A reasonable-adjustments audit should test six things: the disadvantage or barrier, the adjustment agreed, the pupil's view, whether staff could use it, evidence of its effect and the next review decision. Sampling the newest file dates won't answer those questions. Schools need to compare the record with what happened across lessons, routines and wider school life.
This guide applies to schools in England and is accurate on 13 August 2026. It supports professional review and isn't legal advice. Whether a step is reasonable depends on the individual circumstances.
Keep the duty wider than the SEN register
Under section 20 and Schedule 13 of the Equality Act 2010, schools must take reasonable steps to avoid substantial disadvantage caused by a provision, criterion or practice, or by the absence of an auxiliary aid or service. For schools, the duty is anticipatory and continuing.
The audit therefore can't begin and end with pupils recorded as having SEN. A disabled pupil may not have SEN, and a pupil with SEN may not meet the Equality Act definition of disability. An EHC plan can contain relevant provision, but it doesn't replace the school's need to consider individual adjustments.
Physical features sit within the separate accessibility-planning arrangements. Route estate-wide findings into the school's accessibility plan while keeping the immediate question visible: what can staff do now to reduce the pupil's disadvantage?
Audit one adjustment through six fields
Choose a small sample and complete one row for each adjustment. Inspect the source record, then speak with the pupil and the staff expected to use it. A beautifully formatted plan can still be stranded on a shared drive, where many worthy intentions go to become archaeology.
| Audit field | Evidence to inspect | Question to resolve |
|---|---|---|
| 1. Barrier | Pupil account, observation, assessment, plan and family contribution | What substantial disadvantage may arise, in which activity or routine? |
| 2. Agreed step | Live passport, support plan, policy exception or auxiliary aid record | What should happen, where, when and for how long? |
| 3. Pupil view | Recent views, communication preference and any disagreement | Does the pupil find the step accessible, acceptable and likely to help? |
| 4. Use in practice | Teacher account, classroom visit, timetable, incidents and delivery record | Could relevant staff recognise and use it at the point of need? |
| 5. Effect | Participation, work, attendance, behaviour context and further pupil voice | Is the disadvantage reduced, and what uncertainty remains? |
| 6. Review | Decision, rationale, owner, date and route for challenge or correction | Continue, refine, replace or escalate, and who will do what next? |
Choose a sample that can reveal failure
Include pupils with and without EHC plans, and don't limit the sample to the SEN register. Add one recently agreed adjustment, one long-running adjustment and one that staff or the pupil say is difficult to use. Sample across teaching, unstructured time, trips, assessment, communication and policy decisions where relevant.
Look for predictable weak points: a supply lesson, room change, staff absence, busy transition or change of timetable. The question isn't whether the adjustment appears in a document. It is whether the school has made it available where the disadvantage arises.
Record gaps plainly. “No pupil view since March” or “delivery not evidenced for three lessons” is more useful than a confident green status whose supporting evidence has wandered off.
Let connected evidence change the review question
This made-up audit trail combines details to illustrate the decision. A pupil's passport allows a quiet start to design-technology lessons. The record says the adjustment is in place, yet late arrival and lesson-removal entries cluster on two timetable days.
The provision record alone suggests delivery. Classroom checks show that the designated room is sometimes locked, while pupil voice says asking publicly for the key feels exposing. Attendance information shows punctual arrival at school on those days. Together, the evidence changes the professional question from “Why won't the pupil enter?” to “Can the agreed route be used discreetly when the lesson begins?”
The action is to confirm the facts with the pupil and staff, make access dependable, agree a discreet prompt and review participation after a short period. The pattern doesn't prove why each event occurred, that the adjustment is legally required, or that the revised step will work. It gives the review a better question and an observable next action.
What the audit cannot decide
An audit can't diagnose disability, determine substantial disadvantage from a dashboard or produce a universal list of adjustments. The same step may reduce a barrier for one pupil and do little for another. Absence, behaviour or attainment patterns can prompt enquiry; they don't establish cause.
Nor does a completed row make an ineffective step reasonable. The current EHRC technical guidance stresses the need to consider effectiveness, practicability, resources, health and safety, standards, and the pupil's and parents' views. Record the evidence and rationale, hear challenge, and seek specialist or legal advice when the case requires it.
How Student Radar supports the audit
Student Radar's Pupil Passports can hold the agreed needs and strategies, while Provision Map keeps planned support and review points visible. Class Overview helps authorised teachers see relevant support before teaching, subject to their role and school access.
The wider pupil view can place attendance and behaviour context beside SEND records so a SENCo can inspect the underlying evidence. Student Radar doesn't decide whether an adjustment is reasonable or effective. The school retains the judgement, accountability and route for the pupil or family to question the record.
Close the audit with owned actions
- Select a mixed sample and identify the source record for each adjustment.
- Ask the pupil and relevant staff whether the step is usable in the real setting.
- Record missing evidence, uncertainty and disagreement without smoothing them away.
- Give every change an owner, a date and a route back to the pupil or family.
- Review the sample with a school leader and feed common barriers into policy and training.
For the behaviour-policy boundary, read the Cheam reasonable-adjustments guide. For document ownership, compare the accessibility plan and SEN information report. To see the connected workflow in your own context, request a focused Student Radar walkthrough.
Sources and further reading
- Equality Act 2010, section 20, legislation governing the reasonable-adjustments duty.
- Equality Act 2010, Schedule 13, application of the duty to education, including schools.
- Equality Act 2010: advice for schools, Department for Education, published 6 February 2013 and last updated 28 June 2018.
- Technical guidance for schools in England, Equality and Human Rights Commission, published 1 July 2014 and last updated 23 September 2025.
- SEND code of practice: 0 to 25 years, Department for Education and Department of Health and Social Care, last updated 12 September 2024.
- Draft schools in England technical guidance, Chapter 7, Equality and Human Rights Commission consultation draft, published 10 June 2026. It is draft material and doesn't replace the current guidance.