Access Statements for Small Congregations

A congregation of volunteers can write an access statement for its own building without an architect or a consultant. The duty under the Equality Act 2010 is anticipatory: a church must think about disabled people in advance, not wait for a complaint or a request. Measuring the building, writing down what it has and what it lacks, and publishing that record is the work itself. A congregation that wants a model for how a small organisation documents and shares its practical resources can look at how other parish networks handle the same task, including the resource-sharing practice described by the parish resource shelf magazine, which covers cataloguing, lending and the circulation of practical material among small congregations.

What is the anticipatory duty under the Equality Act?

The anticipatory duty sits in section 20 of the Equality Act 2010, which sets out the reasonable adjustments a service provider must make for disabled people. The Equality and Human Rights Commission's statutory code of practice on services makes the point plainly: the duty is owed to disabled people generally, not only to those who have already asked for something. A congregation cannot wait until a wheelchair user arrives on a Sunday morning to decide whether the step at the porch is a barrier.

Section 19 of the Act frames this as indirect discrimination: a provision, criterion or practice that puts disabled people at a particular disadvantage is unlawful unless it can be objectively justified. A 150 mm step at the only entrance is such a practice. So is a 760 mm door leaf where 900 mm is the figure in Approved Document M and BS 8300-1:2018. The duty is to anticipate the barrier and remove it, or to provide a reasonable alternative, before the person is turned away.

For a congregation, this means three things. First, the building must be assessed against published figures, not against impressions. Second, the assessment must be written down and kept current. Third, the information must be available to anyone who asks, including on a website. That written record is the access statement.

What goes into an access statement?

An access statement is a short factual document, usually one to three pages, that describes the building as it is. It is not a promise of perfection and it is not a marketing document. It answers the questions a disabled visitor would otherwise have to telephone and ask.

The core entries are measurements and descriptions, each tied to a published figure:

• Approach and parking: the distance from the nearest set-down point to the entrance, in metres, and whether the route is level or has a gradient. A dropped kerb that is not flush with the carriageway is a barrier and should be recorded as one.
• Entrance: the number of steps, the height of each riser in millimetres, and whether a ramp exists. A ramp at 1 in 12 is the figure in Approved Document M for a short rise; anything steeper should be recorded with its actual gradient.
• Doors: the clear opening width of the main door leaf in millimetres. The 900 mm figure in BS 8300-1:2018 is the benchmark for a principal entrance. Door closers, thresholds and the 15 mm lip at the base of a door are all worth noting.
• Internal circulation: the width of the main aisle in millimetres, the turning space available at the front of the worship area, and whether the floor is level or raked.
• WC provision: whether an accessible WC exists, its door width, and whether a Changing Places facility is available. Changing Places guidance sets out the 3 m by 4 m space, the 700 mm clearance beside the pan and the ceiling track hoist that such a facility requires. Most small churches do not have one, and saying so is part of an honest statement.
• Hearing and sight: whether an induction loop is fitted, whether the sound system has a hearing aid setting, and where the loop coverage ends.
• Worship and participation: whether a wheelchair user can sit with the rest of the congregation rather than in a side aisle, and whether the communion rail or the altar area is reachable.

The statement should also name a contact person and give a way to reach them. It should carry a date. It should be reviewed when anything changes, and the review date should be visible.

The principle is the same: write down what you have, keep it where people can find it, and update it.

Who pays for work to a listed place of worship?

The cost of physical work falls on the congregation or the body that owns the building, not on the person who needs access. There is no central fund that automatically meets the bill. A listed place of worship usually needs a faculty or a similar consent from the diocesan or denominational authority before work can start, and that process adds time rather than money.

Grants exist, and they are the usual route for a small congregation. The National Churches Trust, the Heritage Lottery Fund and various denominational trusts offer grants for access improvements, and the application is normally made by the congregation or the parochial church council. The Equality Act duty itself is not suspended by listed status: a listed building still has to be made accessible so far as is reasonable, and the fact of listing affects what is reasonable, not whether the duty applies.

A practical sequence for a volunteer committee is to measure first, write the statement second, and cost the works third. The measurements give the grant application its evidence. A statement that records a 150 mm step, a 760 mm door and no accessible WC is a stronger application than a general claim that the building is old.

How does a congregation measure and record its building?

The tools are a tape measure, a spirit level, a notebook and two people. One measures, one writes. The figures that matter are the ones already listed above, and each one should be recorded in millimetres or metres with the source that gives the benchmark.

A single walk-through in the order a visitor would take it is enough for a first draft: car park, path, gate, porch, door, aisle, seating, platform, WC, exit. At each point, note the measurement and note the barrier. A threshold with a 15 mm lip is a barrier for some wheelchairs and a trip hazard for some walkers. A door leaf of 760 mm is narrower than the 900 mm figure in BS 8300-1:2018. A ramp at 1 in 8 is steeper than the 1 in 12 in Approved Document M. None of these observations requires a qualification.

Why publish the statement before anyone asks?

Publishing the statement is what makes the duty anticipatory in practice. A visitor who can read the measurements before travelling knows whether the building will work for them. A congregation that has published its figures has a baseline for improvement and a record of what it has already done. The statement also protects the congregation from the assumption that nothing has been considered.

The statement does not have to be long, and it does not have to be perfect. It has to be accurate, dated and easy to find. A page on the church website, a printed copy in the porch and a copy held by the person who answers the telephone are enough.

What should be reviewed, and when?

Review the statement when the building changes, when a new minister or churchwarden takes office, and at least once a year. Check the measurements that were recorded, confirm the contact details, and add any work that has been completed. A statement that still describes a ramp that was removed, or a WC that was refurbished, is worse than no statement at all.

The review is also the moment to decide the next piece of work. A congregation that has recorded a 150 mm step and a 760 mm door has a clear first project. The access statement is not the end of the process; it is the record that makes the next step possible.