Reasonable Adjustments: What the law requires vs good practice

Many UK organisations understand that they have a duty to make reasonable adjustments for disabled people, but uncertainty often arises around what counts as reasonable, when the duty applies, and how decisions should be made. As a result, adjustments are sometimes handled inconsistently, delayed unnecessarily, or treated as discretionary rather than legally required.

This article explains what the Equality Act 2010 requires in relation to reasonable adjustments, how disability is defined in law, and how organisations can move beyond minimum compliance to build clear, fair, and workable adjustment processes. The guidance is based on UK legislation and statutory sources.

At a glance

• Employers have a legal duty to make reasonable adjustments for disabled people

• The duty arises where a disabled person is placed at a substantial disadvantage

• What is “reasonable” depends on context, not opinion

• Good processes reduce risk, delay, and conflict
  
  

What are reasonable adjustments under UK law?

Under the Equality Act 2010, employers must take reasonable steps to avoid disabled people being placed at a substantial disadvantage compared to non-disabled people. This duty applies to job applicants, employees, and workers.

The duty covers three broad areas:

1. Provisions, criteria, or practices (for example, rigid working hours or assessment methods)

2. Physical features of the workplace

3. Auxiliary aids and services, such as specialist equipment or support
   
   

Statutory guidance confirms that the duty is anticipatory in some contexts and must be considered proactively rather than only after problems arise.

Primary sources

• Equality Act 2010, sections 20–21
  https://www.legislation.gov.uk/ukpga/2010/15/section/20

• UK Government Equality Act guidance
  https://www.gov.uk/guidance/equality-act-2010-guidance
  
  

How disability is defined in the Equality Act

A person is considered disabled under the Equality Act if they have a physical or mental impairment that has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities.

“Substantial” means more than minor or trivial, and “long-term” generally means the impairment has lasted, or is likely to last, at least 12 months.

Importantly:

• A formal diagnosis is not always required

• Conditions may fluctuate

• Mental health conditions and neurodevelopmental conditions can meet the definition

Authoritative source

• UK Government statutory guidance on disability definition
  https://assets.publishing.service.gov.uk/media/5a80dcc8ed915d74e6230df4/Equality_Act_2010-disability_definition.pdf
  
  

When does the duty to make adjustments arise?

The duty arises when:

• the employer knows, or could reasonably be expected to know, that a person is disabled; and

• a workplace practice, feature, or lack of support places that person at a substantial disadvantage
  
  

The Equality and Human Rights Commission (EHRC) makes clear that employers cannot avoid the duty by remaining passive or failing to engage.

EHRC guidance:
https://www.equalityhumanrights.com/equality/equality-act-2010

What counts as “reasonable”?

There is no fixed list of reasonable adjustments. Tribunals consider factors including:

• the effectiveness of the adjustment

• practicality

• cost and resources

• the size and nature of the organisation

• availability of external support
  
  

What is reasonable for a large organisation may differ from what is reasonable for a small one, but cost alone is rarely sufficient justification for refusing an adjustment.

Common examples of reasonable adjustments

Depending on context, reasonable adjustments may include:

• changes to working hours or patterns

• modified duties or role expectations

• alternative formats or communication methods

• assistive technology or specialist equipment

• adjustments to recruitment or assessment processes

• changes to policies or performance management procedures
  
  

These examples are drawn from statutory guidance and case summaries referenced by Acas and the EHRC.

Common mistakes organisations make

Treating adjustments as discretionary
Reasonable adjustments are a legal duty, not a benefit or favour.

Waiting for “proof” before acting
Delays caused by unnecessary medical evidence requests can place organisations at risk.

Applying blanket rules
Decisions must be individual and evidence-based.

Failing to document decisions
Lack of records makes it difficult to demonstrate lawful reasoning if challenged.

The Acas highlights that poor process, rather than refusal itself, is a frequent source of disputes:
https://www.acas.org.uk

What good practice looks like

Good practice goes beyond minimum compliance and focuses on:

• early, supportive conversations

• collaborative problem-solving

• clear decision-making frameworks

• documented outcomes and review points

• confidentiality and dignity
  
  

Organisations that embed clear adjustment processes tend to reduce conflict, grievances, and escalation.

A simple reasonable adjustments process

A proportionate, lawful process usually includes:

1. Request or identification of a potential adjustment need

2. Discussion with the individual about barriers and options

3. Assessment of reasonableness using clear criteria

4. Decision and implementation

5. Review to ensure effectiveness
   
   

This approach aligns with guidance from Acas and the EHRC.

Practical checklist for employers

• Do managers understand the legal duty to make adjustments?
  
  

• Are requests handled consistently across teams?
  
  

• Are decisions recorded with clear reasoning?
  
  

• Is confidentiality maintained?
  
  

• Are adjustments reviewed over time?
  
  

Frequently asked questions

Do reasonable adjustments apply to recruitment?
Yes. The duty applies at all stages, including recruitment and selection.

Can an employer refuse an adjustment?
Only if it can demonstrate that the adjustment is not reasonable in the specific circumstances.

Does this apply to small organisations?
Yes, though what is considered reasonable may vary by context.

Disclaimer

This article provides general information about equality and inclusion in the UK. It is not legal advice. Organisations should seek appropriate professional advice for specific situations.

Support

Reasonable adjustments work best when organisations have clear processes that managers understand and can apply consistently. Pathways to Equity supports organisations to design adjustment frameworks that are lawful, proportionate, and workable in practice. Get in touch today to chat.