Accessible Self Storage in the UK: The Equality Act and Building Regulations
As at 18 October 2026 the Equality Act 2010 puts a duty to make reasonable adjustments on a service-provider in Great Britain, owed to disabled people generally, and the Code says it is anticipatory. On 18 October 2026 we found no passage that names self storage in the regulator pages and building guidance we searched, and the building access rules differ in England, Wales, Scotland and Northern Ireland. This is general information, not legal advice.
By Phil McParlane, Founder
Published 18 October 202623 min read
- As at 18 October 2026 the Code says the duty to make reasonable adjustments that the Equality Act 2010 puts on a service-provider in Great Britain is anticipatory and applies “regardless of whether” a provider knows a particular person is disabled; Northern Ireland has the Disability Discrimination Act 1995.
- On 18 October 2026 we found no source that says whether granting a licence to occupy a storage unit falls under Part 3 (services) or Part 4 (premises) of the Act. The Code says the Part 3 duty is anticipatory, while Schedule 4 paragraphs 2 and 3 apply their duties only on a request.
- The Building Regulations 2010 are law, and Approved Document M, the Scottish Technical Handbook and Technical Booklet R are guidance; on 18 October 2026 we found no passage that names self storage in the parts of them we searched.
- The Family Resources Survey 2024 to 2025 classed one in four people in the United Kingdom as disabled, from 12% of children to 45% of State Pension age adults, on its own definition; this guide prints no count of disabled storage customers.
- Section 118(1), subject to section 140AA, says a claim within section 114 may not be brought after six months from the act complained of, or such other period as the county court or sheriff thinks just and equitable.

On this page
As at 18 October 2026 the Equality Act 2010 puts a duty to make reasonable adjustments on a service-provider in Great Britain. On 18 October 2026 we found no passage that names self storage in the statutory 2026 Code of Practice, six other regulator and government pages or the building guidance we searched. Accessible self storage here means access for disabled customers and visitors to a storage business and its premises, not a unit’s opening hours or a site’s location.
This guide is general information, not legal advice. It reads the law of Great Britain (England, Wales and Scotland), the law of Northern Ireland and the building access rules and guidance of all four nations, for customers and visitors; staff and employment are a separate Part of the Act and are not covered. This guide does not decide whether a licence to occupy a storage unit falls under Part 3 (services) or Part 4 (premises).
Does the Equality Act apply to a self storage operator?
The Equality Act 2010 puts its Part 3 duties on “a service-provider”, and on 18 October 2026 we found no source that says whether granting a licence to occupy a storage unit is a service under Part 3 or a disposal of premises under Part 4.
Section 29(1) describes a service-provider as a person concerned with the provision of a service to the public or a section of the public, for payment or not. Section 31(2) says providing a service includes providing goods or facilities. The Equality and Human Rights Commission’s 2026 Code of Practice on services, public functions and associations (the Code) says it “does not impose legal obligations”.
The Code’s chapter 1, under “Large and small service providers”, says “no service provider is exempt from duties under Part 3 because of size”. Its chapter 11, under “What a service is”, says the services covered include “giving access to and use of any place which members of the public are permitted to enter”, and that its list of examples “does not cover all the services covered by the Act”.
Section 28(2) says Part 3 does not apply to discrimination, harassment or victimisation that is prohibited by Part 4 (premises), Part 5 (work) or Part 6 (education). In Part 4, section 33(1) covers a person with the right to dispose of premises, section 35(1) a person who manages premises, and section 38(4) says disposing of premises includes granting “a right to occupy” them. The Code says “This Code does not deal with Part 4 of the Act”.
Section 36(7) says that the duty on a controller of premises in section 36(1)(a) and (b), which Schedule 4 paragraphs 2 and 3 set out, extends to premises “subject to a right to occupy”.
Schedule 2 paragraph 2 applies all three requirements to a service-provider, while Schedule 4 paragraphs 2 and 3 apply the first requirement (a provision, criterion or practice) and the third (an auxiliary aid) only, and only if the controller receives a request (paragraphs 2(6) and 3(5)). Paragraph 2(8) says it is never reasonable for the controller to have to take a step that would involve removing or altering a physical feature.
On 18 October 2026 legislation.gov.uk marked the duty on common parts in Schedule 4 paragraph 5 “Prospective”.
Section 217 says the Act forms part of the law of England and Wales and, apart from section 190 and Part 15, of Scotland, and the Code says Parts 3 and 7 do not apply in Northern Ireland.
Northern Ireland has the Disability Discrimination Act 1995, and on 18 October 2026 legislation.gov.uk’s note on its section 19 said the section “now extends to N.I. only”.
On 18 October 2026 we found no “self storage”, “storage unit”, “lock-up”, “storehouse” or “warehouse” in the 38 legislation pages we searched; as a control, “reasonable” occurs 7 times in section 20.
They were pages of the Equality Act 2010 (sections 6, 20, 21, 28, 29, 31 to 36, 38, 114, 118, 119, 140AA, 140B, 149, 212 and 217 and Schedules 1, 2 and 4), the Equality Act 2010 (Disability) Regulations 2010, the Disability Discrimination Act 1995, the 2018 public sector website regulations and three statutory instruments of 2022 and 2026.
On 18 October 2026 we found no “licence to occupy” or “licensee” in the 35 pages we searched (sections 20, 21, 28, 29, 31 to 36, 38 and 212 and Schedules 2 and 4 of the Act, the 15 pages of the Code and six other regulator pages). As a control, “licence” and its forms occurred 17 times, all in other senses, such as vehicle licensing and driving licences.
What is the duty to make reasonable adjustments, and what counts as reasonable?
The duty to make reasonable adjustments in section 20 of the Equality Act 2010 has three requirements, on a provision, criterion or practice, on a physical feature and on an auxiliary aid, and each asks for “such steps as it is reasonable to have to take”. Schedule 2 paragraph 2 says the duty is owed to “disabled persons generally”.
In chapter 7, under “An anticipatory duty”, the Code says providers “must proactively consider the barriers that disabled people could face”. It adds that the duty applies “regardless of whether” a provider knows a particular person is disabled or has disabled customers, and that providers “are not expected to anticipate the needs of every individual”.
The Code’s list of physical features, which it says “is not an exhaustive list”, includes steps and stairways, kerbs and paving, parking areas, building entrances and exits, doors and gates, toilet and washing facilities, counters, lighting, lifts and signs. It says the duty applies to features “within the boundaries of the premises”, “even if the physical features are outdoors”.
On what counts as reasonable, the Code says “The Act does not specify that any particular factors should be considered”, that the provider’s “size and resources” are among the circumstances, and that the question “is an objective one for the courts to determine”.
In chapter 7 the Code lists “extra staff assistance to disabled people” among auxiliary aids and says “A failure to ensure the auxiliary aid is in operation may itself constitute a failure to make an adjustment”. Under “Providing a reasonable alternative method of access”, it says arranging an in-person service for a disabled person virtually “will only be a reasonable alternative” if there is “no reasonable way of providing the disabled person physical access to the service”.
Our guide to automated self storage covers the fire safety, health and safety, data protection and planning duties that still apply to a site with nobody on it.
Regulation 9(2) of the Equality Act 2010 (Disability) Regulations 2010 says it is not reasonable for a provider of services to have to remove or alter a physical feature that was provided in or in connection with a building to assist access and that satisfies the relevant design standard.
Paragraph 1(3) of its Schedule says a feature does not satisfy it where “more than 10 years have elapsed since” the day its construction or installation was completed or, for a feature provided as part of a larger building project, the day the project’s works were completed.
For a building in England or Wales, paragraph 2(1)(a) names the 1992, 1999 and 2004 editions of Approved Document M, and the Approved Document for England, which is guidance, says the exemption “is not a blanket exemption from duties under the EA”. For a building in Scotland, paragraph 1(2) names the Technical Standards and the Technical Handbook instead.
The Approved Document for England describes the Schedule as tying the standard to “the edition of Approved Document M that applied at the time the building works were carried out”, without naming the 2015 edition.
On 18 October 2026 we found no source that says whether a feature built to the 2015 edition can satisfy the relevant design standard, so this guide states no effect for it.
Service provider A person concerned with the provision of a service to the public or a section of the public owes the duty (section 29(1) and (7)).
Details
It is owed to “disabled persons generally” (Schedule 2 paragraph 2), and providers “are not expected to anticipate the needs of every individual” (Code, chapter 7).Before anyone asks The Code says the duty is anticipatory and providers “must proactively consider the barriers that disabled people could face”.
Details
It applies “regardless of whether” the provider knows it has disabled customers (chapter 7).The trigger A provision, criterion or practice, a physical feature or the lack of an auxiliary aid puts a disabled person at a substantial disadvantage.
Details
“Substantial” means more than minor or trivial (sections 20 and 212).The step The Act asks for “such steps as it is reasonable to have to take” to avoid the disadvantage or provide the aid.
Details
For a physical feature that includes removing it, altering it or providing a reasonable means of avoiding it, and for services a reasonable alternative method (section 20(9) and Schedule 2).What is reasonable The Code says “The Act does not specify that any particular factors should be considered”.
Details
Its non-exhaustive factors include effectiveness, practicability, cost, disruption, the provider’s resources and available assistance.The limits Nothing in the paragraph requires a step that would “fundamentally alter” the nature of the service or the provider’s trade or profession (Schedule 2 paragraph 2(7)).
Details
Where, “having considered the issue thoroughly”, there are “genuinely no reasonable steps”, a situation “likely to be rare”, the Code says the provider “is unlikely to be in breach of the law if it makes no changes”.Who pays The provider is not entitled to require a disabled person to pay any of the costs of complying (section 20(7)).
Details
That is subject to express provision to the contrary. The Code adds that cost “may affect the extent to which that step is a reasonable one”.Consents and the 10 year rule The Code says the Act “does not override the need to obtain such consents”, among them planning permission and building regulations approval.
Details
Regulation 9 says it is not reasonable to have to remove or alter a feature that satisfies the relevant design standard, but a feature does not satisfy it more than 10 years after completion.If challenged Once a claimant shows a substantial disadvantage and identifies potential adjustments “the burden shifts to the service provider” (Code, chapter 7).
Details
Proceedings may not be brought after six months from the act, or such other period as the court thinks just and equitable (section 118(1)).
Equality Act 2010 sections 20, 29, 118 and 212 and Schedule 2 (legislation.gov.uk); Equality Act 2010 (Disability) Regulations 2010 regulation 9 and its Schedule; Equality and Human Rights Commission, Code of Practice on Services, Public Functions and Associations (2026), chapters 7 and 14. Read 18 October 2026.
Does the duty reach a website and online booking?
The Code says some goods and services are provided “remotely through mediums like websites or apps”, and its chapter 5 example of a legal services provider’s website with “all its text embedded within graphics” gives rise to “an obligation to make a reasonable adjustment to their website”.
On 18 October 2026 we found no UK statute or statutory instrument on legislation.gov.uk that mentions WCAG, the Web Content Accessibility Guidelines or the standard EN 301 549 other than the public sector website accessibility instruments.
On 18 October 2026 a text search of legislation.gov.uk for WCAG returned one result, S.I. 2022/1097, “Web Content Accessibility Guidelines” returned 2 and “EN 301 549” returned 4, all about public sector bodies’ websites and mobile applications. The control phrase “perceivable, operable, understandable and robust” returned 7 results.
GOV.UK’s page for public sector bodies, last updated 30 September 2024, says the accessibility regulations “build on your existing obligations” and that “All UK service providers have a legal obligation to make reasonable adjustments under the Equality Act 2010 or the Disability Discrimination Act 1995 (in Northern Ireland)”. The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 apply to “a website or mobile application of a public sector body”.
GOV.UK’s page says a public sector body’s website or app “will meet the legal requirements” if it meets the Web Content Accessibility Guidelines (WCAG) 2.2 AA standard and publishes an accessibility statement. In Northern Ireland the Equality Commission’s page on disability discrimination says its protections “apply whether you buy products or services online or in person”.
We did not check the European Accessibility Act. Our guide to self storage website design covers how a storage website turns a search into a booking.
What do the building regulations ask about access in a new, extended or converted storage building in England?
The Building Regulations 2010, which are law, and Approved Document M volume 2, which is guidance, tie the access requirement to the kind of work and the kind of building, and on 18 October 2026 we found no source that says whether a self storage building is a “shop” or a “public building” in their sense.
The guidance prints requirement M1 as “Reasonable provision must be made for people to” gain access to and use the building and its facilities. The guidance says there is “no obligation to adopt any particular solution contained in an Approved Document”, and that Parts E and M are outside regulation 8 “because they address the welfare and convenience of building users”.
Paragraph 0.1 of the guidance says requirements M1, M2 and M3 apply if a non-domestic building is newly erected, an existing non-domestic building is extended or undergoes a material alteration, or an existing building or part of one undergoes a material change of use to a hotel or boarding house, institution, public building or shop.
Regulation 6(1)(i) adds M1 for a material change of use of the whole of a building to those four kinds, and in the version of regulation 6 marked for England M1 is not among the requirements that apply “in all cases”.
Regulation 2 says “shop” includes premises used by members of the public “for the hiring of any item”, and its definition of “public building” adds that a building is not treated as a place of public resort because it is, or contains, “a shop, storehouse or warehouse”.
On 18 October 2026 we found no “self storage”, “storage unit” or “lock-up” in the 8 pages of the Building Regulations 2010 we read (regulations 2, 3, 4, 5, 6 and 8 and Schedules 1 and 2), where “public building” occurs once in regulation 2.
For a material alteration, paragraph 0.9 of the guidance says “it is not necessary, as regards the Building Regulations, to upgrade access to the building entrance from the site boundary and from on-site car parking where provided”, and draws attention to the Equality Act.
The Approved Document says following its guidance “does not necessarily equate to compliance with the obligations and duties set out in the EA”, and that “regardless of compliance with Building Regulations, there will be obligations under the Equality Act 2010”.
On 18 October 2026 we found no passage that names self storage, a storage unit, a lock-up, a storehouse or a warehouse in the guidance of Approved Document M volume 2 for England (2015 edition, with the 2020 and 2024 amendments) or of its May 2024 amendment booklet. As controls, the guidance’s wider storage words match 11 times, in other senses, and “Requirements M1, M2 and M3 apply if” occurs once.
The guidance in volume 2 is the 2015 edition, in effect from 1 October 2015, with a July 2020 and a May 2024 amendments document, and GOV.UK’s page for it was last updated on 1 October 2024. On 18 October 2026 we found no edition, amendment or update dated after 1 October 2024 on that page or on its “updates” view, where “Last updated: 1 October 2024” occurs once.
Our guide to converting a building into self storage covers regulation 5, the “shop” question and fire, while this guide covers access.
What do Wales, Scotland and Northern Ireland ask of a storage building?
Wales, Scotland and Northern Ireland each publish their own guidance on access to buildings, and on 18 October 2026 we found no passage that names self storage in any of it that we searched.
Wales: the Building Regulations 2010, which are law, apply in England and Wales, and the Welsh Government’s Approved Document M, which is guidance, is the “2004 edition incorporating the 2010 amendments”, with an amendment slip in effect from 3 January 2023 and a page last updated on 20 March 2025.
On 18 October 2026 we found no passage that names self storage, a storage unit, a lock-up, a storehouse or a warehouse in that guidance or its slip, where “The requirements apply if” occurs once. We found no “Equality Act” in them or on the two gov.wales pages on 18 October 2026, while the guidance names the Disability Discrimination Act 1995 eight times.
Scotland: Schedule 5 to the Building (Scotland) Regulations 2004 includes standard 4.1 on access to buildings, 4.2 on access within them and 4.7 on aids to communication, and regulations 4 and 12 with Schedules 2 and 6 deal with conversions.
As legislation.gov.uk prints Schedule 2, the conversions include a change “to allow access by the public where previously there was none”, item 8 of nine, while the guidance in the Technical Handbook’s Table 0.2 lists ten types and numbers it 9, and we did not decide which numbering is in force.
The Handbook (non-domestic, April 2026, published 9 March 2026), which is guidance, applies to a building warrant submitted on or after 6 April 2026, and says “The regulations are mandatory, but the choice of how to comply lies with the building owner”.
On 18 October 2026 we found no passage that names self storage, a storage unit or a lock-up in the guidance text from the heading “4.1 Access to buildings” to the heading “4.8 Danger from accidents”, where “accessible route” occurs 21 times. Elsewhere the guidance uses “storage building” 23 times in lower case and defines “Storage building (Class 1)” and “Storage building (Class 2)”.
Clause 0.4.1 of the guidance gives “development of a retail trade in a storage building” as an example of public access, and on 18 October 2026 we found no passage that says whether a self storage business is a conversion.
Northern Ireland: regulation 8 of the Building Regulations (Northern Ireland) 2012 lists, as Case VIII, a material change of use where “the building is used as a store”.
On 18 October 2026 we found no “self storage”, “storage unit” or “lock-up” in the 8 pages of those Regulations we read (the contents page and regulations 2, 5, 7, 8, 90, 91 and 92), and no definition of “store” in regulation 2, which defines “shop”.
The Table to regulation 8, which applies on a material change of use and was substituted from 6 May 2025, shows Part R (access to and use of buildings) applying in Cases III, IV, V, VI and XII and not in Case VII (office) or Case VIII (store).
Regulation 90 applies Part R to “any building or part of a building”, subject to exceptions, regulation 91 asks for “Reasonable provision” of access, and regulation 5 applies Part R, among other Parts, to the erection of a building.
Regulation 7(1) applies Part R, among other Parts, to a structural alteration or extension of an existing building, subject to exceptions. Regulation 8(4) says that where a material change of use involves or is accompanied by an alteration or extension, regulation 7 applies “any requirements of that regulation which are additional to those directly applied by the Table”.
Technical Booklet R, which is guidance and takes effect on 31 October 2012, says following it gives “a presumption of compliance” that “can be overturned”, and the Department of Finance says to read it with Amendments Booklets AMD 8 (30 June 2022) and AMD 9 (6 May 2025).
On 18 October 2026 we found no passage that names self storage, a storage unit, a lock-up, a storehouse or a warehouse in the guidance of Technical Booklet R, where “Part R” occurs 22 times, and no “Disability Discrimination” or “Equality Act” in it, where “Workplace” occurs 7 times.
Our guides to starting a self storage business in Scotland, Wales and Northern Ireland cover each nation’s planning, rates and tax. Our guide to business licences and registrations says it did not check building control in Wales or Northern Ireland, while this guide reads their access rules only.
| Nation | Law on services | Building access rule | Guidance document |
|---|---|---|---|
| England | Law on servicesEquality Act 2010, Part 3 | Building access ruleBuilding Regulations 2010, Part M | Guidance documentApproved Document M volume 2, 2015 edition |
| Wales | Law on servicesEquality Act 2010, Part 3 | Building access ruleBuilding Regulations 2010, Part M | Guidance documentApproved Document M (Wales), 2004 edition |
| Scotland | Law on servicesEquality Act 2010, Part 3 | Building access ruleBuilding (Scotland) Regulations 2004, Standards 4.1, 4.2 and 4.7 | Guidance documentTechnical Handbook, non-domestic, April 2026 |
| Northern Ireland | Law on servicesDisability Discrimination Act 1995, sections 19 to 21 | Building access ruleBuilding Regulations (Northern Ireland) 2012, Part R | Guidance documentTechnical Booklet R, October 2012 |
Equality Act 2010 sections 29 and 217; Disability Discrimination Act 1995 sections 19 to 21; Building Regulations 2010 Schedule 1; Building (Scotland) Regulations 2004 Schedule 5; Building Regulations (Northern Ireland) 2012 regulations 90 to 92; the four guidance documents named. Read 18 October 2026.
What numbers do the guidance documents print for a route, parking, an entrance, a door and a lift?
The four guidance documents print numbers for an approach route, parking, an entrance, a door, a lift and a reception counter; they are guidance, not law, and each says a requirement may be met in other ways. This guide makes no statement that a storage site needs any of them.
England and Wales print the same values in their own guidance, the 2015 and the 2004 editions, so the table below gives them one column; Scotland and Northern Ireland print their own. Each guidance document ties its requirements to the kinds of work and building it names, and on 18 October 2026 we found no passage that names self storage in the parts of the four that we searched.
On 18 October 2026 we found no car parking bay size, count or ratio in the guidance of Technical Booklet R (Northern Ireland, October 2012): “bay” occurs 0 times and “setting down” 0 times, and “parking” occurs 7 times, in sentences about the approach to a building or its entrance (our reading of the contexts). As a control, “passenger lift” occurs 18 times in that guidance.
Scotland’s guidance in clause 4.1.1 gives a ratio and bay sizes. The England and Wales bay labels (2400mm, 4800mm, 1200mm, 1200mm and 1400mm) were read from the drawing, Diagram 2, and both guidance documents point to BS 8300, which we did not read, for bays by building type.
Our guide to self storage site selection covers how far customers travel to a site and the public data around it. Our guide to the cost to build self storage covers what drives the cost of a build, lifts among them.
| Item | England and Wales | Scotland | Northern Ireland |
|---|---|---|---|
| Approach route, width | England and WalesAt least 1.5m, with passing places (1.13) | ScotlandMinimum 1.8 m from accessible parking or setting-down point; 1.2 m or more elsewhere (4.1.6) | Northern IrelandAt least 1500 mm; 1000 mm at a local obstruction for not more than 6 m |
| Approach route, gradient | England and WalesNo steeper than 1:60, or less steep than 1:20 with level landings for each 500mm rise | ScotlandLevel to 1 in 50; gently sloping to 1 in 20; ramped to 1 in 12 | Northern IrelandRest areas where steeper than 1 in 60 (2.8) |
| Approach route, cross-fall | England and WalesNo steeper than 1:40 (1.13) | ScotlandNot more than 1 in 40 (4.1.3) | Northern IrelandNot steeper than 1 in 40 (2.8) |
| Car parking | England and WalesAt least one bay designated for disabled people; 1200mm zones; Diagram 2 labels 2400mm and 4800mm | ScotlandMinimum 1 per 20 spaces or part; 4.8 by 2.4 m (6.6 by 3.6 m parallel) | Northern IrelandOn 18 October 2026 we found no bay size, count or ratio |
| Entrance, landing and threshold | England and WalesLevel landing at least 1500 x 1500mm; threshold level or, if raised, 15mm at most (2.7) | ScotlandPlatt at least 1.5 m by 1.5 m; upstand projection not more than 15 mm | Northern IrelandAccess area at least 1500 mm by 1500 mm; upstands’ cumulative height 15 mm at most |
| Door, clear width | England and WalesStraight-on 800mm new, 750mm existing; external doors for the general public 1000mm new, 775mm existing | ScotlandDoor leaf clear opening at least 800 mm (4.1.7) | Northern IrelandStaff and visitors 800 mm new, 750 mm existing; public 1000 mm new, 775 mm existing |
| Passenger lift | England and WalesCar at least 1100mm wide and 1400mm deep; doors at least 800mm clear (3.34) | ScotlandCar at least 1.1 m wide by 1.4 m deep; doors at least 800 mm clear | Northern IrelandCar at least 1100 mm wide and 1400 mm deep; doors at least 800 mm clear |
| Reception counter | England and WalesAt least one section at least 1500mm wide, surface no higher than 760mm (3.6) | ScotlandStanding users 950 mm to 1.1 m high; seated users about 750 mm | Northern IrelandAt least one section: surface no higher than 760 mm for at least 1500 mm (5.4) |
Approved Document M volume 2 (England, 2015 edition with the 2020 and 2024 amendments, printed pages as cited); Approved Document M (Wales, 2004 edition with the 2010 amendments); Technical Handbook, non-domestic, April 2026 (Scotland); Technical Booklet R, October 2012 (Northern Ireland). Paragraphs, clauses and tables: England and Wales 1.13, 1.18, 2.7, Table 2, 3.34 and 3.6; Scotland 4.1.1, 4.1.3, 4.1.6, 4.1.7, 4.1.9, 4.2.7 and 4.2.10; Northern Ireland 2.8, 3.4, 3.10, Table 3.1, 4.35, 4.36 and 5.4. Read 18 October 2026.
How many people are disabled, and how does that change with age?
The Family Resources Survey 2024 to 2025, published on 26 March 2026, classed one in four people in the United Kingdom as disabled, from 12% of children to 45% of State Pension age adults, on the survey’s own definition, and this guide prints no count of disabled storage customers.
The survey’s definition is “a long-standing illness, disability or impairment which causes substantial difficulty with day-to-day activities”, which the DWP says is “consistent with the core definition of disability under the Equality Act 2010”, while some people with rights under the Act “are not captured by this definition”. The DWP notes that none of the survey’s disability estimates are age-standardised.
Table 4.1 gives 25% of all people, 12% of children, 23% of working-age adults and 45% of State Pension age adults as disabled, from samples of 34,966 people, 7,252 children, 18,979 working-age adults and 8,735 State Pension age adults, and State Pension age was 66 during the year.
In a three-year average of 2022 to 2023, 2023 to 2024 and 2024 to 2025, 5% of 0 to 4 year olds, 36% of 65 to 69 year olds and 58% of people aged 80 and over were disabled on the survey’s definition, against 24% of all ages. In 2024 to 2025, mobility was reported by 46% of disabled people and 68% of disabled State Pension age adults, and the base is disabled people, not all people.
The DWP says the survey does not record people in nursing or retirement homes, so “it is likely that disability prevalence for older people is higher than estimated”.
Department for Work and Pensions, Family Resources Survey 2024 to 2025, report and Table 4.1 (published 26 March 2026). Read 18 October 2026.
The Census 2021 used another wording: the ONS says people “who assessed their day-to-day activities as limited by long-term physical or mental health conditions or illnesses are considered disabled”, a definition it says “is in line with the Equality Act (2010)”. For England and Wales on Census Day, 21 March 2021, the age-standardised proportion was 17.8% (10.4 million). Scotland’s census was moved to 20 March 2022.
| Source | Who counts as disabled | Area and date |
|---|---|---|
| Equality Act 2010, section 6 | Who counts as disabledA physical or mental impairment with a substantial and long-term adverse effect on day-to-day activities | Area and dateGreat Britain; legislation.gov.uk up to date to 18 October 2026 |
| Family Resources Survey 2024 to 2025 | Who counts as disabledA long-standing illness, disability or impairment which causes substantial difficulty with day-to-day activities | Area and dateUnited Kingdom; financial year 2024 to 2025; not age-standardised |
| Census 2021 | Who counts as disabledDay-to-day activities limited by long-term physical or mental health conditions or illnesses | Area and dateEngland and Wales; 21 March 2021; proportions age-standardised |
Equality Act 2010 section 6 and Schedule 1 (legislation.gov.uk); Department for Work and Pensions, Family Resources Survey 2024 to 2025; Office for National Statistics, Census 2021 disability bulletin (released 19 January 2023). Read 18 October 2026.
Section 6(1) of the Equality Act says a person has a disability if the person has a physical or mental impairment that has a substantial and long-term adverse effect on the person’s ability to carry out normal day-to-day activities. Schedule 1 paragraph 2(1) says the effect is long-term if it has lasted, or is likely to last, for at least 12 months or for the rest of the life of the person affected.
Our guide to who uses self storage reports the age of storage customers, which is a measure of age and not of disability.
What have regulators and courts said about storage?
We could not find, on 18 October 2026, any passage that names self storage in the Code or in six other regulator and government pages, or any judgment on Find Case Law or BAILII that contains both “self storage” and “Equality Act”; the searches and counts follow.
On 18 October 2026 we found no passage that names self storage, a storage unit, a lock-up, a storehouse or a warehouse in the 15 web pages of the Equality and Human Rights Commission’s Code of Practice, its 14 chapters and the appendix. Its wider storage words match 4 times, all about data stored by online intermediaries in chapters 11 and 13, and “reasonable adjustment” occurs 72 times in chapter 7.
On 18 October 2026 we found no storage word of any kind in six other regulator and government pages: the Code’s landing and next-steps pages, the Equality and Human Rights Commission’s guidance for businesses, two Equality Commission for Northern Ireland pages and GOV.UK’s page on public sector websites. As a control, “reasonable adjustments” occurs once in that guidance for businesses. That guidance, dated 19 February 2019, says equality law applies whatever the size of the business.
The Code became statutory on 5 August 2026. S.I. 2026/787 revoked the 2011 Code from that day, and S.I. 2026/788, made on 14 July 2026, brought the 2026 Code into force immediately after the 2011 Code was revoked. The Equality and Human Rights Commission says the Code “does not make new law or create any new legal obligations”, and its chapter 1 says courts and tribunals “must consider any part of the Code that appears relevant”.
On 18 October 2026 we found no judgment on Find Case Law that contains both “self storage” and “Equality Act” (0 results) and no document on BAILII that does (0 documents). Find Case Law says “We do not routinely receive judgments from the County, Crown or Magistrates courts” and “our archive of judgments and decisions is incomplete”, so the search says little about county court claims.
As controls, “self storage” alone returns 46 results on Find Case Law and 82 documents on BAILII, and “reasonable adjustments” with “service provider” returns 62 results and 352 documents. BAILII’s search for “self storage” with discrimination also returned employment tribunal decisions, one of which we could not read. A negative describes the pages searched on that date and nothing wider.
How long does a customer have to bring a claim?
Section 118(1) says proceedings on a claim within section 114 may not be brought after the end of “the period of 6 months starting with the date of the act to which the claim relates” or “such other period as the county court or sheriff thinks just and equitable”.
6 months
time limit for a claim, from the act complained of; a court may allow longer
Section 118(1) of the Equality Act 2010 (England, Wales and Scotland), subject to section 140AA. In Northern Ireland the Disability Discrimination Act 1995 sets six months, with three more months where paragraph 6(2) applies, and lets a court consider a claim out of time if it thinks it just and equitable.
Equality Act 2010 sections 118(1) and 140AA (legislation.gov.uk); Disability Discrimination Act 1995 Schedule 3 paragraph 6; Equality Commission for Northern Ireland, disability discrimination page (undated). Read 18 October 2026.
The Code’s chapter 14, under “Time limits”, says “Court action must be started within six months minus one day of the alleged unlawful act”, and attributes the court’s power to extend the limit where “just and equitable” to section 140AA there and to section 118 paragraph 1(b) under a later heading.
Section 140AA, in its wording in force from 6 April 2026, applies only to a “consumer contract dispute” as the Digital Markets, Competition and Consumers Act 2024 defines it. Where alternative dispute resolution starts before the limit expires, and the limit would otherwise expire before the resolution ends or less than eight weeks after, the limit expires instead eight weeks after the resolution ends. We did not read the court rules that fix how the period is counted.
In Northern Ireland, Schedule 3 paragraph 6 of the Disability Discrimination Act 1995 sets six months from the act complained of and lets a court consider a claim out of time if it considers it just and equitable, and section 25 limits proceedings to a county court.
As legislation.gov.uk prints it, paragraph 6(2) adds three months where the dispute is referred for conciliation in pursuance of arrangements under section 27 of the Equality Act 2006 before the six months end. This guide makes no statement about a claim in any other forum, or about the odds or value of a claim.
What this guide does not cover
- Employment. Staff and employment fall under Part 5 of the Act.
- Other Part 3 conduct. Direct and indirect discrimination, discrimination arising from disability, harassment and victimisation, whose sections of the Act we did not read.
- The public sector equality duty in section 149.
- Other building guidance. BS 8300, which is paywalled and which we did not read, Approved Document B on fire safety, Part T on toilet accommodation and the changing places provisions beyond the lines we read.
- Planning policy and the European Accessibility Act.
- Northern Ireland orders, regulations and codes made under the 1995 Act, which we did not look for.
- Other figures. The Census disability figures for Scotland and Northern Ireland, the cost of building work and any count of disabled storage customers, which we did not look for.
- Code paragraph numbers. This guide cites the Code by chapter and heading because its PDF could not be captured.
Questions to put to the regulator and an adviser
- An adviser or the Equality and Human Rights Commission: does a licence to occupy a storage unit fall under Part 3 (services) or Part 4 (premises) of the Equality Act 2010?
- A building control body: does it treat a self storage building as a “shop” for regulations 5 and 6 in England and Wales, as a change “to allow access by the public where previously there was none” in Scotland, or as Case VIII, “the building is used as a store”, in Northern Ireland?
- An adviser: how does the 10 year design standard rule treat a feature built to the 2015 edition of Approved Document M?
- The Equality and Human Rights Commission: what does the Code mean by staff assistance and a virtual alternative for a site with nobody on it?
- An adviser: how are the six month limit and the court’s “just and equitable” power counted?
- An adviser or a building control body: which parking provision does BS 8300 print for each type of building?
Sources
All read on 18 October 2026.
- Equality Act 2010, on legislation.gov.uk: section 6, section 20, section 28, section 29, section 33, section 35, section 38, section 114, section 118, section 140AA, section 212, section 217, Schedule 1, Schedule 2 and Schedule 4.
- Equality Act 2010 (Disability) Regulations 2010: regulation 9 and the Schedule.
- Disability Discrimination Act 1995: section 19, section 21, section 25 and Schedule 3.
- Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018: regulation 3 and regulation 4.
- legislation.gov.uk text searches read for the website question: WCAG, Web Content Accessibility Guidelines, EN 301 549 and perceivable, operable, understandable and robust.
- Orders of 2026 on the Code: S.I. 2026/788 and S.I. 2026/787.
- Building Regulations 2010: regulation 2, regulation 3, regulation 4, regulation 5, regulation 6, regulation 8, Schedule 1 and Schedule 2.
- Building (Scotland) Regulations 2004: regulation 4, regulation 9, regulation 12, Schedule 2, Schedule 5 and Schedule 6.
- Building Regulations (Northern Ireland) 2012: contents page, regulation 2, regulation 5, regulation 7, regulation 8, regulation 90, regulation 91 and regulation 92.
- Equality and Human Rights Commission, Code of Practice on services, public functions and associations: the landing page, next steps page, chapter 1, chapter 2, chapter 3, chapter 4, chapter 5, chapter 6, chapter 7, chapter 8, chapter 9, chapter 10, chapter 11, chapter 12, chapter 13, chapter 14 and appendix.
- Equality and Human Rights Commission: guidance for businesses.
- Equality Commission for Northern Ireland: disability discrimination and accessible goods and services.
- GOV.UK: accessibility requirements for public sector websites and apps and Approved Document M.
- Approved Document M volume 2 (England): the 2015 edition with the 2024 amendments and May 2024 amendment booklet.
- Welsh Government, Approved Document M (Wales): the page, 2004 edition, amendment slip page and amendment slip.
- Scottish Government, Technical Handbook, non-domestic, April 2026: the page and document.
- Department of Finance, Technical Booklet R: the booklet, publication page, AMD 8 and AMD 9.
- Department for Work and Pensions, Family Resources Survey 2024 to 2025: the report, background and methodology and Table 4.1 workbook.
- Office for National Statistics: the Census 2021 disability bulletin.
- Find Case Law searches: self storage and Equality Act, self storage and reasonable adjustments and service provider.
- BAILII searches: self storage and Equality Act, self storage and discrimination, self storage and reasonable adjustments and service provider.
FAQs
Is the Equality Act the same in Northern Ireland?
No. As at 18 October 2026 section 217 says the Equality Act 2010 forms part of the law of England and Wales and, apart from section 190 and Part 15, of Scotland, and the Code says Parts 3 and 7 do not apply in Northern Ireland. Northern Ireland has the Disability Discrimination Act 1995, and legislation.gov.uk’s note on its section 19 says the section “now extends to N.I. only”. Schedule 3 paragraph 6 of that Act sets six months for a claim, with three more months where paragraph 6(2) applies.
Does the size of a business change the duty to make reasonable adjustments?
The Code says “no service provider is exempt from duties under Part 3 because of size”, but a provider’s “size and resources” are among the circumstances in deciding what is reasonable. Its chapter 1, under “Large and small service providers”, says all service providers have the same legal duties but may put them into practice differently, and its chapter 7 says the question “is an objective one for the courts to determine”.
Can a customer be asked to pay for an adjustment?
As at 18 October 2026 section 20(7) of the Equality Act 2010 says that, subject to express provision to the contrary, the person subject to the duty is not entitled to require a disabled person to pay any of the costs of complying. The Code, under “Costs of providing reasonable adjustments”, says the cost of a particular adjustment “may affect the extent to which that step is a reasonable one”.
Is an Approved Document the law?
No. The Building Regulations 2010 are law and Approved Document M is guidance: the England guidance says there is “no obligation to adopt any particular solution contained in an Approved Document”. Scotland’s Technical Handbook, which is also guidance, says “The regulations are mandatory, but the choice of how to comply lies with the building owner”, and the guidance of Northern Ireland’s Technical Booklet R says following it gives “a presumption of compliance” that “can be overturned”.
What is the 10 year rule for physical features?
Regulation 9(2) of the Equality Act 2010 (Disability) Regulations 2010 says it is not reasonable for a provider of services to have to remove or alter a physical feature, provided to assist access, that satisfies the relevant design standard. Paragraph 1(3) of its Schedule says a feature does not satisfy it where “more than 10 years have elapsed since” its construction or installation (or, for a larger building project, the project’s works) was completed. On 18 October 2026 we found no source that names the 2015 edition of the Approved Document M guidance and says whether a feature built to it can satisfy the relevant design standard.
Which edition of Approved Document M is current in England?
GOV.UK’s page for the guidance in Approved Document M, last updated on 1 October 2024, lists the 2015 edition of volume 2, in effect from 1 October 2015 for use in England, with a July 2020 and a May 2024 amendments document. On 18 October 2026 we found no edition, amendment or update dated after 1 October 2024 on that page or on its “updates” view.
What does the law say about wheelchair access to a self storage site?
As at 18 October 2026 the Equality Act 2010 asks a service-provider in Great Britain to take “such steps as it is reasonable to have to take”, and the Code lists steps and stairways, parking areas, building entrances and exits, doors and gates, lifts and signs among physical features. On 18 October 2026 we found no passage that names self storage in the Code or the building guidance we searched, so this guide states no requirement for a ramp, a lift or a parking bay at a storage site.
Phil McParlane, Founder, StoreBay
Phil is the founder of StoreBay, the UK self-storage management platform. He writes about starting, running and growing storage businesses — the operational detail, not the fluff. About StoreBay
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