Reasonable Adjustments at Work: A Guide for UK Employers (+ Free Adjustment Plan Template)

I recently read an employment law case a colleague shared on LinkedIn, and it got me thinking, because unfortunately I advise on this topic a lot. An employee with a health condition quietly agrees some adjustments with their manager. Nothing written down, because you’re a startup and everything lives in Slack and goodwill. Eighteen months later that manager leaves, the team reorganises, and the new manager, knowing none of the history, asks why this person gets to start at 10am and skip the stand-up. The adjustments evaporate. The employee, who now has to re-explain their disability from scratch to a stranger, goes off sick. Then a solicitor’s letter arrives.

There’s a quieter version too, and I see it just as often. A manager notices someone struggling and suspects a health condition might be behind it, and freezes. They don’t know what they’re allowed to ask, whether saying the wrong thing makes it worse, or whose job this even is when HR is a shared inbox. So nothing gets said, and the performance conversation happens instead of the health one.

I’ve never once had a founder tell me they deliberately ignored someone’s disability. What I have seen dozens of times is a manager leave, a Slack thread disappear, or an adjustment quietly drift because nobody owned it anymore. That’s the real risk. Good companies don’t usually get this wrong through bad intentions. They get it wrong because they grow.

A reasonable adjustment plan is the document that stops both stories happening. You’ll also hear these called reasonable adjustments passports (the Department for Work and Pensions’ version is still the health adjustment passport), adjustment planners or tailored adjustments plans. I’ve moved to “plan”, and I’d suggest you do too: a passport sounds like something stamped once and carried around unchanged, when the whole point is a living document you review together as things change. It’s a short record of the conversation between an employee and their manager, usually held by HR: how their condition affects them at work, which adjustments have been requested, which were agreed (and any that weren’t, with the reasons why), what the company has done to implement them and by when, and what happens when they’re having a bad patch. That makes it both a support tool and a formal record: if anyone ever asks what you knew and what you did about it, the answer is written down with dates. It moves with the employee when they change role, team or manager, so nobody has to disclose their medical history all over again every time your org chart shifts. Which, in a scale-up, is roughly quarterly.

Reasonable adjustments under the Equality Act 2010: the duty you already have

Under section 20 of the Equality Act 2010, if a disabled employee or job applicant is put at a substantial disadvantage by the way you work, your premises, or the lack of some aid or equipment, you must take reasonable steps to remove that disadvantage. “Substantial” just means more than minor or trivial. That’s a low bar, and it’s meant to be.

The duty applies to every employer, from two founders in a WeWork to a 400-person unicorn. Size affects what’s reasonable, not whether the duty exists. It covers job applicants as well as staff, and you can’t ask the employee to chip in for the cost. Acas’s guidance on reasonable adjustments at work is worth a read if the duty is new to you.

Two things trip up smaller companies in particular.

First, you don’t need a formal diagnosis letter to be on the hook. The legal question isn’t whether someone has a diagnosis. It’s whether they meet the Equality Act definition of disability. If you knew, or reasonably should have known, that someone has a disability and is struggling because of it, the duty to make reasonable adjustments may arise. Tribunals call this constructive knowledge. In A Ltd v Z (EAT/0273/18), the employer lost precisely because it never asked the obvious questions about an employee’s mental health; had it asked, it would have known. “She never told us” is not the defence founders think it is.

Second, an adjustment doesn’t have to be expensive or exotic to be legally required. Employees have won claims over a dedicated parking space (Linsley v HMRC, where hunting for parking aggravated the claimant’s ulcerative colitis), a key to the customer lift (Mitchell v Marks and Spencer), and being allowed to listen to music at work to manage anxiety (Hanif v DWP). The pattern across these cases isn’t villainous employers. It’s busy ones, where a small ask sat in someone’s inbox until it became a claim.

Common mistakes employers make with reasonable adjustments

Recruitment is a common one. In AECOM Ltd v Mallon, a job applicant with dyspraxia couldn’t manage the online application form. He asked to apply by phone; the employer kept emailing him instructions instead. The tribunal found the employer should have picked up the phone. If your hiring process is a wall of automated forms and asynchronous take-home tasks, and someone’s condition makes that format the problem, you’re expected to flex it. The same logic sank the Government Legal Service in Brookes, over a multiple-choice psychometric test that disadvantaged a candidate with Asperger’s.

Internal processes are the other trap. Adjustments can apply to your disciplinary, performance and absence procedures too, not just desks and software. Tribunals have found employers should have extended an appeal deadline for a disabled employee (Knightley, an Employment Appeal Tribunal decision), paused a disciplinary hearing for an employee with depression and anxiety, and, in one employment tribunal decision (Lynskey v Direct Line), abandoned a disciplinary process altogether, treating the employee’s menopausal symptoms as mitigation. If your absence policy auto-triggers a warning at three absences and two of them were disability-related, you have a problem a policy tweak would have avoided.

And then there’s the manager-churn problem I opened with. The duty attaches to your “provisions, criteria and practices”, which courts read widely: informal habits, unwritten expectations (in one case, simply expecting people to work late), even a one-off decision if it’s how you’d handle the next case too. When adjustments live only in a departed manager’s head, every reorganisation is a fresh chance to unlawfully withdraw them without anyone deciding to.

Examples of reasonable adjustments at work

The Equality Act doesn’t set out a list; the statutory code of practice gives examples, and what’s reasonable always depends on the person, the role and your resources. In practice, the adjustments I most often see agreed are:

• flexible start and finish times
• hybrid or remote working
• specialist equipment
• ergonomic chairs
• speech-to-text software
• quiet workspaces
• adjusted absence triggers
• modified duties
• a phased return after sickness
• extra breaks
• a parking space closer to the office
• a different interview format

Most of these cost little or nothing, and Access to Work can fund many of the ones that don’t.

Why record them in an adjustment plan

A well-run adjustment plan scheme deals with almost all of this at once. It creates a record of what was agreed and when, which is exactly the evidence a tribunal asks for. It fixes the knowledge problem, because once it’s written down you can never claim you didn’t know. It survives manager changes, so adjustments carry over by default instead of lapsing by accident. And it builds in review points (return to work, role changes, new tooling) so the conversation happens before things break rather than after.

It also does something the law can’t: it makes the conversation easier, on both sides. Most employees hate raising this stuff, and most managers are terrified of getting it wrong. A standard, normalised document that anyone can request, with no diagnosis required to start the conversation, takes the awkwardness out of asking and gives managers a script to follow instead of a minefield to cross. Adjustments funded through Access to Work can be recorded in the same place, so the paper trail stays in one document.

Reasonable adjustment plan FAQs

Introduce it to your managers, make a managers’ resources folder on your HRIS or SharePoint, and/or make it available to anyone who believes they may benefit from workplace adjustments rather than waiting for disclosures, and train managers to treat an adjustment plan as a document they inherit, not renegotiate. If you’re still building the basics, my HR foundations checklist for founders covers what else should be in place.

And if you’d rather someone senior just handled this, it’s exactly the sort of foundation I put in place as a fractional HR director. One conversation is usually enough to work out whether you need one. You know where I am.

This post is general guidance, not legal advice. Cases turn on their facts; if you’re facing a live dispute, get proper advice early.