A woman phones a hotel in Bath to ask whether the accessible room has a level access shower or a bath with a seat. The receptionist puts her on hold, comes back, and says she thinks it is a wet room. It is a bath with a grab rail. The guest arrives at seven in the evening after a four hour drive, cannot use the bathroom, and is offered a £30 refund and an apology.
The hotel did not set out to do that. It had an accessible room, a ramp at the front and a lift. What it did not have was anybody who had ever written down what was actually in the room.
The duty is anticipatory, which is the whole point
Part 3 of the Equality Act 2010 applies to anyone providing a service to the public, which includes every hotel, inn, guest house and self-catering let in Great Britain. In Northern Ireland the equivalent provisions sit in the Disability Discrimination Act 1995 as amended.
The duty to make reasonable adjustments has three limbs. Where a provision, criterion or practice puts a disabled person at a substantial disadvantage, you take reasonable steps to avoid it. Where a physical feature does, you take reasonable steps to remove, alter or avoid it, or provide a reasonable means of avoiding it. And you provide auxiliary aids and services where those would avoid the disadvantage.
The part operators miss is in the timing. Under Part 3 the duty is anticipatory. You are required to think about disabled people in general, in advance, and do what is reasonable before any particular person turns up. You do not get to wait for a complaint and then fix it. By the time the guest in Bath is standing at your desk, the breach has already happened.
What is reasonable depends on your size, your resources and your building. A Grade II listed coaching inn with a spiral stair is not held to the same physical standard as a new build on a retail park, and listed building consent is a genuine constraint that a court will take into account. It is not a blanket excuse, and it says nothing at all about the things that cost you nothing: how you answer the phone, how you describe the room online, and how your staff behave.
One rule has no reasonableness test attached. You cannot charge a disabled person for a reasonable adjustment. Section 20(7) puts that beyond argument. Charging more for the accessible room because it is bigger, or adding a fee for a portable ramp, is unlawful.
What an accessible room actually needs
Building Regulations set the standard for new work rather than for existing buildings. In England, Approved Document M Volume 2 covers buildings other than dwellings, and for hotels and motels it expects at least one wheelchair accessible bedroom for every twenty bedrooms. Scotland works to its own Technical Handbooks and Northern Ireland to its own Technical Booklets. BS 8300-2:2018 is the design standard most consultants work to, and it is more detailed and more useful than the Approved Document.
If you are refurbishing, the material alteration triggers the current standard for the work you are doing, which is the moment to get this right rather than three years later.
The substance, stripped of the drawings, is a route and a room that a wheelchair user can actually use alone. Level or ramped approach from a parking space that is wide enough to get out of a car beside. A door with a clear opening width that a chair fits through, which is usually wider than the 726mm door you have. Enough clear floor space beside the bed to transfer, on the correct side or on either. A wet room or level access shower with a drop-down seat and grab rails positioned to a standard rather than to where the plumber found a stud. A WC with transfer space and rails. Controls, sockets and the emergency pull cord reachable from the floor, because the cord that is knotted up out of the way is the one that fails when somebody has fallen.
Then the parts that are not about wheelchairs at all, and which affect far more of your guests. Visual fire alarm and vibrating pillow alerts for deaf guests. Contrast between the floor, the walls and the sanitaryware for guests with low vision. Hearing loops at reception and in the function room. Assistance dogs accepted anywhere in the building, in a room without a surcharge, because refusing an assistance dog is straightforwardly unlawful discrimination and is also the fastest way to appear in a local newspaper.
Fire safety connects here too. Your fire risk assessment under the Regulatory Reform (Fire Safety) Order 2005 has to deal with evacuating people who cannot use stairs, which in practice means personal emergency evacuation plans and staff who know what the plan is. Putting the accessible room on the third floor with no plan is a fire safety failure as well as an accessibility one.
Describing it honestly is worth more than a refurbishment
Most of the complaints in this area are not about buildings. They are about descriptions.
An accessible room is not a category, it is a set of specific dimensions and fittings, and different guests need different things. Somebody who walks with sticks wants a bath with a rail and a room near the lift. A full-time wheelchair user wants a wet room, a transfer space and a door width. A guest with a hoist needs to know about bed height and clearance underneath. The word "accessible" on a booking page tells none of them anything.
The fix is an access statement that describes the building as it is, including what is wrong with it. Number of steps at the entrance and their height. Door widths in millimetres. Whether the shower is level access or over a bath. Which side of the bed the transfer space is on. Where the parking is and how far it is from the door. Whether the lift is big enough for a chair and a companion. Photographs of the actual bathroom, taken straight on, not styled.
That level of honesty converts. It is the difference between a guest booking with confidence and a guest phoning four hotels and picking the one that answered properly. VisitEngland's National Accessible Scheme exists for operators who want that assessed independently, and third party access guides are widely used by disabled travellers to filter where they will stay.
The booking journey matters as much as the room. If your website cannot be used with a screen reader, or the accessible room cannot be booked online and has to be arranged by phone during office hours, you have built a barrier at the top of the funnel. Working to WCAG 2.2 at level AA is the practical benchmark, and it is cheaper than defending a claim.
The market is real and it is badly served
There is a commercial argument here and it does not need inflating with invented figures. Disabled guests rarely travel alone. A booking is usually two, three or four people, and the group books where the one person's requirements can be met. That makes the accessible room the deciding room for the whole party.
It also makes those guests loyal in a way that is unusual in hotels. A place that got it right, answered the phone properly and did not make anybody feel like an inconvenience gets booked again, and gets recommended in communities that share this information constantly. The barrier to competing for that trade is low, because so much of the sector still describes its accessible room in one word and hopes.
Get the description right first. Fix the building when you next open it up.
Where this shows up in the game
Hotels arrive in Business Baron with the Hotels & Leisure Track, an add-on to the full game. Premises work in the game is a project with a timetable rather than a purchase, which is why an accessible room is cheaper to plan than to retrofit. Brand trust rests partly on integrity, and a description that promised more than the room delivers is the quickest way to spend it.