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The previous article set out the case for reviewing your companion ticket policy. This one gives you a framework for doing it.
An audit isn't a single meeting or a tick-box exercise. It's a structured review of how your organisation understands the access needs of disabled customers, how your policies reflect that understanding, and whether the systems you've built actually deliver the adjustments the law requires.
What follows is a practical framework organised into eight areas. Work through them in order, or use them to identify which parts of your operation need the most attention. Either way, you're looking for the same thing: the gap between what your policy says and what your customers actually experience.
1. Equality Act 2010 Duties
Before you review any specific policy, make sure your team understands what the law actually requires, not what they assume it requires.
The anticipatory duty
You're required to think ahead. The duty isn't triggered by a disabled person making a request — it's owed to disabled people generally, which means you need to consider what adjustments might be needed and put them in place in advance.
The substantial disadvantage test
The duty applies when a provision, criterion, or practice puts a disabled person at a substantial disadvantage compared to a non-disabled person. Substantial means more than minor or trivial — it doesn't require proof of harm.
The reasonable adjustment
The adjustment must remove or reduce the disadvantage. There's no single prescribed form — what's reasonable depends on factors including cost, practicality, the nature of the service, and the resources available.
The Eight Areas
Equality Act 2010 duties — your legal foundation
What your policy actually says
What your policy actually delivers
Your verification and evidence approach
How you handle edge cases and escalations
GDPR and the data you're collecting
Staff training and operational consistency
Continuous review and complaints-led learning
For each of the eight areas, the full article sets out the specific review questions you should be asking, the common failures we see across organisations, and the practical steps to close the gap.
The framework is designed to be used by a single person or a small team. It doesn't require external support to complete — though the findings often create a strong case for it.
The Access Advantage — Subscribers Only
This article continues in The Access Advantage
The full article works through all eight areas of the audit framework, with specific review questions, common failures, and practical steps for each.
Subscribers get monthly legal briefings translated into operational language, direct access to ask one question per month answered personally, and first sight of every tool and framework before public release.
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What's in the full article
Review questions
Specific questions to ask at each of the eight audit stages, with context on what a good answer looks like.
Common failures
The patterns we see most frequently across sport, music, entertainment, and live events — and how they generate complaints.
Practical steps
What to do when the review identifies a gap, including quick wins and longer-term policy changes.
Chris Fry
Accessibility specialist and legal professional. Postgraduate legal qualifications, CEDR mediation accreditation. Contributor to House of Lords and Commons Select Committee proceedings, and Court of Appeal cases. Founder, Strategic Access Advisory Limited.
This article provides general legal and operational information and is not legal advice on the circumstances of any particular organisation.