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Equality Act 2010 for Service Providers
What the Equality Act 2010 requires of service providers in England and Wales: the anticipatory duty, reasonable adjustments, indirect discrimination, and how the 2026 EHRC Statutory Code changed the picture.
The Equality Act 2010 is the framework every service provider in England and Wales operates within when they serve the public. For organisations in sport, music, entertainment and live events, the parts that matter most are the disability provisions in Part 3: the duty to make reasonable adjustments, the anticipatory duty that sits on providers as a class, and the prohibition on indirect discrimination.
On 5 August 2026 the EHRC's replacement Statutory Code of Practice for Services, Public Functions and Associations became the definitive framework courts must apply. It revoked the 2011 Code and substantially updated the disability chapters, including express references to neurodivergence and a fuller treatment of the anticipatory duty drawn from 15 years of caselaw.
The Act isn't a compliance hurdle. Treated properly, it's a design blueprint. The organisations that build their customer experience around it face fewer claims, better reviews, and a stronger tender position. The ones that treat it as a box to tick are the ones that end up in Court.
The anticipatory duty
You owe the duty to disabled people generally, not just to the individual in front of you. You have to think ahead about the barriers your service creates and how to remove them, before a disabled customer has to ask.
Reasonable adjustments
The duty to take such steps as are reasonable to remove a substantial disadvantage. Cost is one factor, weighed against your resources and the effect on the disabled person. It is not, on its own, a defence.
Indirect discrimination
A blanket policy that looks neutral but puts disabled people at a particular disadvantage is unlawful unless it can be objectively justified. Most blanket policies in customer-facing settings can't be.
The 2026 EHRC Code
The replacement statutory Code is now in force. Courts must apply it. It names neurodivergent conditions expressly and expands the anticipatory duty guidance. Every service provider should be reviewing policies, training and complaints procedures against it.
Articles on this topic
The Problem with EMMA: Crash Test your Tech
When AI can't understand the customer, and what it means for every customer-facing business. Chris Fry on the Rotherham GP AI receptionist, the revised EHRC Code, and why AI doesn't remove the reasonable-adjustments duty, it can create a new one.
Read article →Failure to Make Reasonable Adjustments Compensation: What the Courts Award and Why
Reasonable adjustments failures are the most common disability discrimination claims against service providers. Chris Fry on how compensation works, what Courts award, and the patterns that show up in real cases.
Read article →Reasonable Adjustments Examples: What Works in Sport, Music, Entertainment and Live Events
Most organisations understand they have a duty. Far fewer understand what a good reasonable adjustment looks like in practice. Chris Fry sets out real examples across sport, music, entertainment and live events, and the patterns that end up in Court.
Read article →The warning period has ended. The replacement statutory Code now applies.
On 5 August 2026, the EHRC's replacement Code of Practice for Services, Public Functions and Associations became statutory and the 2011 Code was revoked. Chris Fry explains what every service provider, venue and public body needs to do now.
Read article →Are American-Style Disability Testers Coming to the UK?
Strategic litigation is changing. Campaigners are already bringing multiple Equality Act claims, publishing litigation guides, and using Courts to challenge recurring operational failures across entire sectors. Chris Fry on the risk every UK venue should be thinking about now.
Read article →Plummer, Listed Buildings, and the “Cost Excuse”
“We can't afford it” is the most common reason organisations give for not making a reasonable adjustment. The County Court decision in Plummer v Royal Herbert Freehold Ltd shows why cost alone is rarely a defence. Chris Fry on what every venue and heritage site should take from it.
Read article →Passenger Assistance Isn't Delivered Until the Adjustment Actually Works
Recording a reasonable adjustment isn't the same as delivering it. Chris Fry examines Doug Paulley's GTR disability discrimination settlements and the operational lessons every service provider should take from them.
Read article →Stop Asking 'Are You Disabled?' Start Asking 'What Do You Need?'
The debate about disability proof has become polarised. Chris Fry argues we're asking the wrong question, and that the Equality Act points to a better operational approach for venues and service providers.
Read article →Ten Days to Compliance: The EHRC Code Changes Everything for Digital Accessibility
On 5 August 2026 the EHRC's new Statutory Code of Practice became the definitive framework courts must apply to Equality Act claims. For organisations with digital customer journeys, the implications are immediate.
Read article →The 2026 EHRC Code: Everyone Missed the Disability Chapters
The legal press wrote thousands of words about the updated EHRC Code of Practice. Almost all of it was about sex and gender. The disability chapters, neurodivergence, the anticipatory duty, and 15 years of updated caselaw got almost no coverage. Chris Fry explains what service providers actually need to know.
Read article →Summer Camps, Volunteer Organisations and the Equality Act 2010
Every summer thousands of volunteer-led organisations run camps, residential trips and sports tours. The legal risks around operational accessibility are frequently overlooked, and 'we're only volunteers' isn't a defence.
Read article →The Blame Game
The venue says it was the promoter's problem. The promoter says it was the venue's problem. The ticketing platform says it just sells tickets. Chris Fry explains why the Equality Act 2010 does not accept any of those answers, and what it actually means for who gets sued.
Read article →The Right Person for the Job
Automated screening software is quietly filtering out disabled candidates before any human sees their application, and the employers deploying it are carrying the legal exposure.
Read article →Related resources
How Strategic Access Consulting can help
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