No, an access audit isn't a legal requirement. That's the wrong question.

I get asked this a lot, usually in a tone that's hoping for a no.

So here's the straight answer. No statute says you must commission an access audit. There's no inspection, no certificate, nobody turning up to check.

And if you stop reading there you'll make a bad decision - because the law doesn't work the way the question assumes.

What is actually required

The duty to make reasonable adjustments is law. That bit isn't optional and it isn't new.

The part people miss is who it's owed to. Schedule 2 of the Equality Act 2010, at paragraph 2(2), says that for services the reference to a disabled person "is to disabled persons generally".

Read that again - because it's doing a lot. The duty isn't owed to the disabled person who turned up and complained. It's owed to disabled people as a group, in advance, whether or not any of them has walked through your door yet.

That's what anticipatory means - and it's why "nobody has ever asked us" isn't a defence. It's the thing you were supposed to have sorted before anybody had to ask.

So the duty is real and the duty is continuous. What's not specified is how you discharge it.

Where the audit comes in

The Equality and Human Rights Commission issues a statutory Code of Practice on services, public functions and associations.

There's a new one. It came into force on 5 August 2026, approved by the Secretary of State and laid before Parliament. If you're working from the 2011 edition, as a lot of advice online still is - you're reading a superseded document.

Paragraph 3.52 sets up a list. Service providers and people exercising public functions "are more likely to be able to comply with their duties under the Act" if they take certain steps.

Paragraph 3.53 gives four of them for the reasonable adjustments duty specifically. Review regularly whether services are accessible to disabled people. Carry out and act on the results of an access audit carried out by a suitably qualified person. Provide regular staff training relevant to the adjustments. Review regularly whether the adjustments are working, and act on what you find.

So there it is, in a document the state wrote. Not "you must" - but an access audit named as one of four things that help you meet a duty you definitely have.

Does a Code of Practice actually matter?

This is the bit worth understanding - because people hear "code of practice" and mentally file it next to a leaflet.

Section 15(4) of the Equality Act 2006 does two things - and they pull in opposite directions.

First: "A failure to comply with a provision of a code shall not of itself make a person liable to criminal or civil proceedings." So not having an audit is not, on its own, unlawful. That's real - and I'm not going to pretend otherwise.

Second, and this is the half that gets left out: a code "shall be taken into account by a court or tribunal in any case in which it appears to the court or tribunal to be relevant."

Shall. Not may.

So picture the actual scenario. Somebody brings a claim about your building. The question in front of the tribunal is whether you did what was reasonable. Sitting on the bench is a statutory Code, which the tribunal is required to consider, listing four things that would have helped, one of which is an access audit by a suitably qualified person.

You don't have to have done one. You just have to be comfortable explaining why you didn't.

"Act on", which is the half everyone drops

Look at the wording again. Carry out and act on the results of an access audit.

Not commission one. Not hold one. Act on it.

An audit sitting in a drawer is not the thing the Code describes. It might be worse than not having one - because now there's a document saying somebody told you about the problem and recording the date they told you.

That's not a reason to avoid getting one. It's a reason to only get one you intend to use - and to prefer the version that costs the findings three ways so you can act at whatever budget you actually have rather than filing it until you can afford everything.

What else is genuinely compulsory

Two things worth separating out, because they often get muddled into the same question.

Building Regulations. Part M applies when you build, extend or materially alter. It bites at that moment, through building control - and it isn't a continuing duty to keep auditing the finished building. If you're not doing work, Part M isn't asking you anything today.

Fire safety is different. A fire risk assessment is separately and genuinely required, and it has to account for everybody who uses the building. In practice that means the means of escape for people who can't use stairs is already a legal obligation, whatever you decide about access more broadly. That one isn't optional - and a lot of organisations are quietly not doing it.

About "suitably qualified"

The Code says suitably qualified. It doesn't define it, and there's no licensed profession here, no register you must be on, no protected title.

So that phrase is doing less work than it looks like it's doing - and it's worth knowing what to actually ask rather than taking a badge at face value.

Ask what standards they'll assess against, and listen for whether they name current ones. Ask whether findings come costed and prioritised, or as a flat list. Ask what happens to the sensory and cognitive side, because an audit that only covers physical access has answered part of the question. And ask whether disabled people were involved in producing it, which is a different question from whether the consultant has a certificate.

I'd rather you asked me those four things than took anybody's word, including mine.

The honest version

If you want permission to do nothing, you have it. Nobody is coming.

But the duty is anticipatory - which means it's running right now, for people who haven't arrived yet and who mostly won't tell you when they turn away. And the statutory Code that a tribunal must take into account names an audit, acted on, by somebody suitable.

The question isn't whether it's required. It's what you'd say if somebody asked why you hadn't.