The Legal Position in Plain English

The Equality Act 2010 consolidated and strengthened a raft of previous anti-discrimination legislation. Under the Act, service providers — and that includes anyone running a public event — have a duty to make reasonable adjustments for disabled people. Sanitation is not exempt from this duty.

Section 20 of the Act sets out the reasonable adjustment obligation. Where a provision, criterion, or practice puts a disabled person at a substantial disadvantage compared with a non-disabled person, the service provider must take reasonable steps to avoid that disadvantage. Providing only standard portable toilets at an event attended by wheelchair users, people with mobility impairments, or those with certain medical conditions, is precisely the kind of arrangement the Act targets.

The Equality and Human Rights Commission has published guidance making clear that "reasonable" is not a fixed standard — it depends on the resources available, the nature of the event, and the likely makeup of attendees. A large commercial festival with thousands of attendees will be held to a considerably higher standard than a village fete run by volunteers.

What Accessible Provision Actually Looks Like

A standard portable toilet unit is, for many disabled people, entirely unusable. Accessible units are built to a different specification:

  • Wider door openings to accommodate wheelchairs
  • Grab rails positioned to assist transfer from a wheelchair
  • Non-slip flooring
  • Sufficient internal turning space for a wheelchair
  • Lower-height features where relevant
  • Baby-changing facilities in some configurations

The number of accessible units required is not fixed by statute for temporary events, but industry guidance and local authority licensing conditions frequently specify a minimum ratio. A common working figure is one accessible unit per 100 standard units, though this should be treated as a floor, not a ceiling.

Position matters as much as provision. Placing accessible units at the far end of a muddy field, some distance from the main event area, is unlikely to satisfy the reasonable adjustment duty. Units should be on firm ground, clearly signposted, and genuinely reachable by wheelchair without assistance.

Event Licensing and the Equality Act

Local authorities issuing Temporary Event Notices and premises licences under the Licensing Act 2003 often attach conditions relating to sanitation. Some councils have adopted policies that explicitly reference the Equality Act and require applicants to demonstrate accessible toilet provision as part of their event management plans.

Failure to satisfy these conditions can result in licence refusal or, where an event proceeds regardless, enforcement action. The Equality Act also provides individuals with the right to bring civil proceedings where they have suffered discrimination. The reputational and financial consequences of a complaint being upheld are not trivial.

Practical Steps for Organisers

  • Assess your likely audience. If disabled people are likely to attend — and for most public events they are — provision must reflect that.
  • Specify accessible units when booking portable toilet hire. Do not assume a standard package will include them.
  • Confirm placement with your hire company before the event. Accessible units must be on level, firm ground near the main footfall areas.
  • Document your planning. A written record that you considered and addressed accessibility demonstrates good faith if a complaint arises.
  • Review your steward briefing to ensure staff know where accessible facilities are and can direct attendees to them.

A Note on Companion and Changing Places Facilities

For larger events, particularly those running for more than a day or attracting attendees with complex disabilities, standard accessible units may not be sufficient. Changing Places facilities — which include a height-adjustable changing bench, a hoist, and more space — are increasingly expected at major public events. These are not yet mandated by legislation for temporary events, but the Building Regulations 2010 (as amended) now require them in certain new and refurbished buildings, and the direction of travel is clear.

Organisers who can demonstrate they have considered and provided for the full range of disability needs are on considerably stronger ground than those who tick the accessible-unit box and move on.

The Bottom Line

The Equality Act 2010 is not a bureaucratic nuisance. It reflects the straightforward principle that disabled people are entitled to use public events on the same basis as everyone else. Sanitation — basic, private, accessible sanitation — is not an optional extra. It is part of the duty. Organisers who treat it as such, rather than an afterthought, will find compliance both more straightforward and considerably less expensive than the alternative.