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Reasonable adjustments under the Equality Act 2010: shops, restaurants and services
In Great Britain, a shop, a restaurant, a bank or any other business that serves the public has a duty to make reasonable adjustments for disabled people (Equality Act 2010, section 29, subsection 7). The duty has three parts: changing a way of doing things, dealing with a physical feature of the premises, and providing an extra aid or service; and the disabled customer cannot be made to pay for any of it (Equality Act 2010, section 20, subsections 2 to 7). For services, the duty is owed to disabled people generally, not only to the customer who asks (Equality Act 2010, Schedule 2, paragraph 2(2)). This guide explains section 20 and Schedule 2 of the Act, with the examples the Equality and Human Rights Commission gives in its Code of Practice, and walks through a building from the door to the counter.
This guide summarises the sources it cites; it is not legal advice. The official texts are the reference.
Who has to make reasonable adjustments
The duty falls on a service provider: anyone concerned with providing a service to the public or a section of the public, for payment or not (Equality Act 2010, section 29, subsection 1). That covers a café and a cinema, a hairdresser, a bank branch, a hotel, a gym or a solicitor’s office. Section 29 says that a duty to make reasonable adjustments applies to a service provider, and also to anyone who exercises a public function that is not a service to the public (Equality Act 2010, section 29, subsection 7).
Section 20 sets out what the duty is, and a schedule for each part of the Act adds the details. For services and public functions, Part 3 of the Act, that schedule is Schedule 2 (Equality Act 2010, section 20, subsection 13). On legislation.gov.uk both texts are marked E+W+S: they extend to England, Wales and Scotland (Equality Act 2010, section 20; Equality Act 2010, Schedule 2).
The Equality and Human Rights Commission has issued a statutory Code of Practice for services, public functions and associations. The current one came into force on 5 August 2026, and the 2011 Code was revoked on the same date (EHRC Code of Practice for services (2026)). It has been approved by the Secretary of State and formally laid before Parliament (EHRC Code of Practice for services (2026), paragraph 1.5); it does not impose legal obligations and is not an authoritative statement of the law, but courts and tribunals must consider any part of it that appears relevant (EHRC Code of Practice for services (2026), paragraph 1.6). The examples in this guide come from that 2026 Code.
Section 20: the three requirements
The duty comprises three requirements (Equality Act 2010, section 20, subsection 2). Each one starts from the same test: something puts a disabled person at a substantial disadvantage compared with people who are not disabled, and the service provider has to take such steps as it is reasonable to have to take. Substantial, the Code explains, is defined in the Act as more than minor or trivial (EHRC Code of Practice for services (2026), paragraph 7.11).
| Requirement | When it applies | What the service provider does | Section |
|---|---|---|---|
| 1. Provision, criterion or practice | a rule, policy or way of doing things puts disabled people at a substantial disadvantage | takes reasonable steps to avoid the disadvantage | Equality Act 2010, section 20, subsection 3 |
| 2. Physical feature | a physical feature puts disabled people at a substantial disadvantage | takes reasonable steps to avoid the disadvantage: removing the feature, altering it or providing a reasonable means of avoiding it; for services, also a reasonable alternative method of providing the service | Equality Act 2010, section 20, subsections 4 and 9; Equality Act 2010, Schedule 2, paragraph 2(3) |
| 3. Auxiliary aid | without an auxiliary aid, disabled people would be put at a substantial disadvantage | takes reasonable steps to provide the auxiliary aid, which includes an auxiliary service | Equality Act 2010, section 20, subsections 5 and 11 |
- A provision, criterion or practice is a rule or a habit of the business. There is no definitive list of what one is (EHRC Code of Practice for services (2026), paragraph 7.10). In the Code’s example, a disabled customer with severe arthritis cannot stand in a post office queue for more than a couple of minutes; depending on the size of the post office, staff could ask him to take a seat and serve him as if he had queued, or provide a separate service desk with seating (EHRC Code of Practice for services (2026), paragraph 7.38). A ‘no dogs’ policy is another: it shuts out visually impaired people who use guide dogs, though not those who only use a white cane, and the duty is owed to both groups (EHRC Code of Practice for services (2026), paragraph 7.28).
- A physical feature is anything that comes from the design or construction of a building; a feature of an approach to, exit from or access to a building; a fixture, fitting, furniture, furnishings, materials, equipment or other chattels in or on the premises; or any other physical element or quality (Equality Act 2010, section 20, subsection 10).
- An auxiliary aid or service is anything that provides additional support or assistance to a disabled person. The Code’s examples include portable ramps or handrails, signage or notices, a special piece of equipment or assistive technology, a sign language interpreter, lip-speaker or deaf-blind communicator, extra staff assistance, electronic transcription services, an induction loop or infrared broadcast system, video interpreting services, audio-visual fire alarms, screen readers or in-person readers for people with visual impairments, assistance with guiding, and telephone services to supplement other information (EHRC Code of Practice for services (2026), paragraph 7.63).
When the first or third requirement is about information, the reasonable steps include making sure the information is provided in an accessible format (Equality Act 2010, section 20, subsection 6). The Code’s example is a museum that changes the print size and the design of its leaflets for partially sighted visitors and writes them in clear language; depending on its size and resources, it may also need braille or easy-read versions (EHRC Code of Practice for services (2026), paragraphs 7.59 and 7.60).
Section 20(7): the disabled person does not pay
A service provider that has a duty to make reasonable adjustments is not entitled to require the disabled person to pay, to any extent, its costs of complying with the duty, unless the Act expressly says otherwise (Equality Act 2010, section 20, subsection 7). The Code repeats it (EHRC Code of Practice for services (2026), paragraph 7.53) and gives an example: a library service that runs a free creative writing class and charges a participant with a visual impairment a photocopying fee for enlarging the class materials is likely to be acting unlawfully (EHRC Code of Practice for services (2026), paragraph 7.54).
Where the adjustment is a ramp, a large-print menu or the receiver of a hearing loop, then, the customer pays nothing for it (Equality Act 2010, section 20, subsection 7). What the Act does not require is an aid for personal purposes unconnected with the service, or one the customer takes away after use: in the Code’s example, a solicitors’ firm lends a client a digital recorder to record his instructions, and he gives it back (EHRC Code of Practice for services (2026), paragraphs 7.67 and 7.68).
The ADA in the United States has a similar rule: a business may not impose a surcharge on a person with a disability to cover the cost of the measures the ADA requires (ADA Title III regulations, 28 CFR 36.301(c)); see ADA compliance.
Schedule 2: an anticipatory duty
Schedule 2 applies section 20 to services. Its key line is short: the disabled person in each of the three requirements means disabled persons generally (Equality Act 2010, Schedule 2, paragraph 2(2)). The duty is owed to disabled people as a group, not applied only for each person who walks in (EHRC Code of Practice for services (2026), paragraph 7.20).
That is why the Code calls the duty anticipatory: service providers must proactively consider the barriers that disabled people could face, and act on them, before an individual disabled person tries to use the service (EHRC Code of Practice for services (2026), paragraph 7.22). A service provider should not wait until a disabled customer turns up; failing to anticipate an adjustment can make it more expensive, or too late to make (EHRC Code of Practice for services (2026), paragraph 7.23).
- Knowing is not required. Because the duty is to disabled people at large, it applies whether or not the business knows that a particular customer is disabled, and whether or not it has disabled customers today (EHRC Code of Practice for services (2026), paragraph 7.25). When a disabled customer seeks to use the service, the business must already have taken all reasonable steps to provide access (EHRC Code of Practice for services (2026), paragraph 7.26).
- Not every individual need. A business is not expected to anticipate the needs of every individual, but it is expected to think about the barriers that people with different kinds of disability may face, for example people with dementia, mental health conditions or mobility impairments (EHRC Code of Practice for services (2026), paragraph 7.27).
- Then the person in front of you. Once a business knows what a particular disabled customer needs, especially when the customer has pointed out the difficulty or suggested a reasonable solution, a particular step may become reasonable (EHRC Code of Practice for services (2026), paragraph 7.29).
- It never ends. The duty is continuing: what was reasonable once may stop being enough (EHRC Code of Practice for services (2026), paragraph 7.32). In the Code’s example, a sports complex admits assistance dogs and gives their users a tour of its routes; when building work changes those routes, offering them extra help from staff while the work lasts is likely to be a reasonable step (EHRC Code of Practice for services (2026), paragraph 7.33).
Physical features: remove, alter, avoid, or serve another way
For the second requirement, avoiding the disadvantage includes removing the physical feature, altering it, or providing a reasonable means of avoiding it (Equality Act 2010, section 20, subsection 9). For services, Schedule 2 adds a fourth option: adopting a reasonable alternative method of providing the service (Equality Act 2010, Schedule 2, paragraph 2(3)). The Code gives an example of each:
| Option | Example in the Code | Source |
|---|---|---|
| Remove it | display units at the entrance of a small shop stop wheelchair users getting in; the owner moves them elsewhere in the shop without significant loss of selling space: likely to be a reasonable step | Equality Act 2010, section 20, subsection 9(a); EHRC Code of Practice for services (2026), paragraph 7.79 |
| Alter it | a private members’ club lowers a section of its high bar so that wheelchair users can be served more easily: likely to be a reasonable step | Equality Act 2010, section 20, subsection 9(b); EHRC Code of Practice for services (2026), paragraph 7.81 |
| Provide a reasonable means of avoiding it | a probation service’s meeting room has two steps into it; the service installs a permanent ramp beside the steps: likely to be a reasonable step. In another example, a club that cannot practicably lower its bar offers table service to wheelchair users instead | Equality Act 2010, section 20, subsection 9(c); EHRC Code of Practice for services (2026), paragraphs 7.83 and 7.84 |
| A reasonable alternative method of providing the service | the changing facilities in a gym are only reachable by stairs; suggesting that disabled members change in a corner of the gym is unlikely to be reasonable, because it may significantly infringe their dignity | Equality Act 2010, Schedule 2, paragraph 2(3); EHRC Code of Practice for services (2026), paragraphs 7.87 and 7.88 |
The word reasonable carries weight in the last two options. The Code counts whether the arrangement significantly offends the dignity of disabled people and how much inconvenience or anxiety it causes (EHRC Code of Practice for services (2026), paragraph 7.85). A bell at the foot of a flight of stairs with a sign saying ‘Please ring for disabled access’ is unlikely to be a reasonable means of avoiding the stairs if nobody answers it promptly, even in bad weather (EHRC Code of Practice for services (2026), paragraph 7.86). The aim is an experience as close as reasonably possible to the standard offered to non-disabled people (EHRC Code of Practice for services (2026), paragraph 7.89), and when a business chooses an alternative method, a court can look at the other options it could have taken (EHRC Code of Practice for services (2026), paragraph 7.90).
Outdoor features count too, such as the paths and seating in a pub garden (EHRC Code of Practice for services (2026), paragraph 7.73), and so do features a business brings onto premises it does not usually occupy, like the terraced seating an outdoor theatre group brings to the venues where it performs (Equality Act 2010, Schedule 2, paragraph 2(6); EHRC Code of Practice for services (2026), paragraphs 7.74 and 7.75). For services that transport people by land, air or water, Schedule 2 has its own rules: it is never reasonable to have to alter or remove a physical feature of a vehicle, or to change whether vehicles are provided, which ones, or what happens on board (Equality Act 2010, Schedule 2, paragraph 3(1) and (2)). For the first and third requirements, though, taxis, private hire vehicles, public service vehicles, trains and trams, among others, cannot rely on the last three of those limits (Equality Act 2010, Schedule 2, paragraph 3(3)). And a business that provides its service with a hire vehicle built to carry no more than 8 passengers cannot rely on any of them, for any of the three requirements; for the second, hand controls and wheelchair stowage count as physical features of that vehicle (Equality Act 2010, Schedule 2, paragraph 3(5) and (6)).
What makes an adjustment reasonable
The Act does not list factors. What is reasonable depends on all the circumstances, and varies with the type of service, the nature, size and resources of the service provider, and the effect of the disability on the individual (EHRC Code of Practice for services (2026), paragraph 7.36). The Code names some factors, without meaning to be exhaustive (EHRC Code of Practice for services (2026), paragraph 7.37):
- whether the step would be effective in overcoming the disadvantage;
- how practicable it is for the service provider;
- the financial and other costs of the adjustment, and the disruption it would cause;
- the financial and other resources of the service provider, and what it has already spent on adjustments;
- the availability of financial or other help.
A business with substantial resources is more likely to have to make an adjustment with a significant cost than one with fewer (EHRC Code of Practice for services (2026), paragraph 7.39). Where a reasonable adjustment would remove or reduce the disadvantage, a different step that would be less effective is not enough (EHRC Code of Practice for services (2026), paragraph 7.46), and an auxiliary aid that does not help in practice does not count (EHRC Code of Practice for services (2026), paragraph 7.47): in the Code’s example, a conference provides sign language interpreters, but deaf delegates are not given the option to sit near them and in full view (EHRC Code of Practice for services (2026), paragraphs 7.45 and 7.49).
There are limits. A service provider is not required to take a step that would fundamentally alter the nature of the service or of its trade or profession (Equality Act 2010, Schedule 2, paragraph 2(7)). And if, after thinking it through, there is genuinely no reasonable step, a business that changes nothing is unlikely to be in breach; the Code adds that this is likely to be rare (EHRC Code of Practice for services (2026), paragraph 7.52).
A walk through the building: practical examples
The Code lists physical features that the duty covers: steps, stairways, kerbs, exterior surfaces and paving, parking areas, entrances and exits, emergency escape routes included, internal and external doors, gates, toilet and washing facilities, counters and service desks, lighting and ventilation, lifts and escalators, floor coverings, signs, furniture, temporary or movable items such as display racks, and the scale of the premises, such as the size of a shopping centre (EHRC Code of Practice for services (2026), paragraph 7.71). Section 20 and Schedule 2 set no measurements: they ask what is reasonable. This is one way to walk through a shop, a café or an office, in the order a customer meets it:
| Where | What can get in the way | Requirement | Steps the sources mention |
|---|---|---|---|
| Approach and parking | kerbs, paving, parking areas | physical feature (Equality Act 2010, section 20, subsection 10(b)) | these are physical features the duty covers (EHRC Code of Practice for services (2026), paragraph 7.71) |
| Entrance | one or two steps at the door | physical feature (Equality Act 2010, section 20, subsection 10(a) and (b)) | a permanent ramp beside the steps (EHRC Code of Practice for services (2026), paragraph 7.83); a bell nobody answers is unlikely to be enough (EHRC Code of Practice for services (2026), paragraph 7.86) |
| Inside the shop | display units, racks, furniture | physical feature (Equality Act 2010, section 20, subsection 10(c)) | move the display units (EHRC Code of Practice for services (2026), paragraph 7.79) |
| Counter or bar | a counter too high to be served at | physical feature | lower a section of the bar, or offer table service (EHRC Code of Practice for services (2026), paragraphs 7.81 and 7.84) |
| Queue | having to stand for a long time | provision, criterion or practice (Equality Act 2010, section 20, subsection 3) | a seat, and service as if the customer had queued (EHRC Code of Practice for services (2026), paragraph 7.38) |
| Door policy | a ‘no dogs’ rule | provision, criterion or practice | the duty is owed to guide dog users (EHRC Code of Practice for services (2026), paragraph 7.28) |
| Menus, leaflets, signs | small print, information only in one format | provision, criterion or practice or auxiliary aid, about information (Equality Act 2010, section 20, subsection 6) | larger print, clear language, braille or easy-read versions (EHRC Code of Practice for services (2026), paragraphs 7.59 and 7.60) |
| Hearing | speech that cannot be heard over background noise | auxiliary aid (Equality Act 2010, section 20, subsection 5) | an induction loop or infrared broadcast system, kept in working order (EHRC Code of Practice for services (2026), paragraphs 7.62 and 7.63) |
| Toilets and changing rooms | up a flight of stairs, or too small | physical feature | toilet and washing facilities are physical features (EHRC Code of Practice for services (2026), paragraph 7.71); changing in a corner of the gym is unlikely to be reasonable (EHRC Code of Practice for services (2026), paragraph 7.88) |
Two notes on aids. A business should keep its auxiliary aids properly maintained and have a plan for when one fails, because an aid that is not working may count as a failure to make the adjustment (EHRC Code of Practice for services (2026), paragraph 7.62). And the Act leaves it to the business to work out which aids fit its service (EHRC Code of Practice for services (2026), paragraph 7.69). What an induction loop, an infrared system or an FM system is, and how the United States counts the receivers, is in ADA assistive listening systems.
What happens if a business does not make the adjustment
A failure to comply with the first, second or third requirement is a failure to comply with the duty, and a service provider that fails to comply with it in relation to a disabled person discriminates against that person (Equality Act 2010, section 21, subsections 1 and 2). That is the route the Act gives: the duty in Schedule 2 is used to establish whether there was discrimination, and a failure to comply is not actionable in any other way (Equality Act 2010, section 21, subsection 3).
In the Code’s words, a service provider that does not comply commits an act of unlawful discrimination, and the disabled person can bring a claim (EHRC Code of Practice for services (2026), paragraph 7.55). Section 29 also forbids a service provider to discriminate by not providing the service, in the terms on which it is provided, by ending it or by any other detriment (Equality Act 2010, section 29, subsections 1 and 2). How these duties compare with the laws of the US, Canada, Australia and the EU is in accessibility laws by country.
Reasonable adjustments you can see on Braillito Maps
An adjustment helps only the people who know it is there. Braillito Maps is a community map that answers ten questions about each place: step-free entrance or ramp, wide doorway, accessible toilet, accessible parking, tactile paving, braille signage, braille menu, audible signals, guide dogs welcome and a quiet environment.
Several of them match the requirements in this guide. The step-free entrance, the wide doorway, the accessible toilet and the parking are physical features; the braille menu and the braille signage are information in an accessible format; and guide dogs welcome is a door policy. Each question is answered yes or no, or stays without data until someone knows, and the score of a place is the number of yes answers out of ten, always shown with its number, never by colour alone.
If you run a shop or a café that has made one of these changes, add your place with its answers, so that disabled customers find it before they set off. If what a place says is wrong, it can be reported. Meet Braillito Maps.
Frequently asked questions
What are reasonable adjustments under the Equality Act 2010?
Steps a service provider has to take, as far as is reasonable, when a practice, a physical feature or the lack of an auxiliary aid puts disabled people at a substantial disadvantage compared with people who are not disabled (Equality Act 2010, section 20, subsections 2 to 5; Equality Act 2010, section 29, subsection 7).
What are the three requirements of section 20?
Changing a provision, criterion or practice; dealing with a physical feature, by removing it, altering it or providing a reasonable means of avoiding it; and providing an auxiliary aid or service (Equality Act 2010, section 20, subsections 3 to 5, 9 and 11).
Can a shop charge a disabled customer for a reasonable adjustment?
No. A person with the duty is not entitled to require the disabled person to pay, to any extent, its costs of complying with it, unless the Act expressly provides otherwise (Equality Act 2010, section 20, subsection 7).
Is the duty to make reasonable adjustments anticipatory?
For services, yes. Schedule 2 makes the duty one owed to disabled persons generally (Equality Act 2010, Schedule 2, paragraph 2(2)), and the EHRC Code says a service provider should consider barriers before a disabled person tries to use the service, not wait until one turns up (EHRC Code of Practice for services (2026), paragraphs 7.22 and 7.23).
What counts as a physical feature?
A feature from the design or construction of a building, of an approach to, exit from or access to it, any fixture, fitting, furniture, equipment or materials in or on the premises, and any other physical element or quality (Equality Act 2010, section 20, subsection 10).
Does a business have to make every adjustment a customer asks for?
It has to take the steps it is reasonable to have to take (Equality Act 2010, section 20, subsections 3 to 5), and it never has to fundamentally alter the nature of its service, trade or profession (Equality Act 2010, Schedule 2, paragraph 2(7)).
More accessibility guides
- Accessibility laws by country: the ADA, the UK Equality Act, the Accessible Canada Act, Australia’s DDA and the EU rules, and what each covers.
- ADA assistive listening systems: hearing loops, FM and infrared: where the ADA requires them, how many receivers, hearing-aid compatibility, signs and sound levels.
- ADA compliance: a checklist for small businesses, with the 2010 Standards section behind each item.
- Accessible restaurants: what to check before you go: the entrance, the tables, the restroom, the menu and service animals.
- Guide dogs: how they work, where they can go under the ADA, and how to act around one.
- Universal design: the seven principles, with an example from a building for each.
- Accessibility symbols: what the wheelchair symbol means, where it is required and the other access symbols.
- All accessibility guides
Sources
Every figure in this guide comes from one of these official texts, which we read in October 2026.
- Equality Act 2010, section 20: duty to make adjustments. UK Parliament, on legislation.gov.uk, text in force, read October 2026.
- Equality Act 2010, section 29: provision of services. UK Parliament, on legislation.gov.uk, text in force, read October 2026.
- Equality Act 2010, Schedule 2: services and public functions, reasonable adjustments. UK Parliament, on legislation.gov.uk, text in force, read October 2026.
- Equality Act 2010: Code of Practice for services, public functions and associations, 2026. Equality and Human Rights Commission, on GOV.UK, in force since 5 August 2026; ISBN 978-1-5286-6395-3; read October 2026.
- Americans with Disabilities Act Title III Regulations (28 CFR part 36). U.S. Department of Justice (ADA.gov), current text with its appendices, read October 2026.
- Equality Act 2010, section 21: failure to comply with duty. UK Parliament, on legislation.gov.uk, text in force, read October 2026.
Braillito Maps
Find places with ramps, accessible toilets or tactile paving near you in Braillito Maps
In Braillito Maps, every place answers ten questions: step-free entrance or ramp, wide doorway, accessible restroom, accessible parking, tactile paving, braille signage, braille menu, audible signals, guide dogs welcome and a quiet environment. It is built by the people who need it, and every place gets a score out of ten.
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