The duty to make reasonable adjustments is the cornerstone of UK disability employment law. This guide explains what the duty requires, what is "reasonable", how to conduct an interactive process, and how to handle disagreements — drawing on EHRC, ACAS, and case law.
Reasonable Adjustments: Complete UK Employer Guidance
The Legal Duty
The duty to make reasonable adjustments arises under the Equality Act 2010. It is the primary mechanism through which the Act ensures disabled people can access employment on equal terms.
The duty has three separate requirements (limbs):
Provision, criterion, or practice (PCP): Adjust or remove a working rule or practice that puts a disabled person at a substantial disadvantage compared to non-disabled people.
Physical feature: Remove, alter, or provide a reasonable means of avoiding a physical feature of the workplace that puts a disabled person at a substantial disadvantage.
Auxiliary aids: Provide an auxiliary aid or service (e.g., software, equipment, or a support worker) where its absence puts a disabled person at a substantial disadvantage.
When the Duty Arises
The duty arises when the employer knows, or could reasonably be expected to know, that:
The employee has a disability, AND
The employee is likely to be placed at a substantial disadvantage without adjustments
The employer does not need to be told formally. If a manager can reasonably infer a disability from visible symptoms, prolonged sickness absence, or the employee's own statements, the duty may already apply.
What Is "Reasonable"?
Reasonableness is assessed on a case-by-case basis. The EHRC Statutory Code of Practice identifies relevant factors:
Effectiveness: How likely is the adjustment to remove the disadvantage?
Practicability: Is it practical to make?
Cost: What is the financial and other cost, taking into account available resources (including Access to Work grants)?
Disruption: How disruptive will it be?
Employer's resources: The size and resources of the organisation are relevant — larger employers are expected to do more
Availability of financial/other assistance: Access to Work grants reduce the financial burden
Important: The duty is to make adjustments that are reasonable — not every possible adjustment, and not any adjustment the employee requests. The employer must weigh costs and benefits.
The Interactive Process
The EHRC recommends an interactive process — a genuine, open conversation between employer and employee to identify the most effective adjustments.
Step 1: Recognise the Trigger
Has the employee disclosed a disability? Has sickness absence or performance raised a question? Has OH referred the employee?
Step 2: Invite a Conversation
Do not wait for the employee to formally request an adjustment. Proactively invite them to discuss their needs:
> "I want to make sure you have everything you need to do your job well. Can we set some time aside to discuss how we can support you?"
Step 3: Gather Information
Ask the employee what adjustments they think would help
Consider occupational health advice (OH referral is appropriate for complex cases — note that OH advises the employer, it does not make decisions for the employer)
Consult Access to Work if specialist equipment or support may be needed
Step 4: Agree Adjustments
Document the agreed adjustments in writing (the Workplace Adjustments Passport is an ideal vehicle). Be specific about:
What the adjustment is
How long it will be in place
Review date
Step 5: Review
Schedule a review. Adjustments should be reviewed (not removed) at agreed intervals. A review is an opportunity to assess what is working and make changes.
Common Adjustments by Category
Working Arrangements
Flexible start/finish times
Part-time or compressed hours
Remote/hybrid working
Phased return to work after absence
Moving the employee to a different role (as a last resort)
Physical Environment
Accessible parking space
Ergonomic chair or desk
Quiet workspace
Reduced lighting at workstation
Equipment and Technology
Screen reader software (JAWS, NVDA)
Speech-to-text software (Dragon)
Adjustable monitor stand
Specialist keyboard or mouse
Large-print materials
Task and Process Adjustments
Written instructions for complex tasks
Extra time for written work
Reduced pace or adjusted targets during recovery periods
Buddy system or job coaching
Communication Adjustments
BSL interpreter for meetings
Written meeting agendas in advance
Written rather than verbal feedback
When the Employer Can Decline
An employer can decline to make an adjustment if it is not reasonable. Factors that may make an adjustment unreasonable:
Prohibitive cost relative to employer size (though Access to Work may remove this argument)
Adjustment would fundamentally alter the nature of the role
Adjustment is impractical given the physical environment
However: The employer bears the burden of showing an adjustment is unreasonable. In Employment Tribunal cases, tribunals frequently find that employers have not adequately explored alternatives before declining.
Disagreements
If an employee and employer disagree about whether an adjustment is reasonable:
Escalate internally — HR or a more senior manager should review the decision
Occupational health review — an independent OH assessment can provide a neutral view
ACAS early conciliation — free, confidential, and often resolves disputes before they reach tribunal
Employment Tribunal — claims must be filed within 3 months (minus 1 day) of the failure to adjust
Key Cases
Case
Principle
*Archibald v Fife Council* [2004]
Duty to consider redeployment to a different role if the employee can no longer do their original job
*Environment Agency v Rowan* [2008]
Tribunal must identify the PCP, the disadvantage, and the step that would remove it
*G4S Cash Solutions v Powell* [2016]
Adjusting pay protection during a phased return is a reasonable adjustment
*Leeds Teaching Hospital NHS Trust v Foster* [2022]
Adjustments must be effective, not merely token
Sources: Equality Act 2010, EHRC Employment Statutory Code of Practice 2011, ACAS Disability at Work Guidance 2023, Business Disability Forum Reasonable Adjustments Research 2023