Accessibility compliance: Meeting the Equality Act in commercial buildings

How does the Equality Act 2010 apply to commercial buildings?

The Equality Act 2010 makes disability access requirements a fundamental consideration for commercial property landlords, developers and occupiers under UK law. In practice, however, these obligations are not absolute. 

New buildings must comply with Part M of the Building Regulations, which sets out standards for inclusive design. But for existing buildings,  rather than completely rebuilding or extensively renovating the premises, the Equality Act 2010 requires organisations to make reasonable adjustments to improve accessibility where practicable.

The key is to remove substantial barriers while balancing the cost, practicality and impact on the building. This approach ensures legal compliance while recognising that not every building can be made fully accessible without significant disruption.

What counts as a reasonable adjustment depends on factors such as:

• The size and type of the business

• Costs of installation and maintenance

• Physical constraints of the building - For example, older or listed buildings may have structural or heritage features that limit major alterations.

• The likelihood of need - There is an expectation that family spaces are more inclusive

What types of commercial buildings does the Equality Act apply to?

The requirement to make reasonable adjustments mainly applies to organisations that provide goods, services or facilities to the public. That means private offices, warehouses or other workspaces with no public access are not automatically covered. However, employers must still make reasonable adjustments for their employees.

The Act generally applies to:

• Retail stores – supermarkets, shopping centres and boutiques

• Restaurants, cafes and pubs – especially those that serve families

• Leisure and entertainment venues – cinemas, theatres, gyms and sports facilities

• Hotels and accommodation – particularly in areas that provide guest services, such as reception, guest rooms, restaurants and event spaces

• Public offices and service centres – for example, banks, post offices and council service points

Owners and occupiers must make reasonable adjustments that are practicable and proportionate, taking into account the building’s structure, cost and the available resources. That means older buildings are unlikely to require full retrofitting, but owners should still make practical improvements where possible.

Who is responsible for complying with the Equality Act 2010?

Under the Equality Act 2010, the duty to make reasonable adjustments generally falls on the person who owns, leases or manages the premises and has control over those areas. In practice, that means responsibility for compliance is usually shared between landlords and tenants, based on who manages the areas used by the public or employees and the terms of the lease.

Landlords

Landlords are typically responsible for the structure and shared building infrastructure. That often includes entrances, lifts, corridors, stairwells, shared toilets and other common areas. Where landlords control these areas, they may be responsible for making reasonable adjustments under the Equality Act 2010, although the exact allocation of responsibility will depend on the terms of the lease. 

Tenants

Tenants are usually responsible for making reasonable adjustments within their leased space, particularly those connected to their day-to-day operations. That includes internal signage, service counters, furniture layout, portable ramps and any equipment installed specifically for their business activities. If a tenant installs accessibility features, they are also usually responsible for maintaining them. 

Shared or negotiated responsibilities

In multi-tenant buildings, responsibilities are often shared or negotiated, especially when modifications are requested. For example, if a tenant requests modifications to the building, such as widening a doorway, the landlord may need to approve the work, but the tenant may fund and maintain it. 

This type of arrangement will usually be governed by the lease, which will set out the approval process and allocate responsibility for carrying out and maintaining the alterations.

If you’re not sure

If you’re unsure who is responsible for making reasonable adjustments, the first step is to review the lease agreement. It will usually outline each party’s responsibilities for inspecting, maintaining and repairing accessibility features.

If you’re still uncertain, seeking advice from a commercial surveyor or lease advisory team will help clarify your responsibilities, ensure compliance and avoid potential disputes.

Practical steps to ensure compliance

The Equality Act 2010 requires organisations to think ahead about accessibility. That means considering the needs of disabled people in advance and making reasonable adjustments where needed, rather than waiting until someone requests a change. 

To do that effectively, you should:

• Audit your premises to understand the barriers that people with a range of disabilities may face in your building

• Engage with tenants and building users to understand where improvements are needed

• Implement reasonable adjustments to improve accessibility

• Factor inclusive design into any refurbishments or future changes you make

• Monitor and review accessibility regularly to maintain compliance over time

• Keep documentation of audits, adjustments, and consultations to demonstrate proactive compliance

Taking these steps will reduce the legal risk of non-compliance, which can lead to financial penalties and reputational harm, and create a more inclusive and welcoming environment. As a landlord, you may also benefit from a wider tenant base, with more accessible properties appealing to a broader range of businesses. 

Making reasonable adjustments for more inclusive buildings

When it comes to making reasonable adjustments in commercial buildings, these are the key areas to focus on:

1. Accessible entrances

The first point of contact in any building sets the tone for accessibility, so it’s vital to get your entrances right. Doorways should be wide enough for wheelchairs and mobility aids, free from barriers, well-lit and clearly signposted. 

Features such as ramps, automatic doors and level thresholds will enable all individuals to enter the building safely. And if steps cannot be avoided, provide portable ramps or alternative access routes wherever practicable. 

2. External approaches

As well as the entrance, you should also ensure that the external approach, such as drop-off points, parking spaces and pathway surfaces, is suitable for disabled users. Other overlooked steps include ensuring entry systems, like keypads and intercoms, are placed at an accessible height and can be used by those with limited dexterity or visual impairments.  

3. Internal navigation and layout

Spaces should be uncluttered, with wide corridors and non-slip floors to enable safe, unencumbered movement. Adding clear signage with high-contrast text and braille or tactile options is a simple, cost-effective change you can make to assist people with visual or cognitive impairments. 

4. Staircases and lifts

Staircases should have handrails on both sides, with clearly marked, contrasting edges to improve depth perception and reduce the risk of falls. Lifts should be spacious enough for wheelchair users to manoeuvre comfortably and include features such as braille buttons, tactile indicators and audible floor announcements.

5. Restrooms and facilities

Commercial buildings that serve the public should provide at least one fully wheelchair-accessible toilet wherever practicable, equipped with grab rails, emergency alarms and sufficient space for manoeuvring. In larger public-facing buildings, it is also good practice to provide accessible baby-changing facilities to accommodate families and users with additional needs.

6. Interior design and furnishings

Inclusive design should go beyond compliance and shape how visitors and employees experience your space. You can use thoughtfully arranged layouts and furnishings to create clear, unobstructed pathways that make navigation effortless for all users. Adjustable desks, tables and service counters can also accommodate visitors and staff with different mobility needs. 

7. Emergency evacuation procedures

You must also consider the needs of people with disabilities in your emergency planning. Audible and visual alarm systems, clear and well-signposted escape routes, and evacuation chairs and refuge areas in multi-storey buildings help ensure everyone can exit the building safely.

How is the Equality Act enforced?

Enforcement of the Equality Act 2010 typically begins when customers, visitors or employees raise concerns with the organisation directly. If you are not able to resolve the issue, individuals may then take legal action by making a discrimination claim in the County Court or at an Employment Tribunal.

Beyond individual claims, there are regulatory bodies with powers to monitor and enforce compliance, although no single regulator inspects every building:

• The Equality and Human Rights Commission (EHRC) can monitor compliance, investigate complaints and provide guidance

• Advocacy groups sometimes bring test cases to ensure organisations meet accessibility standards

• Local authorities may become involved if accessibility issues affect planning permission or building regulations

If a building is in breach of the Act, you can face legal consequences, including compensation for injury to feelings, reimbursement of financial losses and court orders to make the premises accessible. 

Even in the absence of formal action, non-compliance can damage your reputation, discourage customers or tenants, and create operational and financial challenges. That makes proactively addressing disability access requirements and inclusive design a critical safeguard for your business and its public image.

Create accessible and compliant commercial spaces with us

At Eddisons, we can help you create a compliant commercial space that’s fit for the future. Whether it’s meeting disability access requirements, making reasonable adjustments or incorporating a more inclusive design, our building consultancy and refurbishment and fit-out teams will support you at every stage of the process. 

Please get in touch to discuss your goals or book an appointment at one of our offices throughout the UK.