Reasonable adjustments: research into delays in decisions

Question 1

1. About this report

Accepted Answer

1.1 About us

This report was drafted by the UK government’s Policy Insights Unit (PIU). The PIU is an in-house consultancy which support teams across government to develop analysis and ideas for policy. We have 4 university partners – Brunel University, Lancaster University, University of Surrey, and University of York – but we work with academics and industry experts worldwide.

If you would like to get in touch with us about this report or our work, please email us at enquiries@policyinsightsunit.gov.uk.

1.2 Scope

The PIU was commissioned by the Disability Unit (DU) within the Cabinet Office to conduct a rapid review into how effectively disabled employees can access reasonable adjustments. This research will inform DU’s ongoing management of reasonable adjustment policy.

We focused on analysing the most common barriers to accessing reasonable adjustments, examining challenges at different stages of the process. We particularly considered the prevalence and impact of delays throughout this process. We considered the perspectives of employees and employers when analysing barriers in the process.

1.3 Methods

Conducted interviews with 30 experts. We interviewed experts across academia, government, the legal profession and third sector, including representatives of disabled people’s organisations and a range of people with lived experience of disability. See Annex A for the full list.

Reviewed relevant academic, organisational and government publications. We reviewed surveys and reports from unions, charities and business groups, as well as academic papers. We also reviewed research from the University of York that was commissioned by DU (Annex F).

Analysed a sample of employment tribunal judgements. We analysed 66 employment tribunal judgments that included complaints of failure to make reasonable adjustments. More can be found in Annex B.

Conducted a survey of Advisory, Conciliation and Arbitration Service (Acas) conciliators. We received 24 survey responses. We also ran a workshop with 7 conciliators to discuss these results. More can be found in Annex D.

Question 2

2. Executive summary

Accepted Answer

Reasonable adjustments are changes an employer makes to remove any substantial disadvantage faced by an employee due to a mental and/or physical impairment.^{[footnote 1]} The Equality Act 2010 sets out an employer’s duty and employee’s right to these adjustments.^{[footnote 2]} Adjustments can include alterations to working practices, the physical workplace, the provision of auxiliary aids and many other changes.

2.1 Limited evidence base

Analysing the reasonable adjustment process is challenging, due to the limited and patchy evidence-base.

Academic research is limited and fragmented

Very few studies look at adjustments in isolation. Where they are considered, they often focus on a specific disability or workplace, making findings difficult to generalise to the wider process.

Survey evidence provides only partial and uneven coverage

Very little survey data exists on the process. Where it is available, it is skewed towards employee perspectives. Survey data largely comes from unions and charities, meaning the data does not capture employer attitudes and experiences.

There is limited evidence on employer experiences

Beyond survey data, there are very few reports that capture employer attitudes. This imbalance in the evidence base could lead to certain issues or barriers being overstated.

Available data is skewed towards disputes, rather than successful implementation, making analysis of successful cases impossible

This report uses data from Acas and the Employment Tribunal judgment portal. These datasets only capture cases that have been escalated and cannot be generalised to the wider experience of the process. There is no evidence on how many requests are rejected that do not escalate to Acas or tribunal.

2.2 Issues with processes

Most disabled employees who request adjustments receive some or all of their request

Survey evidence of disabled employees from multiple sources (Trades Union Congress, 2025; Unison, 2020; University of York, 2026) indicates that most who make a request receive all or some of the adjustments from their employer.^{[footnote 3]}^{[footnote 4]} On average, a third receive all their adjustments, with another third receiving some of them.

But employers and employees face issues across the process, with some of them particularly impacted at certain stages

Some employers may struggle when deciding on and implementing requests

Employers may rely on external organisations, such as Access to Work or those providing specialist equipment, which can cause delays at the decision and implementation stage.

Some employees find it difficult to request adjustments

Some evidence suggests employees are not requesting adjustments when they potentially need them. The Trades Union Congress (TUC) (2025) found that only 37% of disabled employees requested an adjustment.^{[footnote 5]} Of those that did not, 47% reported that they could have benefited from one. Similarly, the University of York (2026) found that 16% of surveyed individuals did not request an adjustment, despite feeling like they need one. More research is needed to understand the exact reasons why these employees are not making requests.

A minority of employees are having their requests refused

The TUC (2025) found 11% of disabled employees did not receive any of the adjustments they requested,^{[footnote 6]} while Unison (2020) estimated this number to be 20% of disabled workers.^{[footnote 7]} However, the scale of this is difficult to assess, as it is likely that some requests will be refused as they are clearly unreasonable. More research is needed to understand this further.

2.3 Knowledge gaps

Knowledge gaps are likely the biggest issue impacting the process for both employees and employers

Under the Equality Act 2010 (from now on referred to as the Equality Act), employers have a legal duty to make reasonable adjustments. However, the act leaves the meaning of ‘reasonable’ largely undefined. This inherent ambiguity is often seen as beneficial, providing flexibility to both employers and employees, and avoiding the restrictive nature of overly-prescriptive legislation. However, this can also create ambiguity about what the duty requires and how far an employer’s obligation extends. Although limited guidance should fill these knowledge gaps, both employers and employees continue to be uncertain about when the duty applies and what actions are necessary to meet it.

Employers are unclear on their legal duties under the Equality Act

In interviews, legal and academic experts, as well as tribunal judges and Acas conciliators, confirmed that the ambiguity of the Equality Act leaves many employers unsure of their legal obligations. Employers may be unclear on how far the duty extends, particularly around what may be considered reasonable or unreasonable.

Employees are unclear what may constitute a ‘reasonable’ adjustment

Employees are similarly disadvantaged by a lack of clarity in the law with some disabled employees requesting adjustments that are considered unreasonable. Others may not request adjustments at all, as they are unaware of their entitlements to support.

2.4 Additional barriers

We have identified 4 additional barriers which may undermine the efficacy of the process for both employers and employees, though evidence gaps make it difficult to assess their exact impact and scale.

Delays

Unison (2020) and the TUC (2025) both present delay as a major barrier to accessing adjustments.^{[footnote 8]}^{[footnote 9]} Acas conciliators acknowledged that delays may occur in this process but did not view them as particularly impactful. Neither legal experts nor tribunal judges viewed delays as a significant barrier to adjustments or to accessing justice. There is little evidence from the employer’s perspective here.

Fear of negative consequences

Academic research and survey data suggests disabled employees may avoid disclosing their impairments, and subsequently requesting adjustments, due to fears of stigma and discrimination. Experts note that employers also fear making the ‘wrong’ decision in relation to adjustment requests, believing they may lead to legal costs and/or reputational damage.

Lack of clear workplace practices

The TUC (2025)^{[footnote 10]} and University of York (2026) suggest that employers rarely have clear procedures in place for dealing with requests. Acas conciliators also reported the lack of clear processes in the workplace to be a significant barrier to employees accessing and employers implementing reasonable adjustments. There is no evidence on how many employers have practices in place, making a full analysis difficult.

Cost

Survey data from the TUC (2025) and Unison (2020) suggests that some employees have their requests refused as employers see them as unreasonable due to the high costs they would take to implement.^{[footnote 11]}^{[footnote 12]} However, numerous interviewees challenged this claim, explaining that most adjustments are cost neutral. Acas conciliators and tribunal judges similarly disputed the prevalence of cost, suggesting this is not a prominent barrier in escalated cases. We were unable to find views from businesses on this issue.

These barriers negatively impact employers and employees.

Certain employers are likely to be particularly impacted by an ineffective process

Issues with support for employers, such as delays in Access to Work funding, can mean employers are unable to provide adjustments, even where they wish to support disabled employees. Small and medium-sized enterprises (SMEs) are likely to be particularly impacted, as they may have no or very small HR teams. These companies will likely have less knowledge and capability to provide adjustments, especially compared to larger companies.

Employees’ productivity and conditions may worsen if not in receipt of essential adjustments

Research suggests not having adjustments leads to poorer retention, productivity and wellbeing. The Business Disability Forum (BDF) (2023) found that 49% of disabled employees said adjustments help them stay in their job,^{[footnote 13]} while 48% said they help them to be more productive. Unison (2020) reported that disabled employees who had not yet received adjustments took more sick leave and experienced increased pain and fatigue.^{[footnote 14]}

Question 3

3. Context and research challenges and key barriers

Accepted Answer

3.1 What are reasonable adjustments?

Reasonable adjustments are changes an employer makes to remove or reduce disadvantage that arise from an employee’s disability.^{[footnote 15]}

Employee rights and employer duties are set out in the Equality Act. The act establishes that:

A disability can be a physical or mental impairment.^{[footnote 16]} The act sets out that a person has a disability if their impairment has a substantial and long-term adverse effect on a person’s ability to carry out day-to-day activities. This also applies to some neurodiverse conditions.

Employees have a right to request adjustments, but employers are only required to make adjustments that are reasonable. This means that factors such as cost and practicability can be considered when deciding what is reasonable. It does not mean that employers must comply with every request made by a disabled employee. The act does not provide a definition of what qualifies as reasonable, though some further explanation is available in the statutory guidance (2011).^{[footnote 17]}

An employer must make reasonable adjustments when they know, or could reasonably be expected to know, that a disabled employee is placed at a substantial disadvantage compared to employees who are not disabled. To remove these disadvantages, employers may, for example, physically change the workplace, alter working patterns or provide assistive equipment. The act permits them to take this action in a pre-emptive manner.

Reasonable adjustments can be practical or procedural. Employees can request 3 kinds of adjustments to address their substantial disadvantage in the workplace. These include changes to a provision, criterion or practice (PCP) (for example, flexible working hours), changes to a physical feature of the workplace (for example, support rails in long corridors) and the provision of an auxiliary aid (for example, speech-to-text software).

The act applies to employers only in England, Scotland and Wales. It does not apply to Northern Ireland.

3.2 The reasonable adjustment process

The reasonable adjustment process typically involves 4 key stages. Employees may escalate disputes via Acas and the employment tribunal.

The barriers we have identified impact the different stages in this process, with most barriers occurring at the decision and implementation stages.

The Equality Act outlines an employer’s duty to make reasonable adjustments, but it does not specify the amount of time an employer should take at any of these stages. Instead, timeliness of employers at each stage is assessed on a standard of reasonableness: they should take “such steps as it is reasonable to have to take”.^{[footnote 18]}

Whilst these stages represent a typical example of how an employee would access reasonable adjustments, they do not represent a formal process. For example, not every employee would formally request an adjustment. Rather, we have identified these stages through our own analysis.

Figure: Reasonable adjustment process – 4 key stages

Stages in the reasonable adjustment process

Stage	What happens
1. Request	The reasonable adjustment duty is activated when an employer becomes aware (or could be expected to be aware) that an employee is substantially disadvantaged due to a disability. However, it is often a formal request from an employee that begins the process of granting or refusing reasonable adjustments.
2. Acknowledgement	If an employee has made a request, the employer then acknowledges it.
3. Decision	An employer then decides whether to accept or reject the request. The act does not contain a duty to consider reasonable adjustment requests, only one to make reasonable adjustments.
4. Implementation	An employer must implement it as soon as reasonably possible.

If a request is unsuccessful or not implemented appropriately, an employee can escalate their claim to Acas or to an employment tribunal.

Stage	What happens
5. Conciliation	If employees do not receive the adjustment they request, they may choose to escalate their case to Acas. At this stage a neutral conciliator will mediate the reasonable adjustment dispute between the employee and employer. Acas has no enforcement mechanism.
6. Employment Tribunal	Should the case not be resolved via Acas, the employee may take it before a judge at an employment tribunal.

3.3 Evidence challenges

Issues with data

Assessing the number of requests and disputes is difficult because they are not directly observable in national datasets.

There is no data on the number of reasonable adjustment requests made to employers.

Employers are not required to publish information on how many requests they receive or how they are handled.

Reasonable adjustment disputes are not recorded as a distinct category in national datasets. Complaints relating to reasonable adjustments are categorised in national datasets as disability discrimination cases, rather than being identified separately.

These datasets do not allow for the disaggregation of reasonable adjustment complaint data. Acas and HM Courts and Tribunals Service (HMCTS) do not disaggregate their data on disability discrimination, making it impossible to identify how many disability discrimination claims involve adjustment complaints. Tribunal decisions can be filtered by disability discrimination but not by reasonable adjustments. The Department for Work and Pensions’ (DWP) Access to Work programme does not capture adjustment-specific data. Relevant data could potentially be gathered through these existing systems but any changes to data collection would be highly resource intensive.

Certain adjustment disputes will not show in the data. Cases that are resolved outside of Acas or the tribunal are not reported in any capacity. Judges advised us that employers often require employees to sign a non-disclosure agreement, once a settlement has been reached. This makes it difficult to assess the extent of employers’ failure to comply with the adjustment duty.

The data is weighted towards disputes over adjustments, rather than instances of successful implementation. Disabled employees who have their adjustments implemented successfully will never end up at tribunal. Some employers may apply adjustments without ever using the legal language of the adjustment duty. Judges emphasised at interview that cases that reach tribunal represent the “tip of the iceberg” and that most requests for reasonable adjustments are probably actioned quickly by employers.

Limitations to external research

Analysis of issues in the process is also challenging due to the limitations of external research and data.

Academic research is limited. Disability law is a relatively small field. Where research does address reasonable adjustments, it rarely focuses on the employment context and tends to focus narrowly on specific disabilities, adjustments or sectors. We drew on forthcoming research by the University of York (2026) to plug some of these gaps.

Survey evidence is partial and uneven. Recent surveys by the TUC (2025),^{[footnote 19]} BDF (2023)^{[footnote 20]} and Unison (2020)^{[footnote 21]} are focused on reasonable adjustments, but these studies are not peer reviewed. These studies typically treat adjustments as a secondary issue rather than the primary focus. Their data also tends to focus on the decision and implementation phases of a reasonable adjustment process, rather than the acknowledgement phase. This means the evidence is uneven across the reasonable adjustment journey and can overstate issues in certain areas. These surveys focus overwhelmingly on the employee perspective.

There is limited evidence on employer perspectives and behaviour. Only the BDF survey provides a direct account of employer perspectives. Academic research on employer behaviour rarely focuses on reasonable adjustments. We have interviewed representatives from the business community, but more substantial engagement with businesses is needed to fully plug this evidence gap.

Limitations to our own research

There are limitations to our own research. Our review of employment tribunal judgements and survey of Acas conciliators presents specific challenges.

Cases that reach Acas and the employment tribunal are not representative of most adjustment requests. Most cases do not escalate through Acas or the employment tribunal, so our Acas survey and interviews and tribunal judgement analysis are weighted towards cases that end in dispute.

Our samples were small. We analysed only a fraction of published judgments and interviewed only a handful of conciliators. See the Annex D for more on the methodology of our original research.

3.4 Key barriers

Despite all these research challenges, our analysis shows disabled employees and employers face 5 main barriers to accessing and handling adjustment requests. They are:

delays
knowledge gaps
fear of negative consequences
a lack of clear workplace processes
cost

These barriers can exist independently, but often they are interdependent. For example, delays may occur because of an employer’s lack of knowledge around how to implement adjustments. A lack of clear workplace practices around disability might contribute to an employee’s fear that asking for reasonable adjustments may prejudice their employer against them.

The following chapters discuss each barrier in detail.

We analyse these from the perspective of the employee and employer. Where possible, each chapter considers the impact of a barrier on a disabled employee requesting an adjustment, as well as an employer dealing with a request. Most chapters group analysis by considering the employer and employee perspective, except for the delay chapter that is framed around the stages of the process where delay may occur.

We outline at which stage the barrier has an impact. Each chapter outlines which stage in the adjustment process the barrier is affecting. This is before assessing the scale of their impact at the end of the chapter.

Question 4

4. Delays in accessing reasonable adjustments

Accepted Answer

Delays occur at 3 stages of the process, with some employees waiting to have their requests acknowledged or to receive a formal decision. Both employees and employers face delays in the implementation phase, particularly when awaiting specialist equipment.

Stakeholders disagree on the significance and scale of delay as a barrier in the process. The TUC and Unison present delay as a major barrier for employees. Acas interviewees were more ambivalent, as were interviewees representing employer perspectives. Judges and other legal professionals argued that delay is not a significant barrier. This chapter assesses the evidence of delay at different stages in the process, as well as its causes and impacts.

4.1 Acknowledgement and decision delays

Evidence on delays in the acknowledgement and decision stages is limited.

The main issues are:

Limited evidence makes it difficult to assess the scale of the problem. Despite the TUC (2025)^{[footnote 22]}, Unison (2019)^{[footnote 23]} and a House of Lords report (2025)^{[footnote 24]} suggesting long waiting times in the acknowledgement and decision-making stages may be a problem, many other pieces of evidence do not identify this as a key pain-point of the process. For example, see Acas (2024)^{[footnote 25]}, BDF (2023)^{[footnote 26]}, Leonard Cheshire (2021)^{[footnote 27]}, Youth Futures Foundation (2023).^{[footnote 28]} Although surveyed Acas conciliators recognised delays at the decision stage, this only gives an indication of their prevalence among claims that are escalated, which may not be representative of the ‘typical’ reasonable adjustment request.

Data on acknowledgement and decision delays is not collected systematically, making it challenging to differentiate between delays in these stages. The distinction between the acknowledgement and decision phases depends on how a company deals with requests and likely differs between employers. A lack of standard practice in employer procedure and wider guidance means that data on delays at these stages is not collected systematically, with interviewees and survey participants often using ‘acknowledge’ and ‘respond’ interchangeably.

The available evidence suggests that a small number of disabled employees may experience delays in having their request acknowledged or in receiving a formal decision.

A small percentage of disabled workers may experience delays in employers acknowledging their request - with some potentially ignored entirely. The TUC (2025) found that 5% of the disabled workers who had requested reasonable adjustments had not heard back from their employers.^{[footnote 29]} Unison (2019) reported that a significant portion of disabled employees had their requests ignored, but attributed no numerical data to this finding.^{[footnote 30]} Respondents to our Acas survey also reported cases of employers ignoring requests, but 88% reported this happening in less than half of their cases (Annex D).

A greater number of disabled workers may experience delays in waiting for a decision. The University of York (2026) found that 23% of disabled workers waited over a month for a decision on their request, while 9.8% waited over 3 months. Expert interviews echoed these reports of delays around decisions. Similarly, 42% of surveyed conciliators said that employers “sometimes” delay decisions, while 33% reported this happening “often” in cases escalated to Acas (Annex D). However, our analysis of Employment Tribunal judgments found only one case explicitly referring to delay in the decision phase (Annex B).

4.2 Delays in implementation

A stronger base of evidence suggests that disabled employees might be facing long delays in the implementation of requests, even after they have been accepted.

Some employees seem to be facing significant delays when waiting for their adjustment to be implemented. Amongst the disabled employees who did request reasonable adjustments, BDF (2023) found that 1 in 8 faced delays in implementation^{[footnote 31]}, with Unison (2019) reporting that only 27% received their adjustments within one month of them being accepted.^{[footnote 32]} The TUC (2025) reported that 82% of disabled employees waited 4 months or more for their adjustments to be implemented.^{[footnote 33]} Unison (2019) survey data shows that 38% of disabled employees whose employers agreed to provide reasonable adjustments waited 6 months or more for implementation. Of the Tribunal judgments impacted by delays, three-quarters of those in our sample involved delays in implementation (Annex B).

However, many individuals appear to have their adjustments implemented in a timely manner. Research by Kumar and Provost (2022) suggests that although some interviewees waited “years” for their adjustments, others had them implemented in “minutes”.^{[footnote 34]} In the University of York’s (2026) survey, a majority of respondents reported no delays in implementation and 23% of respondents only experienced “minor” delays.

“It is not the reasonable adjustment decision that is a length[y] process, it is the implementation: supply, budget, provision, ongoing review. It is these latter stages that are currently letting employees down.” Angela Matthews, Business Disability Forum.

4.3 Reasons for delay

The number of complex adjustment requests is likely rising, increasing pressure on employers, which is probably causing delays.

Experts consistently identified a notable increase in cases involving mental health and neurodiversity claims. When surveyed, 79% of Acas conciliators reported that the number of cases citing mental health as grounds for adjustments had increased “significantly” (Annex D). There was a similar level of consensus among academic and legal experts.

Cases involving mental health and neurodiversity are often more ‘complex’, as they require procedural adjustments. Although mental health issues are not inherently more complex, experts explained that they are more likely to require procedural adjustments, such as flexible working. These adjustments can be harder to intuit and more challenging to implement. University of York (2026) found that employers and employees agree that decisions on complex cases can reasonably take longer than decisions on more straightforward cases.

Some argue that delays may be intentionally caused by employers, but the evidence suggests that employer-led delays are rarely intentional and often overstated.

A few experts expressed fears of employers intentionally delaying the process. A small number of academic experts and union representatives suggested that employers may be “waiting it out” - ignoring or intentionally delaying requests in the hopes that the issue will “just go away”. In particular, some Acas conciliators told us that smaller employers may “bury their heads in the sand” when they receive requests. Other academic experts identified employers of all sizes avoiding requests in this way, however, this was not consistently identified as a barrier by interviewees.

We were unable to find other evidence to substantiate these claims. Our analysis of Employment Tribunal judgments found no clear instances of employers intentionally delaying the process (Annex B). Similarly, only 8% of Acas conciliators surveyed noted this as a reason for delays (Annex D). As emphasised by a legal academic, very few employers are poorly intentioned. Rather, most employers are well-intentioned but may have limited understanding or capacity to fulfil requests (Annex E).

Current guidance does not provide employers with specific advice on how long they should take to acknowledge, decide on or implement a request. This likely contributes to delays in the process.

Guidance rarely recommends timelines for the process. Guidance on delays is absent from numerous key organisations, including from Acas (2025)^{[footnote 35]}, the Equality and Human Rights Commission (EHRC) (2019)^{[footnote 36]}, DWP (2025)^{[footnote 37]}, Scope (2025)^{[footnote 38]} and Mind (2025).^{[footnote 39]} Although a few organisations emphasise the importance of responding in a ‘timely manner’, they rarely present specific recommendations (for example, 2 weeks), because the timeframes to implement adjustments are similarly context dependent. This makes it difficult for employers to understand what timeframe may be considered “reasonable” at each stage of the process.

Administrative backlogs within key advisory organisations and funding agencies are also likely causing delays. For example:

Employers may rely on external organisations to support decisions on complex cases, which causes delays. Where cases are not straightforward, employers often reach out to other organisations, such as occupational health experts, for a second opinion. BDF (2023) found occupational health referrals to exacerbate delays, with many describing this support as “inaccessible”.^{[footnote 40]} In our survey of Acas conciliators, the most common reasons for delays were employers seeking a second opinion (83%), such as occupational health, and delays from an external organisation (58%), such as Access to Work (Annex D). Delays to seek further advice are often indicative of diligence, rather than negligence, and should thus be interpreted with caution.

Waiting times for Access to Work support and conciliation via Acas are increasing. The average processing time for Access to Work claims is currently 109 working days, compared to 66 working days in 2024 to 2025 and just 28 working days in 2021 to 2022 (National Audit Office, 2026).^{[footnote 41]} These backlogs mean employers are not receiving notifications of claims until late in the conciliation period. This delays the potential settlement of reasonable adjustment disputes and increases the likelihood of claims being escalated to Tribunal.

4.4 Impacts

Delays in accessing adjustments may be undermining productivity and retention of disabled employees. Possible consequences of this include:

Delays in accessing adjustments potentially hinder disabled employees from being productive in the workplace. The TUC (2025) reported that long waiting times have a “serious impact” on an employee’s ability to do their jobs well and to progress in their role.^{[footnote 42]} Similarly, in interviews, academic experts and charity representatives explained that delays at any point in this process undermine a disabled individual’s ability to complete their work effectively, as they continue to be “significantly disadvantaged” without them. These delays are, therefore, also to the detriment of the employer, as productivity during long-waiting periods is likely reduced.

Some individuals have reportedly experienced difficulties remaining in employment due to delays in accessing adjustments. Scope (2019) reported that 48% of disabled people who fell out of work did so because of a lack of reasonable adjustments.^{[footnote 43]} Kumar and Provost (2022) similarly report that disabled workers often have to “make do” while waiting for reasonable adjustments or simply not work at all.^{[footnote 44]} A report from RNIB (2023) also found individuals facing redundancy as a direct result of delays in receiving Access to Work funding for their requested adjustments.^{[footnote 45]}

Individuals still in their probationary period are potentially most significantly impacted by delays, though this group is likely quite small. One expert explained that some disabled individuals reach the end of their probationary period before having their adjustment granted, leading to their contract being terminated due to capability issues. This was also reported by RNIB (2023), with one respondent explaining that the failure to implement requested adjustments before the end of their fixed-term contract led to their contract being terminated.

Waiting for adjustments to be approved or implemented may also have a significant impact on disabled employee’s wellbeing.

Disabled employees report poorer mental health and wellbeing as a direct result of delays. Unison (2019) survey respondents felt frustrated and upset by delays, with some individuals reporting increased stress levels and suicidal thoughts as a result.^{[footnote 46]} Other respondents felt as though they were “being a pain” when chasing adjustments, which led them to withdraw their requests. BDF (2023) found that disabled employees experienced an “additional layer” of pressure and stress, when waiting a long time for their adjustments.^{[footnote 47]} Similarly, RNIB (2023) shared employee accounts of delays having a direct and significant impact on their mental health and confidence in the workplace.^{[footnote 48]}

Disabled employees also report worsening physical health symptoms due to delays, leading to increased sick leave. Unison (2019) survey respondents reported increased pain levels and fatigue, and the worsening of existing impairments as a consequence of delays. Unison also found that employees waiting for adjustments took more sick leave. It is important to note that Unison did not support this claim with statistical data, making it difficult to clearly assess the scale of this issue.

Delays – and confusion around them – could undermine access to justice for disabled employees, though this is rare.

There is a strict time limit for employees to file a disability discrimination claim with an Employment Tribunal of 3 months minus one day^{[footnote 49]} from the point of discrimination. Delays at any stage of the process could cause this time limit to lapse. If a case is filed after this time limit, regardless of the legitimacy of the claim, the case could be time-barred and thus thrown out. Tribunal judges may choose to waive the time limit in exceptional circumstances where they deem it ‘just and equitable’ to do so, however, this is rare and did not occur in any of the cases we reviewed.

In theory, delays in the process can prevent individuals from accessing justice via an Employment Tribunal. According to Acas (2025), some employees feel that their employers were testing their determination to go to Tribunal by prolonging various points in the reasonable adjustment journey.^{[footnote 50]} However, no evidence is available to substantiate this claim.

In practice, this barrier to justice is rare. Only 10.6% of the cases included in our analysis of employment tribunal judgments (Annex B) were time-barred and none of these could be clearly or exclusively attributed to delays earlier in the process. When interviewed, all Employment Tribunal judges corroborated this finding, describing the time limit as more flexible than it appears in legislation, particularly if individuals are filing more than one disability discrimination claim.

Question 5

5. Employer and employee knowledge gaps

Accepted Answer

Gaps in knowledge among employers and employees influence 2 stages of the process.

Employees may not request adjustments if they are unclear on their entitlements. Employers may make ‘wrong’ decisions if they are unclear on their duties.

Legislation around reasonable adjustments is intentionally ambiguous to allow necessary flexibility, but knowledge gaps exacerbate this. Ambiguity is inherent to the ‘reasonable’ definition of the law on adjustments, as outlined in the Equality Act. This means that a level of uncertainty about the definition is expected and not initially problematic. However, this ambiguity transforms into a barrier to accessing adjustments when combined with wider knowledge gaps among both employers and employees.

5.1 Employer knowledge gaps

Employers lack clarity over the adjustment duty. As a result, some employers may struggle to comply with it.

The law leaves the meaning of ‘reasonable’ largely undefined, creating grey areas for employers. Legal professionals told us that the meaning of ‘reasonable’ in the law is highly unclear. Although the EHRC (2015) Employment Statutory Code of Practice provides guidance on this^{[footnote 51]}, Acas workshop attendees explained that very few employers used this to guide reasonable adjustment decisions, particularly flagging a lack of awareness of this resource. Anecdotally, employers more commonly look to organisations, such as Acas, for information and support. However, Acas is neutral, mediating body, as opposed to a source of guidance or legal advice, meaning they cannot pass judgment on what may be considered ‘reasonable’. The ultimate arbiter of what is reasonable is the tribunal. So, if employers and employees disagree about the reasonableness of an adjustment, there is no definitive way to prove either side correct prior to the tribunal. One judge described this as the root of the problem in most reasonable adjustment disputes.

Most experts argued that employers’ knowledge of the reasonable adjustment duty is likely poor. Several experts pointed to a “knowledge and understanding gap” among employers. Judges suggested that while many employers are aware of reasonable adjustments as a concept and know that they have a duty to provide them, they are less informed on how to do so. DWP and the Department of Health and Social Care (DHSC) (2021) reported that employers, particularly SMEs, struggle to identify what constitutes ‘reasonable’ under the duty because they “lack awareness and understanding” of their responsibilities.^{[footnote 52]}

Existing guidance does not translate the legal duty into practical, operational advice. Multiple experts argued that available guidance offers too little detail on how to handle adjustment requests in real workplaces. Representatives from the business community said the law has not been effectively translated for the operational level. Scope similarly reported that employers want clearer guidance on what adjustments look like and how to build them into everyday working patterns and arrangements.

This lack of knowledge is likely particularly acute surrounding neurodiversity and non-visible conditions. Conciliators we interviewed argued that there is a definite lack of education amongst employers as to how to make adjustments for these conditions. Legal experts we interviewed agreed that employers struggle more with requests involving mental health issues than with those involving physical impairments, as these cases are often less intuitive and typically require more complex adjustments.

5.2 Employee knowledge gaps

Disabled employees do not always understand their rights under the Equality Act and may request adjustments that are likely to be deemed “unreasonable” as a result. Survey evidence and expert opinion suggests disabled employees specifically do not have knowledge of the reasonable adjustments that are available to them or how they can access them.

Disabled employees’ understanding of the different kinds of adjustment they can request is reportedly poor. Experts representing disability charities and unions suggested that disabled employees are unaware of the full scope of adjustments that may be available to them. In their survey of disabled employees, the University of York (2026) found that 5.1% of disabled employees who did not request an adjustment did not know what kinds of adjustment were available. Despite the EHRC Employment Statutory Code of Conduct (2015)^{[footnote 53]} offering comprehensive guidance, Acas workshop attendees questioned the accessibility of this resource for employees, particularly given its length.

New needs are arising as more young people are diagnosed with mental health issues. The House of Commons Library (2025) reported that disability prevalence in 16 to 24-year-olds more than doubled between 2013/14 and 2023/24.^{[footnote 54]} DWP (2025) found that the most common impairment types reported by working-age adults were around mental health.^{[footnote 55]} Business officials we interviewed suggested that businesses are struggling to adapt to this change.

There may also be a generational divide in expectations around adjustments.

Some experts suggested that younger disabled people have greater expectations when it comes to adjustments. One interviewee suggested that the adjustments young people receive in education are not often easily translated to workplaces because what is reasonable when providing a student with education is different from what is reasonable when considering a business’ economic objectives. This difference can cause frustration for younger employees.

However, this was not reflected in claim escalation data. There were no significant trends around age of claimant in our sample of employment tribunal judgments. Most individuals had been in employment for more than 4 years (62%) and represented a variety of ages. Additionally, age was not mentioned as a defining factor of case escalation by Acas workshop attendees or tribunal judges.

5.3 Impacts

Disabled employees may not request adjustments because they do not know they are entitled to them.

Recently published survey data shows that some disabled employees are not requesting adjustments. In the TUC’s 2025 survey, 47% of disabled employees who needed reasonable adjustments did not request them.^{[footnote 56]} Of these, 16% did not know they could request them from their employer. The University of York (2026) reported that 16% of disabled workers felt that they needed reasonable adjustments but did not ask for them. Of these, 9.6% were unaware they could ask for adjustments.

Knowledge gaps can create a misalignment of expectations between employers and employees over the reach of the duty.

Some employees believe employers have a greater duty than the one which exists in law. Judges and Acas conciliators we interviewed stressed that disabled employees sometimes believe that employers have a duty to make every adjustment that they request, as opposed to a duty to make adjustments in response to significant disadvantage in the workplace. Several legal experts reiterated that employers only have a duty to make adjustments that are deemed to be ‘reasonable’, as well as effective in addressing said disadvantage. This suggests that employees often do not understand the scope of this duty.

This may cause a misalignment of expectations over the duty, as employers may feel employees are making unrealistic requests. Scope (2019) reported that gaps in employee understanding of the Equality Act can lead disabled individuals to be unable to distinguish between “reasonable adjustments” and “adjustment requests that would be rejected”.^{[footnote 57]} The TUC (2025) reported that 24% of employers who gave a reason for rejecting reasonable adjustment requests said that the requested adjustment was ‘not practical to implement’.^{[footnote 58]} The disability charity Leonard Cheshire (2021) found that 67% of employers see the ‘practicalities’ of making reasonable adjustments as a barrier to employing disabled people.^{[footnote 59]}

Our own research suggests that this misalignment of expectations is the most frequent reason why requests result in disputes.

Conciliators we interviewed cited a “mismatch of expectations” as a crucial barrier in the process. 70% of Acas conciliators we surveyed suggested that ‘misalignment of expectations’ and ‘knowledge’ were the biggest barriers to accessing reasonable adjustments. 62.5% said that when there was a misalignment of expectations between employer and employee, it usually concerned whether the requested adjustment is reasonable or not (Annex D).

In our sample of employment tribunal judgments, misaligned expectations was the most common barrier. 68% of the cases we analysed involved misaligned expectations (Annex B).

Question 6

6. Fear of negative consequences

Accepted Answer

Both employers and employees are impacted by a fear of negative consequences. Employees may avoid requesting adjustments due to fears of discrimination.
An employer’s decision or implementation of an adjustment may also be influenced by fears of the impact on the wider workforce and/or potential escalation.

6.1 Employees’ fear of disclosing a disability

Employees are likely not making requests as they are afraid of the consequences of declaring a disability.

Reasons for this include:

Attitudes to disability in the workplace remain poor. In our interviews, many experts argued that stigma towards disability, particularly mental health issues and neurodivergence, remains a prominent issue in the workplace. Kumar and Provost (2022) reported that line managers often feel uncomfortable discussing disability with employees, suggesting employers still lack knowledge about impairment and disadvantage in the workplace and fear ‘doing the wrong thing’.^{[footnote 60]} BDF (2023) also found that 40% of disabled employees have felt ‘put down’ or patronised at work because of their condition.^{[footnote 61]}

“Stigma around disabled people using these provisions has not really declined.” Professor Nicholas Bacon, Bayes Business School.

Some employees fear requesting an adjustment will prejudice their employers against them, so do not disclose their disability. The TUC (2025) found that 34% of disabled workers chose not to disclose their disability, as they feared employers would think they could not do their job.^{[footnote 62]} Meanwhile, 24% of disabled workers felt they would not be supported if they disclosed their disability. The University of York (2026) also found 53% of disabled employees expressed concerns about potential negative consequences arising from requesting reasonable adjustments.

6.2 Employer’s fear of handling reasonable adjustment requests

Most employers are fearful of mishandling requests. This is because:

Employers may fear taking the wrong action when responding to requests. In a 2021 consultation on the health and retention of disabled employees, DHSC reported that employers fear “doing the wrong thing” when it comes to disabled workers, and being taken to tribunal as a result.^{[footnote 63]} In written evidence to the Lords’ Public Service Committee, DWP similarly suggested that employers “often have fears about saying or doing the wrong thing to disabled people in the work place.”^{[footnote 64]} Experts who engage with employers all raised this as an ongoing concern for most businesses.

Employers may fear the legal consequences that may come with requests. Legal experts told us that employers fear being taken through expensive tribunal cases. This prompts them to bring in legal advice early in the process, rather than engage with the request directly. An expert who works closely with businesses said that employers feel the “hairs on their necks stand up” when confronted with requests because the duty is so “legal-led.” This is especially true for smaller or medium-sized businesses that cannot afford a legal dispute.

Employers may believe that doing the wrong thing will damage their business. Legal experts and others told us how many employers fear the reputational damage that might result from incorrectly dealing with requests.

Employers may also fear the impact on their wider workforce when reviewing requests.

Employers often mistakenly believe that making adjustments for disabled employees means they must make them for non-disabled employees. As detailed by Olsen (2024)^{[footnote 65]}, EHRC stresses that it is not unlawful to treat disabled people more favourably than non-disabled people, as this does not disadvantage non-disabled people. Academic experts and disability advocates also told us that employers do not understand that it is not illegal to ‘positively discriminate’ against disabled employees. Adjustments are designed to level the playing field, not to provide disabled employees with an unfair advantage.

6.3 Impacts

Employees’ fears overwhelmingly impact the request stage of the process. This is because:

Businesses cite non-disclosure of disability as a significant barrier to providing adjustments. BDF (2023) reported that 81% of managers said it is easier to make adjustments when employees make them aware of their condition.^{[footnote 66]} Olsen (2024) found that employers cite employees’ non-disclosure of their disabilities as ‘the biggest challenge of employing disabled people’, including in relation to adjustments.^{[footnote 67]} Acas conciliators also told us of cases where employers are confused after some employees file an adjustment complaint having not requested an adjustment.

Failing to disclose a disability can also cause problems for disabled employees at tribunal. Kumar and Provost (2022) interviewed legal experts. They found that disabled employees are more likely to have their disability challenged by the employer at tribunal if they do not disclose their disability before later asking for adjustments.^{[footnote 68]}

Employers’ fears are likely impacting the acknowledgement and decision stage. This is because:

Some employers are likely rejecting requests because they are concerned about the impact on the wider workforce. Several experts suggested that employers choose not to grant adjustments because they believe that doing so would negatively impact their other employees. They also suggested that employers fear a “snowball” effect around granting adjustments, particularly around things like flexible working. Unison (2020) found that 32% of employers who rejected adjustments cited “impact on team performance” as the reason for their refusal.^{[footnote 69]} But without evidence from the employer’s perspective, it is very challenging to understand the accuracy and scale of this.

Question 7

7. Lack of clear workplace processes

Accepted Answer

Few employers have clear workplace processes for managing requests.
This absence of a clear process can cause issues at all stages for both parties. Employees may not understand how to make a request, and managers may be unclear on how that request should be managed.

7.1 Employers lack clear reasonable adjustment processes

Employers’ procedures around adjustments are not always clear, while others do not have them at all.

Many disabled employees do not know how their employer deals with requests. The TUC (2025) found that 1 in 5 disabled employees were never asked if they had a disability or condition, and that 19% did not know how to start a conversation about adjustments.^{[footnote 70]} In our workshop, Acas conciliators also told us that many employees expect a more proactive approach from employers.

Evidence suggests both employees and employers find current processes challenging to navigate, but it is difficult to assess the scale of this issue. Acas conciliators told us that some employers are unclear on their own processes, with different teams within an organisation unclear on who is responsible. Different layers of management can mean that decisions on adjustments can take a long time. Of the conciliators we surveyed, 29% said a “lack of clarity around the process” employers use was “often” a barrier to accessing adjustments, and 29% said this was “nearly always” a barrier. In the University of York’s (2026) survey, 5% of disabled workers did not request an adjustment because the process was too complicated. Legal experts and judges we interviewed also raised this issue.

Employers do not always train their line managers to understand how best to handle requests. Scope (2023) reported that 53% of employers were worried that their line managers could not understand the challenges faced by disabled employees.^{[footnote 71]} Kumar and Provost (2022) found that line managers do not know how to think creatively about how to implement adjustments and are often uncomfortable discussing disability.^{[footnote 72]}

Table: Surveyed Acas conciliators on how frequently a lack of clarity around the process of granting reasonable adjustments is an issue in disputes^{[footnote 73]}

Frequency	Number of occurrences
Rarely (0% to 20% of the time)	5
Sometimes (20% to 50% of the time)	5
Often (50% to 80% of the time)	7
Nearly always (80% to 100% of the time)	7

7.2 Impacts

Disabled employees may struggle to access adjustments because of complex or absent work procedures.

The workload for securing adjustments often falls on disabled employees. BDF (2023) reported that 78% of disabled employees had to start the process themselves.^{[footnote 74]} Only 10% said it was easy to get the adjustments they needed. In written evidence to the Lords’ Public Services Committee, the Youth Futures Foundation argued that young workers especially feel they have to “make a lot of noise” before receiving the adjustments they request.

The impact of this extra workload can be difficult for disabled employees to bear, especially if they do not receive the adjustments they request. We interviewed experts with lived experience of making requests. They argued that it is a “painful” experience to take on extra work and planning only to be told that the employer will not grant their adjustments. One academic noted how being disabled is a “full-time job” that is made much harder due to difficulties navigating the process.

Poor or absent procedures may contribute to delays in accessing reasonable adjustments. The University of York (2026) found that both employers and employees have different expectations on the frequency of communication. Employees believed that receiving updates every 4.3 days was reasonable, whereas employers believed updates every 8.4 days was reasonable, constituting a 95% difference in expectations. Additionally, where individuals are unsure of who is “in charge” of the process, the parties may delay actions, for example, if an employer expects an employee to reach out to an occupational health assessor (see example in Annex D).

Line managers often become responsible for handling requests despite their lack of training. Multiple experts told us that line managers often become “case managers” for a disabled employee’s adjustments, despite their lack of training. Acas conciliators also suggested that if employees rely on a line manager for their adjustments, then manager turnover can cause disputes if new line managers do not agree there is a need for an adjustment.

Question 8

8. Costs

Accepted Answer

The perceived or actual cost of adjustments impact the decision stage of the process. An employer’s decision on whether to grant an adjustment may be heavily influenced by the cost - or perceived cost - of that adjustment or the accessibility of funding.

8.1 Employers sometimes use cost as a justification for rejecting adjustment requests

Employers refuse adjustments they believe to have ‘unreasonable’ or prohibitive costs. Some experts suggested that some requests are simply too expensive to be classed as reasonable. The TUC (2025) reported that 19% of employers who had rejected adjustment requests suggested that the “cost was too high”.^{[footnote 75]} Similarly, Unison (2020) found that 23% of adjustment refusals were down to cost.^{[footnote 76]} Leonard Cheshire (2021) also found that 69% of employers cite the cost of making adjustments as a barrier to hiring disabled people.^{[footnote 77]}

Long waiting lists for Access to Work funding make it more difficult for employers to implement costly reasonable adjustments. The Access to Work Collective (2025) found that 78% of employers relied on Access to Work support to implement and maintain adjustments.^{[footnote 78]} DWP (2024) found that 11% of employers were not entitled to financial support because they were unable to part-fund the adjustments their employees had requested.^{[footnote 79]} Experts indicated that some employers may feel they have to dismiss disabled employees if their costs are not covered, or not covered quickly, by Access to Work.

But evidence suggests adjustments are often ‘cost-neutral’, leading to potentially reasonable requests being rejected. Only 4% of disabled employees in Kumar and Provost’s (2022) study required an adjustment that was not ‘cost-neutral’.^{[footnote 80]} Academic experts, union officials and disability advocates stressed in interviews that most adjustments are cheap to implement, and that companies benefit financially from the employees they retain through their implementation.

“Employers see adjustments as difficult and costly to make. Most are not that expensive. Many are cost neutral.” Katrina Gilman, Unison

8.2 The scale of cost as a barrier in the process is difficult to assess

Disputes about cost are rare in early conciliation or at employment tribunal, making it difficult to capture the scale of this barrier. Of the conciliators we surveyed, 54% said cost was only “rarely” a factor in disputes. In our analysis of employment tribunal judgments, only 5% of cases (3 out of 66) involved disagreements about the cost of adjustments. This suggests that companies are likely misinformed about associated costs before they are asked to implement them. It could also mean that employees find it harder to raise complaints against employers who argue that they cannot afford an adjustment.

Table: Acas conciliators on the frequency of the cost of reasonable adjustments as a factor in disputes^{[footnote 81]}

Frequency	Number of occurrences
Rarely (0% to 20% of the time)	13
Sometimes (20% to 50% of the time)	7
Often (50% to 80% of the time)	2
Nearly always (80% to 100% of the time)	1

Question 9

9. Conclusion

Accepted Answer

The evidence reviewed in this report suggests that while the reasonable adjustment process generally functions as intended, users face several barriers at different stages. Survey evidence from the TUC (2025)^{[footnote 82]}, Unison (2020)^{[footnote 83]} and University of York (2026) indicates that most disabled employees who request adjustments have them partially or fully implemented. This suggests that the system is largely functioning as intended. However, a significant minority of employees experience difficulties. Some do not request adjustments despite needing them. Others have requests rejected outright.

When examining why these problems occur, the weight of the evidence points strongly to one factor above all others: lack of knowledge about what adjustments are ‘reasonable’. The ambiguity inherent in current legislation is somewhat addressed by existing guidance. However, experts noted a lack of awareness of existing guidance and critiqued the accessibility of more comprehensive documents, leading to subsequent knowledge gaps among employers and employees. Nearly all experts interviewed identified these knowledge gaps as the most significant barrier. Our workshop with Acas conciliators and employment tribunal analysis support this conclusion, with judgments frequently revealing misunderstandings over what the duty requires.

Taken together, the evidence suggests that many of the process’ current challenges stem not from the design of the duty, but from poor understanding of how it should be interpreted and applied. Where expectations are unclear, disputes are more likely to occur and escalate. Where employers lack confidence in how to assess reasonableness, decision-making may become risk-averse or inconsistent. Improving clarity may reduce friction across the process without altering the statutory framework.

There is far less consistent evidence that other barriers are having an equally significant impact on the process. Evidence points to fear of negative consequences, unclear workplace practices and cost concerns as contributory factors. However, these appear secondary rather than primary drivers of issues in the process.

Delays in acknowledging and responding to reasonable adjustment requests are rarely identified as a key barrier to accessing adjustments. Although some survey data suggests delays in the implementation of adjustments are common and significant, this was not reflected in interviews, or our analysis of tribunal judgments and Acas survey results.

At the same time, the adjustment process is operating in a system under strain. Rising disability discrimination claims, Access to Work backlogs, and congestion at Acas and the employment tribunal system are increasing the time and complexity involved in resolving disputes. These structural pressures may be exacerbating problems, but they do not necessarily demonstrate that the process requires overhaul.

Policy reform should likely be targeted toward improving guidance, because it is not clear that the statutory framework is failing but rather under pressure. Tribunal judgments, conciliator evidence and expert interviews suggest that disputes arise mainly from misunderstandings about what the duty requires. Policy reform should be discussed with and informed by individuals with lived experience of disability and accessing reasonable adjustments, as well as employers of different sizes and sectors.