A passenger has to be able to book before a wheelchair-accessible taxi is any use at the kerb. For a taxi or private hire operator, that booking is part of the service covered by the Equality Act.
Section 29 of the Equality Act 2010 covers a person who provides a service to the public, or to a section of the public, whether or not a charge is made. The provider must not discriminate against a person who requires the service by refusing to provide it. A duty to make reasonable adjustments applies to the service provider. The section applies in England, Wales and Scotland.
The Equality and Human Rights Commission’s statutory code of practice, published on 5 August 2026, says that obligation also applies to a service provided on a website. The code does not make new law or create a new legal obligation. It explains duties already in the Act.
A booking on an app
Some services are provided remotely, through a website or an app, and the Act applies to that conduct in Great Britain. Part 3 also applies to certain transport services, with ticketing given as an example in Chapter 11. The example is a theatre that sells tickets at the box office or through an app. Refusing bookings from wheelchair users is likely to be direct disability discrimination on either route. Part 12 of the Act, as amended by the Taxis and Private Hire Vehicles (Disabled Persons) Act 2022, sets specific duties on taxi and private hire drivers, which this code does not cover. For an operator, the booking question sits under the Part 3 duty on the service offered to the public.
Before a passenger asks
Schedule 2 provides that, for a service, the reasonable-adjustment duty is owed to disabled people generally. That makes the duty anticipatory. A provider is expected to consider barriers disabled people could face, and to act, before a disabled passenger tries to use the service. Leaving it until that point can make the adjustment too late.
A provider is not expected to foresee every individual. The requirement is to think about people with different kinds of disability, because the barriers are not all the same. Once a particular passenger’s difficulty is known, a further step for that person may be reasonable.
The duty continues, and it needs to be kept under review. A step that was enough can stop being enough. A change in technology can also make a step reasonable when it was not reasonable before.
What counts as reasonable
The chapter on reasonable adjustments sets out three requirements. Take reasonable steps to avoid a substantial disadvantage caused by a provision, criterion or practice. Take reasonable steps to avoid a substantial disadvantage caused by a physical feature, or adopt a reasonable alternative. Provide an auxiliary aid where the lack of one puts disabled people at a substantial disadvantage.
What is reasonable depends on the circumstances, including the type of service, the provider’s size and resources, and the effect of the disability. The factors include whether the step would overcome the disadvantage, whether it is practicable, the financial and other cost, the disruption, the resources available, what has already been spent on adjustments, and whether financial or other help is available. A provider with substantial resources is more likely to be expected to meet a significant cost.
A step that would fundamentally alter the nature of the service, or the nature of the provider’s trade or profession, is not required.
An auxiliary aid has to work in practice. One that does not give disabled people access is not treated as a reasonable step. Where there is genuinely no reasonable step that would give access, making no change is unlikely to breach the duty. That situation is likely to be rare.
Who pays
Section 20 provides that a provider under the duty cannot require the disabled person to pay any of the cost of the adjustment. The size of that cost can still affect whether the step is reasonable for the provider.