A reasonable adjustment changes the process so a disabled person can access the service or complaint route without a substantial disadvantage.
Under the Equality Act 2010, service providers and others can have duties to make reasonable adjustments for disabled people. In complaint handling, this might concern communication method, format, extra time, support from a representative or another practical change.
Ask for the adjustment you actually need and explain the barrier it addresses. You do not normally need to provide a complete medical history simply to request an obvious communication adjustment.
Key points
- Describe the disadvantage and requested adjustment.
- Ask for confirmation in writing.
- Keep the adjustment separate from the merits of the complaint.
- Record repeated failures to follow an agreed adjustment.
Examples
- Email rather than telephone
- Large print or accessible document format
- Extra time to respond
- Permission for a representative/support person
- Breaks or altered appointment format
- Clear written summaries after calls
Reasonableness is contextual
The duty is not an unlimited right to any preferred process. What is reasonable depends on effectiveness, practicality, resources and circumstances. A request is stronger when it clearly removes the identified barrier.
Complaint handling can create a second problem
If the original complaint is about billing but the organisation then ignores an agreed adjustment, document that separately. Do not let the adjustment failure replace the underlying billing issue, but do not lose it either.
In practice
- Use functional language: “Telephone contact causes X barrier; please use email.”
- Ask the organisation to record the adjustment on the case.
- If it says no, ask what alternative adjustment it proposes and why.
What to do
A practical next-step plan
- Identify the barrier.
- Request a specific effective adjustment.
- Confirm it in writing.
- Record compliance/failures.
- Challenge refusal with reasons.
- Use the organisation’s equality/complaint route and seek advice where needed.
Common traps
Things that often confuse the issue
- Do not assume “vulnerable customer” policies replace Equality Act duties.
- Do not disclose more health information than reasonably necessary.
- Do not let the adjustment request become an excuse for indefinite complaint delay.
Evidence worth keeping
Keep the adjustment request separate from the merits of the complaint.
Useful wording.
“Because of [functional effect], the standard process places me at a substantial disadvantage. I request [adjustment] to remove that disadvantage. If you cannot provide it, please explain what alternative reasonable adjustment you propose and the basis for refusing my requested measure. This should not delay determination of the underlying complaint.”
Ask for a reasoned decision if the adjustment is refused.
A provider does not have to accept the exact adjustment proposed if another reasonable measure adequately removes the disadvantage. But a bare “policy does not allow this” can be inadequate if the policy itself is the source of the disadvantage. Ask what alternatives were considered and how the equality duty was applied.
Describe the functional barrier and the adjustment requested.
| Barrier | Potential adjustment |
|---|---|
| Telephone-only process is inaccessible | Email/web communication or other accessible channel. |
| Short deadline creates disability-related disadvantage | Reasonable extension where the process allows it. |
| Complex repeated retelling causes substantial difficulty | Single point of contact or written case summary. |
| Standard document format is inaccessible | Accessible format or auxiliary aid. |
The stronger request explains why the standard process causes substantial disadvantage and how the proposed adjustment would address it.
The legal duty is about removing substantial disadvantage, not granting every preference.
For services and public functions in England, Scotland and Wales, the Equality Act 2010 reasonable-adjustment duty can require reasonable steps where disabled people would otherwise face substantial disadvantage. The updated statutory Code of Practice for services, public functions and associations came into force on 5 August 2026 and explains the anticipatory nature of the duty for service providers and public functions.
Northern Ireland has a different equality-law framework, so do not automatically apply Equality Act wording there.
Official sources
Check the rules behind this guide
Reasonable-adjustment duties depend on the Equality Act context and the service being provided. This page focuses on making a complaint process accessible, not on diagnosing disability or deciding a legal claim.
- Equality Act 2010 - legislation.gov.uk
- Reasonable adjustments for services and public functions - EHRC
- GOV.UK: Equality Act 2010 Code of Practice 2026 ↗
These are official or primary sources for this topic. Rules, scheme terms and deadlines can change, so check the live source before relying on a formal time limit or procedure.