
The Equality and Human Rights Commission (EHRC) describes reasonable adjustments as steps an employer must take to remove or reduce disadvantages faced by disabled people in the workplace [1]. Employers are only required to make adjustments that are reasonable, which depends on the specific circumstances and the nature of the job.
This article is for informational purposes only and aims to help employers navigate this complex area of law by explaining the definition of disability and outlining when reasonable adjustments are required. It also provides practical examples and current best practices to enable HR professionals and businesses to apply the law confidently and fairly.
Legal duty: Employers must make reasonable adjustments in recruitment, working arrangements, physical premises, and the provision of equipment or aids.
When it applies: The duty arises when an employer knows - or should reasonably know - an employee is disabled and at a substantial disadvantage.
Defining reasonable: Tribunals consider factors such as effectiveness, practicality, cost, and available support when determining whether an adjustment is reasonable.
Common adjustments: Offering flexible hours, hybrid working, adapted equipment, reallocation of duties, and accessible communication formats.
Process matters: Employers should identify needs early, consult with the employee, document all decisions, and review adjustments on a regular basis.
Beyond compliance: Embedding adjustments within broader diversity and wellbeing strategies strengthens culture, retention, and reputation.
Support and resources: EHRC, GOV.UK, and specialist charities provide guidance and funding options.
The Equality Act (‘the Act’) consolidated previous discrimination laws into one statute, covering nine protected characteristics, including disability. Under sections 20 and 21 of the Act, employers must take reasonable steps to avoid substantial disadvantages caused by workplace arrangements, physical features, or lack of auxiliary aids.
The duty applies to:
Failure to comply could amount to discrimination under section 21 of the Act and expose employers to tribunal claims, where compensation is uncapped.
A person is considered disabled 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; “long-term” means lasting at least 12 months or likely to recur. See section 6 of the Act for the full definition.
Examples of conditions that may qualify as disabilities include a range of physical, sensory, mental health, and neurodiverse conditions.
The interpretation of ‘disability’ and its application in the workplace have been considered in several key cases. In Goodwin v the Patent Office [1999] ICR 302 (EAT), the Employment Appeal Tribunal confirmed that determining whether an impairment has a substantial and long-term adverse effect requires an objective assessment of the employee’s abilities without taking account of measures such as medication or coping strategies.
Similarly, in Paterson v Commissioner of Police of the Metropolis [2007] IRLR 763, the Employment Appeal Tribunal recognised dyslexia as a qualifying disability, highlighting that even conditions that can be managed may still meet the statutory definition if they cause a real and persistent disadvantage in performing normal activities.
The obligation to make reasonable adjustments arises when:
This knowledge may come through employee disclosure, medical evidence, observation, or obvious indicators such as repeated absences or visible impairment. Employers must therefore ensure managers are trained to recognise when to explore potential adjustments.
The duty is anticipatory during recruitment and becomes reactive once an individual is employed. This means employers must think ahead and plan for potential barriers that disabled applicants might face, rather than waiting for someone to request adjustments. For example, job adverts should already avoid unnecessary or overly restrictive requirements that could deter disabled applicants, such as demanding a driving licence when travel is not a core part of the role. Employers should also ensure that recruitment materials, application processes, and interview arrangements are accessible from the outset.
Once a person is employed, the duty shifts to responding directly to the employee’s needs by making reasonable adjustments that enable them to perform their role effectively. This could include modifying working hours, providing specialised equipment, adjusting performance targets, reallocating certain tasks, or making physical changes to the workplace. The key point is that employers must consider the unique circumstances of the employee and take practical steps to remove or reduce any disadvantage they may face because of their disability. These adjustments should be discussed with the employee and reviewed over time to ensure they remain appropriate and effective.
Employers can take numerous steps depending on individual needs, typically grouped into the following categories.
Even small changes can make significant differences. According to NHS Employers guidance, most workplace adjustments cost less than £100, whilst many cost nothing at all and simply require a change to a process or a policy, yet deliver measurable performance [2].
There is no fixed list of reasonable adjustments. Tribunals consider the:
Reasonableness is judged case by case and will depend on the size and resources available to the employer. A small employer is not expected to invest in major building work if alternative solutions exist but should still explore proportionate measures such as re-allocating duties or allowing homeworking.
EHRC guidance emphasises that employers should focus on outcomes, not just cost - the goal is to remove barriers effectively and sustainably [3]. Tribunals will weigh both the effectiveness of the adjustment and the impact on the business when determining reasonableness.
These cases highlight that reasonable adjustments extend beyond physical modifications to encompass workplace policies, procedures, and performance expectations. Employers who engage proactively, make decisions transparently, and maintain clear documentation are far better placed to defend potential claims. The EHRC’s Employment Statutory Code of Practice remains a key point of reference in this regard for continuing guidance [4].
A structured and well-documented process is essential to demonstrate compliance and ensure consistency in practice.
It’s important to remember to keep written records, including meeting notes and rationale for decisions, at all stages of the process as these can be valuable evidence should a dispute arise. ACAS advises confirming adjustments in writing and reviewing them at least annually or after any significant changes in role or health [5].
Many adjustments are inexpensive or cost neutral. Examples include changing work hours or reallocating duties. When equipment or specialist support is required, external funding and advice may be available.
Access to Work, a Department for Work and Pensions scheme, provides financial support for equipment, software, travel, and job-coaching services for people with disabilities [6]. Grants are paid directly to suppliers, meaning employers often incur no net expense.
Other external sources include:
It’s worth noting however that cost alone rarely justifies inaction. Tribunals assess whether the employer explored all alternatives. The case Cordell v Foreign & Commonwealth Office (2012) shows that even where an adjustment was extremely costly, transparent evaluation of options and reasoning was critical.
Even well-intentioned employers sometimes fall short in implementing reasonable adjustments. The most frequent difficulties arise from poor communication, inconsistent application of policies, or delays in taking action.
The EHRC recommends embedding clear internal procedures, supported by training and communication plans, so managers know when to seek HR or occupational-health advice [7].
For many HR teams, the challenge lies not in understanding the duty itself but in balancing it with operational realities. Adjustments should be approached as problem-solving exercises, guided by the principles set out below.
By focusing on outcomes rather than rigid processes, employers can balance fairness with practicality while demonstrating compliance.
Occupational health input can be invaluable in assessing an individual’s capabilities and recommending proportionate adjustments. However, medical advice should inform, not dictate, decisions. Employers must still evaluate whether recommendations are practical and sustainable.
Where internal occupational health support is unavailable, employers may seek assistance from external occupational health providers or explore relevant NHS or local employment support services. Employers must obtain the employee’s consent before requesting medical information and handle such data in accordance with the UK GDPR, the Data Protection Act 2018, and the ICO’s employment guidance.
Adjustments are not limited to physical or sensory disabilities. Conditions such as anxiety, depression, or autism may require tailored approaches. The Health and Safety Executive (HSE) emphasises that psychosocial risk management should be integrated into workplace health and safety frameworks.
For mental health, adjustments may include:
Employees who have neurodivergent conditions may benefit from flexible communication styles, assistive technology, or sensory adaptations. The CIPD Neuroinclusion at work report highlights that inclusive design benefits all employees, not only those with diagnosed conditions. It emphasises that workplace adjustments and flexible practices - such as clear communication, varied working environments, and options for how work is completed - can improve wellbeing, engagement, and productivity for everyone [8].
Reasonable adjustments are most effective when part of a broader inclusion strategy. Employers who normalise adjustments from recruitment onwards reduce stigma and encourage early disclosure. Key steps for cultivating an inclusive culture include embedding disability inclusion within HR policies, diversity strategies, and wellbeing frameworks; providing training for managers on disability awareness, communication, and flexibility; ensuring IT, buildings, and communication platforms meet accessibility standards; engaging staff networks or consultation forums in policy development; and having senior leaders communicate commitment to inclusion and model good practice.
According to the Business in the Community (BITC) report - Everyday Inclusion: What Really Works? - organisations that develop genuinely inclusive working cultures, where people feel they belong, are valued for their whole selves, and have a voice, are more likely to experience stronger engagement, better productivity and enhanced innovation outcomes [9].
Once implemented, adjustments should not be left unchecked. Regular review ensures they remain effective and aligned with both the employee’s needs and the organisation’s operational context.
Reviews might take place after a change in role or working environment, when new technology becomes available, following feedback from the employee or line manager, or as part of annual performance or wellbeing reviews.
Documenting review outcomes provides evidence of compliance and ongoing commitment. Employers should also record reasons where adjustments are modified or withdrawn, maintaining transparency and consistency.
The duty to make reasonable adjustments intersects with many other HR policies. For example, attendance triggers in absence management should be modified where disability contributes to absence. Performance management targets may need adjustment if standard criteria disadvantage a disabled worker. Requests under flexible working regulations can overlap with adjustments, though they remain distinct legal frameworks. Adjustments should also align with health and safety requirements, including safe working practices and risk assessments.
Integrating adjustment considerations into these policies ensures consistent treatment and reduces the likelihood of procedural errors or disability discrimination.
Beyond compliance, the business case for reasonable adjustments is compelling. According to data from the Department for Work and Pensions’ Disability Confident employer scheme, disabled people represent over 20% of the working-age population [9]. Inclusive employers access a wider talent pool, reduce turnover, and enhance reputation.
Studies by the Chartered Institute of Personnel and Development (CIPD) show that inclusive workplaces experience improved employee engagement and innovation [10]. Many adjustments enhance productivity for all staff, such as flexible hours, quiet working zones, or improved digital tools.
As hybrid and remote working become embedded, expectations around reasonable adjustments are changing. The EHRC has confirmed that the duty applies equally to home-based arrangements - employers must consider how digital tools, communication methods, and supervision models can be adapted for disabled employees [11].
Emerging trends include ensuring digital accessibility so that collaboration platforms and software are compatible with assistive technologies, embedding inclusive design into systems and policies from the outset, and using anonymised workforce data to monitor adjustment patterns and effectiveness.
Legislative updates may also arise as part of the UK Government’s ongoing review of workplace equality frameworks. In particular, HR teams should remain alert to guidance updates from the Equality and Human Rights Commission (EHRC), Advisory, Conciliation and Arbitration Service (ACAS) and GOV.UK. Key forthcoming reforms include the draft Equality (Race and Disability) Bill, which will introduce mandatory ethnicity and disability pay‑gap reporting for employers with 250+ staff and may extend equal pay claims to cover race and disability. Also, the Government’s “Call for Evidence” into equality law reform signals possible changes around pay transparency, combined discrimination protection, and the Public Sector Equality Duty.
Employers seeking to comply with the Equality Act and promote inclusion should be aware of the legal duty under sections 20–21 of the Equality Act and have clear processes for identifying and implementing adjustments.
Early, open communication with employees is essential, alongside thorough documentation and regular review. Adjustments should also be integrated with broader diversity and wellbeing strategies.
Reasonable adjustments are not only a legal requirement but also a marker of good employment practice. By taking proportionate, thoughtful, and transparent action, employers can meet statutory obligations while fostering workplaces where all individuals can contribute fully.
By applying the principles outlined in this guide, employers can not only meet their legal duties but also build workplaces that truly value diversity, equity, and human potential.
This article is intended for informational purposes only and does not constitute legal advice. The information is accurate at the time of writing but may be subject to change. For advice specific to your situation, please consult a qualified professional.
[1] The Equality and Human Rights Commission (EHRC), Supporting disabled workers with hybrid working: Guidance for employers. 5 September 2025.
[2] NHS Employers. Making workplace adjustments to support disabled staff. 8 December 2023.
[3] EHRC. Employing people: workplace adjustments. 18 November 2019.
[4] EHRC. Employment: Code of Practice. 4 September 2015.
[5] Acas. The law on disability discrimination. 11 September 2023. [6] GOV.UK. Access to Work: get support if you have a disability or health condition.
[7] EHRC. Good equality practice for employers: equality policies, equality training and monitoring. Guidance for employers, volume 7 of 7.
[8] CIPD. Neuroinclusion at work report 2024.
[9] BITC report. Everyday Inclusion: What Really Works? 5 November 2020.
[10] CIPD. Equality, diversity and inclusion (EDI) in the workplace. 14 August 2024.
[11] EHRC. Supporting disabled workers with hybrid working: Guidance for employers. 5 September 2024.