Equality Act 2010 and BS 8300, UK wide
Access Audits
If you provide a service to the public, the law expects you to have thought about disabled people before any of them arrive. AL23 Safety audits buildings and the services delivered from them against the Equality Act 2010 and BS 8300, then hands you a prioritised plan, for clients UK wide.
What is an access audit?
A journey from the pavement to the exit, judged against the duty rather than the drawings
An access audit examines how a disabled person would approach, enter, move through, use and leave your premises, together with how your management arrangements help or hinder them. It covers the physical fabric, the equipment, the information and the policies together because the Equality Act treats them together.
The output is not a list of faults. It is a plan that separates what you must do to avoid placing someone at a substantial disadvantage, what building regulations will require if and when you next carry out work and what would simply be better practice.
Who needs one
Service providers, employers, public bodies and anyone about to spend money on a building
- Service providers open to the public, whose duty is anticipatory and owed before anyone complains.
- Public authorities and organisations exercising public functions, who must evidence the public sector equality duty at the time a decision is taken.
- Employers responding to an individual request for adjustment where the building itself is the barrier.
- Landlords, managing agents and facilities teams preparing planned maintenance or refurbishment programmes.
- Design teams wanting an independent review before a scheme is fixed and changes are still cheap.
- Organisations that have received a complaint, a solicitor's letter or a county court claim about access.
- Education providers, associations and membership bodies, which owe anticipatory duties under their own schedules.
The regulations that apply
Your legal framework, in plain terms
The Equality Act 2010 is the source of the duty. Section 20 sets out three requirements to make reasonable adjustments, covering a provision, criterion or practice, a physical feature and the provision of an auxiliary aid. Section 21 makes a failure to comply with any of those requirements discrimination against the disabled person concerned. For service providers, section 29 and Schedule 2 apply the duty. Schedule 2 paragraph 2(2) is the provision that makes it anticipatory. Separately, the Building Regulations 2010, SI 2010/2214, Schedule 1 Part M sets construction requirements on access to and use of buildings. Part M is law. The Approved Documents that explain it are guidance. BS 8300-1:2018 and BS 8300-2:2018 are voluntary standards, published on 31 January 2018, which go considerably further than the Approved Document and form the practical benchmark for an audit.
Section 20(9) and 20(10)
Avoiding the disadvantage can mean removing the physical feature, altering it or providing a reasonable means of avoiding it. A physical feature includes design and construction, approaches, exits, fixtures, fittings, furniture and equipment.
Section 20(7)
You cannot require the disabled person to pay any part of the cost of the adjustment.
Section 212(1)
"Substantial" means more than minor or trivial. That is a low bar and it surprises most duty holders.
Section 149, the public sector equality duty
Due regard to eliminating discrimination, advancing equality of opportunity and fostering good relations, evidenced when the decision is made rather than justified afterwards.
Sections 114 and 118
A claim goes to the county court, normally within six months less one day of the act complained of. Remedies include damages for injury to feelings, with no cap.
What anticipatory actually means
The service provider duty is owed to disabled persons generally, not to a named individual. You must think ahead about the barriers people may face and remove them in advance. The duty is continuing and evolving rather than discharged once. Not knowing that a disabled person will use your service is not a defence.
The employment duty is different. It is reactive and depends on actual or constructive knowledge of the individual's disability and disadvantage. Organisations regularly apply the employment test to their public-facing premises and get it wrong. The EHRC statutory code of practice on services, public functions and associations, issued in 2011 under section 14 of the Equality Act 2006, is admissible in evidence and a court must take into account any relevant part.
Compliant and still inaccessible
The point of the audit, stated plainly
A building can be fully compliant with Part M and signed off by building control while still placing a disabled person at a substantial disadvantage. There are four reasons.
- 01
Part M is a construction stage minimum, applied once
Building regulations bite on new build, material alterations, material changes of use and certain extensions. They do not apply retrospectively. An office block unaltered since the 1970s carries no Part M obligation at all.
- 02
The Equality Act duty is continuous and attaches to the service
It keeps running long after practical completion and reaches things Part M never mentions.
- 03
Schedule 21 gives only a narrow defence
Where a physical feature was provided in accordance with the relevant Approved Document requirements, a service provider is generally not required to alter that specific feature for a limited period afterwards. We check the current wording and the period before relying on it. It protects nothing about management, policy or auxiliary aids.
- 04
Part M is silent on much of what matters
Furniture layout, temporary obstructions, queueing and booking systems, staff behaviour, wayfinding strategy, acoustics and sensory environment, digital accessibility, assistance dogs, communication support and the ongoing maintenance of accessible features. An accessible WC used as a store cupboard is a live breach whichever Approved Document the building was built to.
Approved Document M Volume 1 covers dwellings and stands as the 2015 edition incorporating 2016 amendments, effective 1 March 2016. Volume 2 covers buildings other than dwellings and stands as the 2015 edition incorporating 2020 and 2024 amendments, last updated on 1 October 2024. The July 2020 amendment introduced Changing Places toilets in appropriately sized publicly accessible buildings. Requirements M4(2) and M4(3) for dwellings are optional and apply only where imposed as a planning condition.
What we assess
The whole journey, fabric and management together
- Approach and arrival. Accessible parking provision, dimensions, marking, surface and distance to the accessible entrance, setting down points, dropped kerbs and enforcement.
- External routes. Widths, gradients, cross-falls, surface firmness and slip resistance, drainage, tactile paving, external lighting and glare.
- Entrance. Whether the accessible route is the principal route, effective clear widths, door opening forces measured on site, power operation, thresholds, manifestation on glazing and lobby depth.
- Door entry systems, intercoms and keypads, including reach, tactile marking and audible feedback.
- Reception and waiting. Counter heights for seated and wheelchair users, hearing enhancement that is signed, tested and switched on, lighting for lip reading, seating variety and acoustics.
- Horizontal circulation. Corridor widths, passing places, projecting objects, floor finishes and changes of level.
- Visual contrast between critical surfaces such as doors against walls and handrails against their background, measured as light reflectance value difference against the current BS 8300-2 benchmark.
- Vertical circulation. Stair geometry, handrails, nosing contrast, hazard warning surfaces, lift car dimensions, controls, announcements and dwell times, plus any platform lift that needs staff assistance.
- Sanitary provision. Wheelchair-accessible WC layout, transfer space, handedness across the building, grab rails, reach ranges, ambulant cubicles, accessible showers and Changing Places facilities where required.
- Emergency alarm cords in accessible WCs, including whether the cord reaches the floor, whether the indicator outside works and whether anyone knows who responds.
- Communication and information. Signage typeface, size, contrast and mounting, tactile and Braille provision, wayfinding strategy, hearing enhancement in meeting spaces and visual fire alarms.
- Means of escape. Refuge provision and communication, evacuation lifts, evacuation chairs with trained users on every shift, plus the fire evacuation plans that set out how the building empties.
- Management and policy. Assistance dog policy, reasonable adjustments log, staff training, complaints route and any published access statement.
Our process
Walk the journey, then test it against the duty
- 01
Brief
We agree the scope, the buildings, the services delivered from them and who uses them, including staff, visitors and contractors.
- 02
Survey
We walk the full journey in sequence, measure against the current standards and photograph the findings.
- 03
Interview
We talk to reception, facilities and front line staff because most access failures are operational and never appear on a drawing.
- 04
Analyse
We test each finding against the Equality Act duty first, then against Part M and BS 8300 so you can see which pressure each item is under.
- 05
Report and plan
We deliver a prioritised action plan with cost bands, owners, target dates and a review date, then help you work through it.
What you get
A prioritised plan you can put to work
- An access audit report structured by the user journey, with annotated photographs and located findings.
- A prioritised action plan separating Equality Act exposure, building regulations triggers and best practice under BS 8300 and PAS 6463:2022.
- Cost bands and suggested owners for each action so the plan can go straight into a maintenance or capital programme.
- A board or committee summary, which for public bodies also evidences due regard under section 149.
- A draft access statement for publication to service users, where you want one.
- A written note of the dimensional benchmarks applied and the edition of each standard used so the audit remains auditable.
What we need from you
Plans, history and access while the building is busy
- Floor plans and site plans, at whatever level of accuracy exists.
- Any previous access audit, along with what was and was not actioned.
- Your fire strategy, evacuation plan and any existing personal emergency evacuation plans.
- Details of complaints, requests for adjustment and the outcome of each.
- Access to the building while it is in use, including a busy period.
Why AL23 Safety
The unlawful named, not buried in recommendations
Accountable
Where a feature is unlawful rather than merely imperfect, we say which duty it fails and why. We do not bury the exposure in a list of recommendations.
Measured, not remembered
Dimensional benchmarks move between editions. We work to the current Approved Document M and BS 8300-2:2018 text on the day of the audit rather than quote an old handbook.
Managed specialists where they add value
We scope the work, appoint the right specialist, interpret the results and turn them into an action plan you can actually deliver. There is no statutory requirement to use a consultant on the National Register of Access Consultants. Access consultant is not a protected title either. We tell you plainly what competence is being brought to your job.
UK wide
We audit offices, retail, leisure, education, healthcare and public buildings across the UK and join the findings up with our fire strategy work where evacuation is part of the picture.
Wondering whether your building would stand up to a claim
Access failures rarely arrive as a surprise. They arrive as a letter
Describe the building and the service you run from it. We will tell you what an audit would cover and what usually turns up first.
Common questions
Answers, up front
Cannot see your question? Get in touch and we will answer it directly.
Contact usNo. Nothing in the Equality Act 2010 requires an audit as such. What the Act requires is that you make reasonable adjustments in advance for disabled people generally. Public bodies must also show due regard to equality at the time decisions were made. An audit is the normal way of evidencing both. Without one, you rely on your own assertion that you thought about it.
Building control confirms that the work met the Building Regulations requirements at the time it was done. That is a construction standard, applied once, to the work carried out. The Equality Act duty is continuous, applies to the service and covers management and policy that Part M never touches. The two tests are different and passing one does not answer the other.
The Register, established in 1999, lists Access Auditors and Access Consultants accredited by peer review against published standards. It is voluntary and there is no statutory requirement to use a registered auditor. Where a project needs that credential or a client's specification demands it, we scope the work, appoint an appropriately registered specialist and stay accountable for the interpretation and the action plan.
That sits outside Part M entirely, under the Regulatory Reform (Fire Safety) Order 2005. An audit that finds a compliant accessible entrance and a refuge with a dead intercom has found a serious problem. We assess refuges, communication, evacuation lifts and trained assistance as part of the audit and produce the plans themselves through our personal emergency evacuation plans service.
A claim goes to the county court under section 114 of the Equality Act 2010, normally within six months less one day of the act complained of, extendable where the court thinks it just and equitable. Remedies include a declaration, an injunction and damages including for injury to feelings. There is no statutory cap. The reputational cost is usually larger than the award.
Cost is driven by floor area, the number of storeys and entrances, the complexity of the service and whether external areas are in scope. A single-storey community building is a half day survey. A multi-building campus is a programme. Reports normally follow within two weeks of the survey. Send us the plans and we will price the actual building rather than a category.
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