Public bodies must comply with the Equality Act when providing services and exercising public functions. This can affect access to complaint systems, communication methods, appointments, assessments, decision-making and the way policies are applied. The reasonable-adjustment duty for disabled people is anticipatory in service provision and should not depend on a person using legal terminology.
Key points
- Public services and public functions are generally covered by section 29 of the Equality Act 2010.
- A disabled person may be entitled to reasonable adjustments to policies, physical features and auxiliary aids or services.
- The public sector equality duty is a decision-making duty. It does not automatically dictate one outcome.
- State the disadvantage, requested adjustment and practical reason for it.
Legal framework
Different Equality Act duties do different jobs
| Issue | Relevant concept | Practical question |
|---|---|---|
| Different treatment because of a protected characteristic | Direct discrimination | Was the treatment because of the characteristic? |
| A general rule causes group disadvantage | Indirect discrimination | Is the rule justified as a proportionate means of achieving a legitimate aim? |
| Unfavourable treatment connected to disability | Discrimination arising from disability | Was the treatment justified and did the body know, or should it have known, about disability? |
| A disabled person cannot access the process equally | Reasonable adjustments | What reasonable step would avoid the substantial disadvantage? |
| A public authority makes or applies policy | Public sector equality duty | Was due regard given to the statutory equality needs? |
Reasonable adjustments
Describe the barrier and the workable solution
A useful request explains the disability-related barrier, the part of the process affected and the adjustment sought. Examples may include telephone contact instead of an online-only form, accessible documents, extra time where reasonable, a named contact, communication through a representative, rest breaks, or changes to appointment arrangements. The body should consider the request on its facts and may propose an effective alternative.
Evidence
Keep the adjustment history
- the date the body was told about disability or access needs
- the exact barrier experienced
- the adjustment requested and why it would help
- medical or supporting information where reasonably required
- the body’s decision and reasons
- any alternative offered and whether it was effective
- the effect of delay or refusal
Challenge
Keep the service complaint and equality issue connected but distinct
Use the organisation’s complaint procedure to identify the service failure and the alleged equality failure. Ask who considered the adjustment, what information was used, whether an alternative was assessed and how equality duties informed the decision. Where legal proceedings may be considered, obtain advice promptly because limitation periods are separate from complaint and ombudsman processes.
Official sources
Check the current rules behind this guide
- Equality Act 2010
Primary legislation covering discrimination, reasonable adjustments and the public sector equality duty. - EHRC Code for services and public functions
The statutory code explaining how the Equality Act applies to services and public functions. - EHRC Chapter 11: services and public functions
Detailed official guidance published in August 2026.
These are official or primary sources. Local policies, statutory guidance, legislation and deadlines can change. Check the live source and the decision notice before acting.