Reasonable Adjustments: A Manager’s Guide - July 2026
1. Introduction
Carmarthenshire County Council is committed to removing structural, organisational, physical and attitude barriers that disabled people may face.
This guidance is designed to advise any Carmarthenshire County Council manager who is responsible for implementing a workplace reasonable adjustment or support a disabled employee.
The guidance provides general advice on reasonable adjustments.
There are over 7 million people of working age in the UK living with a disability. However, not every disability is obvious or visible; in fact, 70% of people have a disability which is not visible. It is important as a manager[ALC1.1] therefore to not make assumptions when managing performance of your employees.
As a manager you are responsible for creating an open and supportive environment in which all the employees you manage meet their objectives and performance targets whilst enabling them to achieve their full potential in their role.
This includes disabled employees who may sometimes need you to make changes or “reasonable adjustments” to enable them to do so.
Whilst this guidance is primarily aimed at supporting employees living with a disability, the principles of this guidance can apply to all employees where reasonable adjustments may be appropriate.
This guidance covers all employees including centrally employed teachers but excludes staff on the complement of locally managed schools for whom a separate guidance applies. In the absence of guidance agreed locally by individual schools the principles of this guidance should be followed.
2. What Does the Term “Disability” Mean and Who is Included?
The term “disability” applies to a range of people with different impairments. It is not just visible physical conditions that are included, conditions such as anxiety[ALC2.1] or depression are also included in the definition.
As a manager you also need to be aware that under the law the term disability is so broad that people you might not think of as disabled are included, for example, people with diabetes, asthma, back problems, facial disfigurements and mental health conditions such obsessive-compulsive disorder[ALC3.1].
Managing an employee with mental ill health is the same as managing an employee with a physical illness. Your duty as a manager would be to try and put adjustments in place to help them through their ill health and stay in work/or return to work.
Employees diagnosed with cancer, Multiple sclerosis (MS) and HIV are automatically included from the point of diagnosis[ALC4.1]. Alcoholism/ substance addiction are not included in the definition although it may subsequently impact on physical and mental health and that may mean that an employee is defined as disabled. It is not possible to provide a comprehensive list of all the impairments that might lead a person considering themselves to be disabled. This is because the legal definition is broad and not always easy to apply.
3. What is My Role as a Manager?
It is your responsibility as the manager to ensure that the reasonable adjustment is put in place. As a flexible employer we need to ensure that we enable employees who are living with a disability to fulfil their potential as far as is reasonably practicable. As a manager you can agree adjustments in the short term so that the employee can carry out their work effectively and perform to a high standard. This could include for example, starting later to avoid traffic.
Sometimes the adjustment may be less straightforward, or you may need further advice in determining reasonable adjustments. In those circumstances you can seek support from HR, Occupational Health and Access to work, as appropriate.
4. The Law
The legal definition of a disability under the Equality Act 2010 is “a physical or mental impairment which has a substantial and long-term adverse effect on your ability to carry out normal day-to-day activities”.
The Equality Act 2010 does not prevent you as a manager from asking for information about an employee’s health or impairment. However, this information must not be used to discriminate. Understanding the negative effects of an impairment may also help you to explore with the employee if adjustments need to be made and what these could be. You must ensure there is positive communication between the employee in your team and yourself, whilst being sensitive and maintaining confidentiality always.
Reasonable adjustments need to be made in the following circumstances:
Where someone has declared or told us that they have a disability, illness or injury and requested reasonable adjustments.
Where it might be reasonably expected that someone would need an adjustment.
Where is might be reasonably expected that someone is disabled.
Where making a reasonable adjustment would enable the employee to do their job more effectively, regardless of whether they are covered under the legislation.
4.1 Finding out if someone has a disability
You only have to make these changes where you know or could reasonably be expected to know that an employee has a disability and is likely to be at a substantial disadvantage as a result. This means doing everything reasonable to find out. This does not however mean asking intrusive questions or ones that violate someone’s dignity. Think about privacy and confidentiality in what you ask and how you ask.
Example
An employee’s performance has recently deteriorated, and they have started being late for work. Previously they have had a very good record of punctuality and performance. Rather than just telling them they must improve; their manager talks to them in private. This allows the manager to ask whether the change in performance could be for a disability related reason. The employee says that they are experiencing a recurrence of depression and are not sleeping well which is making them late.
Together, the manager and the employee agree to change the hours of work slightly while they are in this situation and that the employee can ask for help whenever they are finding it difficult to start or complete a task. This is a reasonable adjustment.
4.2 When should we be making reasonable adjustments?
Reasonable adjustments should be made whenever necessary. This may include:
Recruitment and selection: this may apply to the way in which the application is completed, interview or test conducted, or any other criteria applied. Please see Appendix 1 for further details.
On starting employment: if a new employee is starting within your team you may need to make reasonable adjustments.
At any point during employment with us.
When undertaking learning and development.
On a change of role or transfer or working environment or conditions.
Before considering/making a reasonable adjustment there are many important issues that need to be taken into consideration. As the manager, please ensure that you complete the Reasonable Adjustment Action Plan with the employee (Appendix 2).
4.3 Is there a format for the discussion with the employee I can use?
Please refer to Appendix 2 – Action Plan.
5. Who Might Provide Support in Arranging Reasonable Adjustments?
• HR Business Partner (HRBP) – HR advice is important as some of the changes you may need to consider may affect individual’s employment contract;
• Occupational Health (OH) – in some circumstances occupational health may be able to provide advice on the adjustments that will enable an employee to operate effectively in their role;
• Access to Work: – A programme to support disabled people by helping them overcome work-related obstacles arising from their disability, if this is likely to last for 12 months or longer. Please refer to Appendix 3 for further details
• Other agencies – Please see appendix 3 for a list of specialist agencies and organisations. There are likely to be others that may be able to provide more specialist advice and assistance. For example, Dyslexia Action can provide assessments for dyslexia and assistance with specific adjustments that may be required.
5.1 Funding for reasonable adjustments
It is important to remember that as a manager, once it has been decided that an adjustment is reasonable. You have a legal duty to ensure that this is put in place. It is worth noting that most adjustments cost nothing or very little. Where adjustments are expensive, funding may be available through Access to Work (referred to above).
Please note that as a manager you may contact Access to Work for advice, but the onus is on the employee to contact Access to Work for an assessment.
An assessor will usually visit the employee and manager in the workplace to carry out an assessment of their needs. They will also advise of the funding that can be provided. Access to Work grants apply to any job whether full time, part time, and permanent or temporary.
6. What is Reasonable?
It can be difficult to assess whether an adjustment is reasonable, and a number of factors should be considered.
6.1 How much does a reasonable adjustment cost?
It is worth noting that most adjustments cost very little or nothing and are often a matter of flexibility or changing an approach to a working practice.
Where there is a cost involved in making the reasonable adjustment and you feel the cost could be prohibitive, you will need to consider:
How expensive the adjustment is in relation to Carmarthenshire County Council as a whole. As a large organisation it might be difficult for us to defend the failure to make a reasonable adjustment on cost alone. Advice should be taken from your HRBP in conjunction with your Head of Service if a reasonable adjustment appears too costly. Remember that in many cases grants may be reclaimed from Access to Work.
Will the adjustment benefit other people as well as the disabled employee? For example, clearer signage, better lighting and automatic doors may require an initial monetary investment but they would benefit many people.
6.2 How effective is the proposed reasonable adjustment?
A reasonable adjustment may only be considered reasonable if it reduces the disadvantage that the employee is facing. You must always ask the employee what they think would help them do the job but remember that people living with a disability are not always the experts on all the support available to them. OH, may be able to advise further where required.
6.3 How practical is it to make the adjustment?
Adjustments will only be reasonable if they are practical to make.
In some cases, the type of adjustment required may not be practical because of other circumstances e.g. if some structural work is required to a listed building, then this may not always be possible, although each case needs to be considered individually.
In some cases, you may need to consider different types of work by mutual agreement, and this may be a reasonable adjustment.
6.4 How much disruption will it cause?
The amount of disruption that an adjustment would cause to service delivery will affect whether an adjustment is considered reasonable. Whilst most adjustments cause no disruption at all and only affect the way in which an individual works there may be cases where a proposed reasonable adjustment causes too much disruption to service delivery, in which case alternative adjustments will need to be considered.
6.5 How does it affect other people in the team?
It is your role as a manager to make it clear that equality does not mean treating everybody the same; in fact, to treat people fairly we must treat them differently according to their needs.
Other team members including other managers/senior manager should only be told about a person’s disability or any health condition with the explicit consent of the employee.
They will need to be informed of any reasonable adjustment that is made if this has an impact on them and their working environment
If a disabled person feels valued and comfortable in the environment where they work, they are more likely to disclose their disability to you as their manager and to colleagues.
6.6 Does it pose a health and safety hazard?
It is important to consider whether a reasonable adjustment puts the disabled employee and others at risk.
If an adjustment poses an unacceptable risk to the health and safety of either the disabled employee or any other employees, then it will never be reasonable.
However, before a decision is made to refuse an adjustment on health and safety grounds you must ensure that you have all the facts and are not basing the refusal on assumptions. This means conducting a thorough risk assessment and seeking advice from a H&S Advisor. Examples of reasonable adjustments.
7. What if Someone Hasn’t Declared a Disability that you Suspect Exists?
As a manager you need to be aware that an employee may not tell you that they are living with a disability because:
They don’t think of themselves as living with a disability.
They don’t think they need reasonable adjustments.
They are worried about the perceived reaction of the organisation.
They fear the perception of harassment, bullying or resentment from colleagues.
As a manager you must be alert to any signs that may be disability related such as:
Their attendance has deteriorated.
Their performance at work has deteriorated.
Their behaviour at work has changed and they have become angry, withdrawn, tearful, forgetful or aggressive
Their timekeeping has deteriorated.
They appear to be in pain.
They are absent from work on medical grounds.
If any member of your team is experiencing any of these concerns, you should always consider the possibility that is may be disability related. However, do not make assumptions as all the above could be caused by other concerns or circumstances.
Rather than trying to determine whether an employee meets the definition of a disability, talk to them to try and find out what would help. Then try to introduce any adjustments you reasonably can to help them do their job either in the short or long term.
Having a good understanding of the way in which individuals in your team generally perform and behave will mean that you’re more likely to be able to identify any changes in them. In which case you should be able to have a conversation about what adjustments you may be able to make. Please refer to Appendix 4 for top tips on supporting the employee.
8. Ensuring Equality of Treatment
All employees are required to adopt a positive, open and fair approach and ensure the Authority’s Equality and Diversity Policy is adhered to and applied consistently to all irrespective of race, colour, nationality, ethnic or national origins, disability, religion and belief or non-belief, age, sex, gender reassignment, gender identity and gender expression, sexual orientation, pregnancy or maternity, marital or civil partnership status.
In addition, the Welsh Language Standards ask us to ‘ensure that the Welsh language is treated no less favourably than the English language’ and this principle should be adopted in the application of this Guidance.
If you have any equality and diversity concerns in relation to the application of this policy and procedure, please contact a member of the HR Team who will, if necessary, ensure the policy/procedure is reviewed accordingly.
If you require this publication in an alternative format, please contact People Services by emailing CHR@carmarthenshire.gov.uk
Appendix 2 – Reasonable Adjustment Action Plan
Full details here: Appendix 2 – Reasonable Adjustment Action Plan
Appendix 4 – Top Tips to Support Disabled Employees
Full details here: Appendix 4 – Top Tips to Support Disabled Employees