A common assumption is that an employer can wait for Access to Work before changing anything for an employee with sight loss or hearing loss. The wait for a decision is now more than 100 days on average, so the assumption has real consequences. This article explains how the employer’s duty to make reasonable adjustments sits alongside the scheme, what the law asks employers to do in the meantime, and how a private workplace assessment can give them something concrete to act on. It is general information and not legal advice.
The duty does not depend on a grant
Under section 20 of the Equality Act 2010, an employer must take reasonable steps to avoid a substantial disadvantage to a disabled person where a provision, criterion or practice, a physical feature or the absence of an auxiliary aid puts them at that disadvantage compared with people who are not disabled. A person with sight loss or hearing loss may meet the definition of disability where the effect is substantial and long-term, and the effect of aids such as hearing aids is ignored when deciding that. Whether the definition is met depends on the individual.
The Act does not list waiting for an Access to Work decision as a reason for delay. The duty arises when the employer knows, or could reasonably be expected to know, that the person is disabled and likely to be placed at a disadvantage, as Schedule 8 sets out. An employee who tells their manager they cannot read the screen, or cannot follow meetings, has given the employer that knowledge.
Who pays
Acas and the Equality and Human Rights Commission both state that the employer is responsible for paying for reasonable adjustments, and section 20 says the employer cannot require the disabled person to pay. GOV.UK says Access to Work will not pay for adjustments an employer must make, but it can advise whether a change is one the employer should make. What is reasonable depends on factors such as practicality, cost, the size and resources of the organisation and whether the step would remove or reduce the disadvantage. A small employer may be expected to do less than a large one, and a very low-cost step is more likely to be reasonable.
In practice, many adjustments for sight loss and hearing loss are inexpensive, such as lighting, display settings, formats, agendas, captions and seating. Where an expensive item is involved, Access to Work can contribute, and an employer who is waiting for that decision can still make the changes that are within reach.
How long is too long?
The Act sets no fixed time limit, and what counts as reasonable depends on the circumstances. A short, explained delay while an employer arranges equipment is very different from months of inaction. The National Audit Office reported that Access to Work processing had reached 109 working days in November 2025, against a target of 25 days, so an employer who relies on the scheme alone may be waiting well beyond the point at which a reasonable employer would have acted. Whether a particular delay was reasonable is a question of fact, and anyone facing a dispute should take legal advice.
What a reasonable response looks like while waiting
A sensible employer will usually do five things. It talks to the employee about the specific barriers. It makes the quick, low-cost changes straight away and records them. It decides whether a specialist assessment is needed to work out the rest. It supports the Access to Work application in parallel. And it sets a date to review what has been done.
Where the employee is returning from sickness absence, GOV.UK fit note guidance explains that a fit note can say a person may be fit for work with changes such as a phased return, altered hours, amended duties or workplace adaptations. A return to work assessment can turn those options into specific, workable changes for the person’s job before they come back.
How a private workplace assessment helps
People often search for a private Access to Work assessment when they want to move faster. Access to Work is a government scheme with its own process, and Visualise Training and Consultancy Ltd is an independent provider, not part of it. A visual impairment workplace assessment or a hearing loss workplace assessment is a separate piece of work. It looks at the person, the job and the workplace, names the barriers in the tasks that matter, and recommends adjustments with a sensible order of priority.
That gives an employer a record of what was recommended and why, and something specific to act on now. It may also be useful supporting information if an application is made, although the scheme decides for itself and nothing can be promised.
What this means for occupational health, HR and case managers
If you are advising a manager, the most useful message is short. The duty is the employer’s, the grant is a separate question, and the first changes do not need to wait. Keep a written record of the conversation, the steps taken and the dates, because that record shows what the employer did and when. Where a report is commissioned, ask that it names each barrier, each adjustment and what to do first. Anything that turns on whether an adjustment is reasonable in a particular case is a matter for legal advice.
Summary
Access to Work is a helpful grant, not a precondition for acting. The employer’s duty arises when it knows of the disadvantage, the employer generally pays for reasonable adjustments, and a long wait is not a reason in itself to do nothing. Making early low-cost changes, recording them and arranging a private workplace assessment where the picture is unclear is a practical way to meet the duty while the scheme catches up.
Watch the short film
This short film follows an employee who needs equipment while government support is pending. Their manager wants to help but assumes the cost would come out of her own pocket, so she stalls. When she asks finance, the answer is that this is what the budget is for. A workplace assessment is booked and the equipment arrives in weeks. The film lasts about a minute.
Frequently Asked Questions
The Equality Act 2010 does not list waiting for a grant decision as a reason for delay. The duty arises when the employer knows, or could reasonably be expected to know, about the disadvantage. Seek legal advice on a specific case.
Acas and the Equality and Human Rights Commission both say the employer pays, and the Act says the employer cannot require the disabled person to pay. Access to Work can help with other support.
The Act sets no fixed period. What is reasonable depends on the circumstances, such as the cost, the practicality and the resources of the employer.
No. It is separate. It gives the employer practical recommendations to act on now and may be useful supporting information for an application, but the scheme makes its own decisions.
The conversation with the employee, the barriers identified, the adjustments made and the dates, and the review date. Keep the record factual and shared with the employee.
If you or someone in your team is visually impaired, deaf or has hearing loss and would like expert, tailored support to stay productive and comfortable at work, visit https://visualisetrainingandconsultancy.com/workplace-assessments/ to arrange a workplace assessment.
Sources
legislation.gov.uk, Equality Act 2010, section 20: https://www.legislation.gov.uk/ukpga/2010/15/section/20
legislation.gov.uk, Equality Act 2010, Schedule 8: https://www.legislation.gov.uk/ukpga/2010/15/schedule/8
Acas, Reasonable adjustments: https://www.acas.org.uk/reasonable-adjustments
Equality and Human Rights Commission, Paying for reasonable adjustments: https://www.equalityhumanrights.com/en/multipage-guide/paying-reasonable-adjustments
GOV.UK, Access to Work: https://www.gov.uk/access-to-work
National Audit Office, The Access to Work scheme: summary (February 2026): https://www.nao.org.uk/wp-content/uploads/2026/02/the-access-to-work-scheme-summary.pdf
GOV.UK, Getting the most out of the fit note: guidance for employers and line managers: https://www.gov.uk/government/publications/fit-note-guidance-for-employers-and-line-managers/getting-the-most-out-of-the-fit-note-guidance-for-employers-and-line-managers