and other duty-holders in Great Britain, including services, education, premises and qualifying associations. The applicable schedule changes the scope; an association generally needs at least 25 members and rules regulating admission with a selection process.
Do I need a diagnosis to request adjustments?
No. The Equality Act doesn’t require a formal diagnosis to be considered disabled, and ACAS guidance is clear that employers should engage with adjustment requests on the basis of the practical need, not on documentation alone.
What’s the difference between anticipatory and reactive duty?
Service providers should consider disabled people’s needs in advance. Employment duties normally depend on actual or reasonably expected knowledge of the disability and disadvantage. Landlord and education duties have separate detailed rules.
Who pays for reasonable adjustments?
The duty-holder cannot charge the disabled person for required adjustments. Access to Work may fund eligible additional employment support, but does not replace the employer’s reasonable-adjustment duty.
What if my employer refuses to make adjustments?
Seek advice promptly and consider raising the issue internally. For most Great Britain tribunal claims, the limit is three months minus one day for problems before 1 October 2026 and six months minus one day for problems from that date. Notify Acas in time; timely conciliation can pause the limit, but a grievance does not.
Reasonable adjustments are one of the most actively litigated provisions of the Equality Act 2010. They sit alongside the wider framework of the nine protected characteristics and the duties of public bodies under the Public Sector Equality Duty. To train your managers to handle adjustment requests well — confidently, lawfully, and in a way that doesn’t end in tribunal — our Equality, Diversity & Inclusion Training course covers the duty in detail with worked examples and current case law.
Related guides
- Equality Act 2010: The Complete UK Guide
- The Nine Protected Characteristics Under the Equality Act 2010
- Equality and Diversity in Health and Social Care: A UK Guide
Sources & references
- Equality Act 2010, section 20 and applicable schedules
- Acas: reasonable adjustments at work
- Acas: disability and diagnosis
- DWP: Access to Work scope and employer duties
- EHRC: services, public functions and associations code
- Acas: tribunal time limits
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Mark writes about workplace equality, diversity & inclusion and accredited online training for Equality, Diversity & Inclusion Training, part of Online CPD Academy.