The two-week reasonable adjustment deadline: responding is the easy part
On 21 May 2026, the Work and Pensions Committee published its Disability at Work report and recommended something employers have never faced before: a two-week legal deadline to respond to a reasonable adjustment request, with written reasons required for any refusal. There is no fixed deadline in the Equality Act 2010 today. If this lands, there will be.
The reaction in HR circles has mostly been about the clock. Two weeks is tight. Can we hit it? That is the wrong thing to worry about. Responding inside fourteen days is the easy part. The hard part is everything the response is supposed to contain.
Respond is not the same as resolve
A deadline to respond does not mean a deadline to fix. The committee was careful about that distinction, and so should employers be. You can acknowledge a request in two minutes. What the recommendation actually asks for is a real answer: whether you accept the person is disabled, whether you accept they are at a substantial disadvantage, and if you are declining, why. In writing.
That is not an email. It is a documented decision. And the moment a decision is documented, it can be examined. A rushed yes with no record is almost as exposed as a slow no. The two-week window does not reduce the legal risk in the adjustments process. It concentrates it into a fortnight and asks you to put your reasoning on paper.
The data the committee was responding to
The recommendation did not appear from nowhere. The evidence to the inquiry was stark. Most reasonable adjustment requests took more than four months to be implemented, and some took a year. The disability employment rate sits at around 52.8 percent against 82.5 percent for non-disabled people, a gap of nearly thirty percentage points. The committee concluded that, despite a legal duty that has existed since 2010, the workplace is still a hostile environment for too many disabled people.
In other words, the duty has been theoretical. A response deadline is an attempt to make it operational. That is the real shift, and it is bigger than the number of days.
It is a recommendation, not law. That matters, but not the way you think.
Nothing here is binding yet. The Employment Rights Act 2025 has already received Royal Assent, so any new duty would arrive through secondary legislation, a future bill, an amendment, or an ACAS code of practice. The exact window is not settled either: the House of Lords proposed four weeks, the government has commissioned research from the University of York, and the committee benchmarked its two weeks against flexible working rules.
So you could wait. You could treat this as noise until it becomes statute. The problem with that approach is the direction of travel. Every signal points the same way: toward a defined window, written reasons, and a duty to inform employees of their rights. The employers who scramble will be the ones who waited for the final wording. The ones who are ready will simply set a number.
What to actually do now
Treat the recommendation as a forcing function, not a compliance task for later. Three things are worth getting in place regardless of when the law lands:
A defined response window you can actually measure. Not a vague intention to act promptly, but a logged date on every request and a clock you can see. If you cannot tell me today how long your last ten requests took to answer, you are not ready for a two-week rule.
A structured way to record a refusal. The written-reasons requirement is the part most organisations are least prepared for. A decline needs to capture the statutory elements every time, in plain English, in a form that survives scrutiny. Free text in an inbox does not.
A separation between responding and implementing. Track them apart. You want to be able to prove you answered within the window even while the adjustment itself is still being arranged. Collapsing the two is how good-faith employers end up looking non-compliant.
None of this requires the law to pass first. It is simply what a defensible adjustments process looks like, and the two-week recommendation has done employers a favour by describing it out loud.
The deadline is the prompt, not the point
A countdown is easy to build and easy to hit. What protects an organisation is the record around it: who asked, when, what was decided, and why. Get that right and a two-week rule is a formality. Get it wrong and no amount of speed will save you.
The duty stopped being theoretical the moment Parliament put a clock on it. The question now is whether your process can answer the clock with more than an acknowledgement.
TryMosaic is the system of record for workplace reasonable adjustments under the Equality Act 2010. It logs every request, runs a configurable response window, captures structured written refusals, and keeps an audit-ready trail. trymosaic.co
