Treat every adjustment as a live case, not a one-off conversation. Record the request, the disadvantage it addresses, the decision and the reasoning behind it, then set a review date, ideally every six months as Acas suggests. Restrict access to the health information involved, and make sure a new manager can see the agreed adjustments without asking the employee to start again. A single, auditable record is what lets you show you acted, and acted consistently.
Most HR teams handle reasonable adjustments well when the person asking is in front of them. The trouble usually starts later when the manager who agreed to the adjustment leaves or moves teams. The new person has no way of seeing the occupational health report because it’s still sitting in someone else’s inbox. The phased return that was meant to be reviewed in March is still going in September because nobody added the check-in to the calendar.
That gap between the decision and the follow-through is where disability discrimination claims tend to appear. The Equality Act 2010 puts the duty on the employer, not the line manager, and a tribunal will want to see what the organisation did and when. Memory and email chains are not useful evidence.
It’s important that HR teams understand what the law requires, where adjustments typically go wrong, what a properly tracked adjustment record looks like, and how to control sensitive health information while still making it useful.
Section 20 of the Equality Act 2010 sets out three requirements. The first applies where a provision, criterion or practice puts a disabled person at a substantial disadvantage, such as a rigid shift pattern or a standard performance target. The second covers physical features of the workplace. The third covers auxiliary aids, which includes equipment and support services. In each case the employer must take the steps that are reasonable to avoid the disadvantage, and cannot require the disabled person to pay towards the cost.
Acas describes reasonable adjustments as changes an employer makes to remove or reduce a disadvantage related to someone's disability. Its examples range from extra time for tests and redistributed tasks to flexible hours, phased returns, adapted software and paid time for medical appointments. Employers are not required to change the basic nature of the job.
The duty applies when an employer knows, or could reasonably be expected to know, that someone is disabled. The second part is crucial. If a manager has been told about a condition in a one-to-one, or an absence pattern points clearly to one, the organisation may be treated as knowing even if HR never opened a formal case. Adjustments that only exist in a manager's notebook are still everyone’s responsibility.
The volume of disputes is rising. According to Acas research on disability discrimination tribunal claims, disability discrimination made up 8.7% of employment tribunal claims accepted in 2022-23, up from 5% in 2017-18. In early conciliation, it grew from under 10% of discrimination cases in 2020-21 to 14% in the first half of 2023-24.
The same research points to the background behind many of these cases. Disagreements over what counts as a reasonable adjustment were a core dispute, and claimants described employers refusing adjustments, delaying them, or withdrawing arrangements that had already been agreed. Prolonged internal processes and a perceived lack of engagement made cases harder to resolve without a hearing.
From an HR case management point of view, delay, withdrawal and silence are process failures. They are also the failures that a tracked case, with owners, deadlines and reminders, is designed to prevent.
Acas is also clear about what should happen when an employer decides a requested adjustment is not reasonable. The employer should talk to the employee, explain their reasoning, and try to find another adjustment that does work. A flat refusal with no record of the conversation puts the employer in a weak position if the case escalates.
A useful record is short enough to complete properly and specific enough to defend. For each employee, you should capture:
Consistency matters as much as completeness. If two employees in similar roles ask for similar adjustments and get different answers, you need a recorded reason for the difference. Without one, that difference is going to be hard to defend in a tribunal.
An adjustment is not finished when it is agreed. Acas recommends reviewing adjustments every six months, or sooner if something changes, such as the role, the equipment, the working pattern or the employee's condition. Acas also highlights written records and the reasonable adjustments passport as the way to protect continuity when staff change, so a new manager can see what is in place without the employee explaining everything again.
In practice, review dates only work if they generate an action. A date in a spreadsheet column doesn’t make things happen, but a task assigned to a named manager, with a reminder and an escalation to HR if it is missed, does.
Your reasonable adjustments policy should also say what happens when an adjustment is not working. Acas suggests that policies should cover how and when employees can access adjustments, how managers should respond, and how adjustments are reviewed and monitored. Sickness absence and capability procedures should be aligned with it, so a disability-related absence does not trigger the wrong process.
Information about an employee's health is special category data under UK GDPR, and the ICO expects organisations to have a valid basis for processing it and to protect it accordingly.
That can create a conflict: HR needs the full picture to make a fair decision but line managers only need to know what adjustment to make, without needing the details of the medical diagnosis. Occupational health reports should not be visible to everyone who can see the employee's file.
The workable answer is to limit access. Give managers a summary of the adjustments in place and the review date. Keep clinical detail in the case itself, only visible to the people handling it, and keep an audit trail of who has viewed what. This is much easier to do, not to mention more reliable, in a system built for case work than in a shared drive with folder permissions someone set up three years ago.
Tracking adjustments comes down to four things: one record per case, clear ownership, timely prompts and controlled access. That is what HR case management software is for.
At Workpro, HR teams can set up their own case types with configurable workflows, so a reasonable adjustments case can include the fields listed above and move through defined stages from request to review. Tasks can be assigned to named owners, and alerts and reminders prompt action when a review is due. Documents such as occupational health advice sit within the case, with restricted access, and email and letter templates keep correspondence consistent.
On confidentiality, Workpro offers case-level access restrictions and a full audit trail, with data held in UK-based, ISO 27001 certified data centres. The optional Workpro Connect module gives line managers a secure route to correspond with HR, which suits the manager-facing summary approach described above without opening up the whole case file.
Because every adjustment is a structured record, reporting becomes possible. You can see how many adjustments are open, which reviews are overdue, and which types of request take longest to resolve, enabling a proactive approach to improvements.
Reasonable adjustments are a legal duty, but the day-to-day reality is administrative: keeping track of what was agreed, who owns it, and when it next needs to be addressed. Acas research suggests that refusal, delay and withdrawn arrangements are what turn disagreements into tribunal claims. A well-kept case record makes all these issues clearly visible before they become a dispute.
HR teams that can show a time stamped request, a reasoned decision and a completed review will be in a far stronger position than those piecing together the story from old emails after a claim arrives.