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Disability Access Audit UK: Equality Act Guide 2026

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Part ofUK Health & Safety Law

Updated June 2026 · England & Wales
If you run premises that the public can use, whether that is a shop, office, restaurant, clinic, gym or community venue, you have duties under the Equality Act 2010 to think carefully about how disabled people experience your space. A disability access audit is the structured way most businesses approach this. It looks at the physical building, the services offered, and the policies that sit behind them, then flags where reasonable adjustments might be needed. This guide, written for owners and managers rather than lawyers, walks through what an audit covers, when to commission one, and how findings typically feed into a prioritised action plan. I have kept the language practical so you can use it as a starting point before deciding whether to bring in a specialist auditor or take advice on a particular concern.

Overview

A disability access audit is a structured assessment of how accessible a building, service or facility is to disabled people. It is not a legal document in itself, and there is no single prescribed format set out in statute. Instead, audits are a working tool that businesses, landlords and public bodies use to evidence their thinking around the anticipatory duty to make reasonable adjustments under the Equality Act 2010.

A typical audit covers the physical approach to a building, entrances, circulation routes, facilities such as toilets and counters, signage, lighting, acoustics, emergency egress, and the way staff deliver services. The output is usually a written report that records what was observed, identifies barriers for people with different impairments (mobility, sensory, cognitive, mental health), and sets out recommendations ranked by priority, cost and feasibility.

Many organisations use BS 8300 as a reference standard alongside Building Regulations Approved Document M, although meeting a technical standard is not the same as meeting the Equality Act duty, which is broader and more situational.

Key steps

  1. Decide the scope of your audit. Start by defining what you want assessed: a single shop floor, an entire office building, a website, or the end-to-end customer journey. Scope drives cost and usefulness. A narrow audit on a new site will feel different to a full estate review, so be clear about boundaries, the audience (staff, customers, visitors), and whether you want policies and training included alongside the physical space.
  2. Gather background information. Pull together floor plans, previous audit reports, lease terms, planning consents, fire strategy documents and any complaints or feedback received from disabled customers or employees. This context helps whoever is carrying out the audit understand constraints, for example listed building status or landlord consent requirements, and avoids recommendations that cannot realistically be delivered on the site in question.
  3. Carry out the on-site assessment. The auditor walks the site using the lens of different disabilities, measuring door widths, gradients, counter heights, lighting levels and contrast, and testing things like hearing loops, lift controls and wayfinding. They will also observe how staff interact with visitors. Photographs, measurements and notes are recorded so that each finding can be traced back to a specific location or feature.
  4. Produce a prioritised action plan. Findings are written up in a report that typically splits recommendations into quick wins, medium-term works and longer-term capital projects. Prioritisation usually reflects the severity of the barrier, the number of people affected, the cost of the change, and whether the adjustment is reasonable given the resources of the organisation. This plan becomes your working document.
  5. Implement, record and review. Assign owners and timescales to each action, keep a written log of what has been done and when, and revisit the audit after major refurbishments, service changes or every few years as a matter of course. Keeping a paper trail is important because the reasonable adjustments duty is anticipatory and ongoing, not a one-off tick-box exercise.

Common questions

If you're dealing with this kind of situation, a call with an experienced legal adviser can help you work out the right next step — from £89.

Common questions

Q Is a disability access audit legally required?
There is no specific legal requirement to commission a formal audit. However, the Equality Act 2010 places an anticipatory duty on service providers and employers to make reasonable adjustments for disabled people. An audit is one of the most practical ways to show you have thought about that duty seriously and acted on what you found. Without some form of structured assessment, it can be harder to demonstrate you took reasonable steps if a complaint or claim arises.
Q Who counts as disabled under the Equality Act 2010?
The Act defines disability 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. This covers a wide range of conditions, including mobility impairments, sensory impairments, learning disabilities, mental health conditions and long-term health conditions. An access audit should consider the whole spectrum, not just wheelchair users, because accessibility barriers affect different groups in different ways.
Q How often should an audit be refreshed?
There is no fixed interval. Many organisations refresh their audit every three to five years, or sooner if there has been a refurbishment, a change of use, a new service line, or feedback suggesting barriers exist. Treat it as a living document. If you move premises, take on a new lease, or open to the public in a new way, an earlier refresh usually makes sense.
Q What does 'reasonable adjustment' actually mean?
Reasonable is judged in context. Factors include the cost and practicality of the change, the resources of the business, the disruption involved, and the benefit to disabled users. A small independent shop is not expected to deliver the same works as a national retailer, but both must think about what they can reasonably do. Low-cost changes, such as moving stock, training staff, or offering assistance, are often considered reasonable even where structural works are not.
Q Do I need a qualified specialist to carry out the audit?
For internal reviews, a trained member of staff using a good checklist can produce useful findings. For a more authoritative report, especially on larger or more complex sites, many organisations engage an access consultant, often one listed on the National Register of Access Consultants. A specialist brings technical knowledge of BS 8300, Building Regulations Approved Document M, and how barriers affect different impairment groups.
Q Does the audit cover digital accessibility too?
A physical access audit usually focuses on the built environment, but digital accessibility sits alongside it and is equally important. Websites, booking systems, apps and self-service kiosks all fall within the reasonable adjustments duty. If your customer journey is largely online, commissioning a separate digital accessibility review against WCAG standards alongside the physical audit gives you a more complete picture.
Q What happens if a disabled customer brings a complaint?
Complaints can be raised directly, through the Equality Advisory and Support Service, or ultimately through the County Court as a claim for disability discrimination. Having an up-to-date audit and a documented action plan helps show the steps you have taken. It will not prevent every claim, but it puts you in a stronger evidential position and often helps resolve concerns before they escalate.
If you're dealing with this kind of situation, a call with an experienced legal adviser can help you work out the right next step — from £89.

Sources

This guide is based on primary UK law and official guidance.

Brad Askew, Solicitor (non-practising)

Written & reviewed by

Brad Askew Solicitor (non-practising)

Brad is on the roll of solicitors of England & Wales but does not hold a practising certificate and does not provide legal advice. LegalDocuments.co.uk is not a law firm and does not provide regulated legal advice.

Legal disclaimer
This article is for general information only. It is a tool to help you find your way — not legal advice, and not a substitute for speaking to a qualified adviser about your situation.