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Operational AccessibilityThe Access Advantage

Temporary Doesn’t Mean Exempt

What the Equality Act means for pop-up venues and event infrastructure.

24 August 2026·Chris Fry·Strategic Access Advisory Limited, Sheffield
Outdoor festival stage with crowd, illustrating the temporary infrastructure that event organisers install

Photo: Pexels

Temporary structures can create very real accessibility barriers. The new EHRC Services Code gives event organisers an important reminder: audit the event you actually build, not simply the venue underneath it.

Temporary does not mean outside the Equality Act

When people think about physical accessibility, they tend to think about buildings. Steps, doors, lifts, toilets, corridors, counters. For the events industry, that can create a dangerous assumption: that the accessibility of the permanent venue is the principal issue and everything temporarily installed for an event sits somewhere outside that analysis.

The new Equality and Human Rights Commission Code of Practice for Services, Public Functions and Associations addresses this directly. A physical feature can include something brought onto premises by or on behalf of a service provider, even though it doesn’t normally occupy those premises. The Code gives a particularly relevant example: an outdoor theatre company bringing its own terraced seating to venues where it performs. That seating can itself constitute a physical feature for the purposes of the reasonable-adjustments duty.

Think about what gets built after the accessibility audit

Consider a festival site a week before opening. The permanent venue may have been audited. The accessible routes may have been identified. The plans may show accessible toilets, viewing areas and entrances.

Then the event build starts. Temporary grandstands arrive. Crowd-control barriers go in. Queueing pens appear. Cables cross pedestrian routes. Temporary bars and merchandise concessions are installed. Security fencing divides the site. Pop-up food, drink and merchandise stands occupy previously clear pathways. Hospitality platforms are erected.

The accessibility problem hasn’t been created by the landowner. It’s been created by the event infrastructure. And the fact that the structure is temporary doesn’t make the disadvantage temporary in any meaningful sense for the disabled customer who has bought a ticket for Saturday evening. For that customer, the barrier exists precisely when the service is being provided.

Crowd barriers can create accessibility barriers

One of the most overlooked parts of event accessibility is crowd management. Barriers are installed for good reasons: they manage queues, protect restricted areas, create emergency routes and help security teams manage large numbers of people safely. But their placement can dramatically alter an accessible route. A wheelchair user who could ordinarily travel directly across a concourse may suddenly face a lengthy diversion. Someone who can’t stand for long periods may find themselves channelled into a queueing system designed on the assumption that everyone can.

The full article covers cable management and trip hazards, pop-up concessions and temporary bars, queueing system design, portable toilet accessibility, and a pre-build accessibility review framework.

Cables crossing pedestrian routes can create trip hazards for everyone. For wheelchair users, ambulant disabled people, and people with visual impairments, they can constitute a substantial barrier to moving around the site safely.

The question is not whether the cable was always going to be there. It’s whether the route was reasonably accessible when the service was delivered.

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The full article covers cable management, pop-up concessions, queueing system design, portable toilet accessibility, contractor briefing obligations, and a complete pre-build accessibility review framework.

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What’s in the full article

Build-phase accessibility

Cables, pop-up concessions, queueing systems and portable toilets. The specific infrastructure decisions that create the most common accessibility failures.

Contractor briefing

Why the accessible route obligations extend to contractors installing temporary infrastructure and what a build-phase briefing should cover.

Pre-build review framework

A complete framework for auditing the event as built before gates open, not just the permanent venue before the event arrives.

CF
Chris Fry

Accessibility specialist and legal professional. Postgraduate legal qualifications, CEDR mediation accreditation. Experience in Court of Appeal and Supreme Court cases. Director, Strategic Access Advisory Limited.

This article provides general legal and operational information and doesn’t constitute legal advice. For organisation-specific guidance, contact us.

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General legal information, not legal advice. For organisation-specific guidance, contact us.

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