This is a checklist of actions that all providers of NHS and health and social care services in England receiving public funding must take to meet the requirements of the new information standard for the reasonable adjustment digital flag. Providers must reach full compliance with the standard by 30 September 2026.  

More background on the new information standard is available in the sections that follow the checklist.  

Summary checklist of actions for all NHS and health and social care service providers

A new reasonable adjustment digital flag information standard was published in this  Information Standards Notice (ISN) in December 2025. It replaces and updates a previous notice published in September 2023.

All organisations in scope of the reasonable adjustment digital flag information standard must implement it fully by 30 September 2026. A summary of the requirements is available below.

The ISN includes full details of the reasonable adjustment digital flag information standard and implementation guidance. The following summary checklist is for all NHS and health and social care providers that are publicly funded.    

Summary checklist 

• develop a policy which is in line with the reasonable adjustment digital flag information standard and amend any other impacted policies
• agree a comprehensive approach to identifying disabled people with reasonable adjustment requirements, including the new patient process in line with the reasonable adjustment digital flag information standard
• establish a clear process for recording individuals’ disability and reasonable adjustment information in line with the reasonable adjustment digital flag information standard
• create and establish a reasonable adjustment flag in local patient record systems, in line with the standard, to highlight and make individuals’ disability and reasonable adjustment information highly visible to staff
• establish a clear process for sharing individual’s disability and reasonable adjustment information in line with the reasonable adjustment digital flag information standard
• establish a clear process for reviewing and updating information on an individual’s records relating to disability and reasonable adjustment information in line with the reasonable adjustment digital flag information standard
• ensure organisational readiness for future digital integrations
• provide training and briefings to staff to explain the reasonable adjustment digital flag information standard, detail processes to be followed and raise awareness of support which staff can provide themselves. National training for all relevant health and care staff is available via a short e-learning module

What the reasonable adjustment digital flag is and why it must be implemented

The reasonable adjustment digital flag is a national record which indicates that reasonable adjustments are required for an individual and optionally includes details of their significant impairments, key adjustments that should be considered, and underlying conditions.

NHS England has built the reasonable adjustment digital flag in its National Care Records Service (previously known as the NHS Spine) to enable health and care professionals to record, share and view details of reasonable adjustments across the NHS, wherever the person is treated.

The Equality Act (2010) places a legal duty on all health and care services to make changes to their approach or provision to ensure that services are as accessible to people with disabilities as they are for everyone else. This duty aims to address the recognition that people with a disability may appear to have equal access to care and services, but without specific adjustments being made, that access may not be equitable.

A reasonable adjustment digital flag information standard was first published in September 2023 under section 250 of the Health and Social Care Act 2012.

In December 2025 the standard was updated, and it became mandatory for all NHS and publicly-funded health and care service providers to work towards full national compliance.   

The deadline for full national compliance with the information standard is 30 September 2026.

What must organisations that provide NHS and health and social care services do?

Compliance and implementation of the reasonable adjustment digital flag information standard is by a 2-phase approach. Organisations in scope should be actively working towards full compliance by no later than 30 September 2026.

Phase 1 – overview of actions, expectations and compliance

In phase 1, organisations must use their own systems and processes to identify, record, flag, share, meet, review and update reasonable adjustment information locally, ie on their own electronic systems and notes ready for sharing via the National Care Records Service. Where digital entry is not readily available, organisations should record them using paper records and subsequently code these digitally either on their own systems or via the National Care Records Service. The service’s IT customer support portal is available online.  

Phase 2 – overview of actions, expectations and compliance

In phase 2, organisations must flag and share reasonable adjustments using the reasonable adjustment digital flag via the National Care Records Service.

Phase 1: 3 practical actions for providers

This section describes 3 practical actions that providers need to undertake in phase 1 in order to achieve full compliance with the information standard by 30 September 2026. 

Action 1 required: identify patients with a disability or significant impairment

Identify people with a disability or impairment as defined under the Equality Act 2010 (a physical or mental impairment that has a substantial and long-term (greater than 12 months) negative effect on ability to do normal daily activities).

How can I do this? 

Suggestions on how to achieve this are below (note this is not an exhaustive list):

• disability and reasonable adjustment section on all new patient forms/registration documents (for example, add a standard line ‘do you require reasonable adjustments?’)
• disability and reasonable adjustment section on recall, review and appointment letters (for example, add a standard line ‘do you require reasonable adjustments?’)
• check at first contact
• identification during standard health checks such as annual health checks, long-term condition reviews, regular review appointments or assessments or during programmes such as immunisations (for example, annual influenza campaign)
• opportunistically: at any contact with the organisation
• identification through information received from outside the organisation (such as referral letters, discharge or out-patient letters, community assessments and communications from third party organisations
• review of registers and patient lists or consideration of cohorts coded with conditions which might result in impairment, such as those with conditions resulting in vision or hearing impairment.
• enable and encourage self-identification and optimise awareness (for example, posters, organisation website information)

Action 2 required: follow 6-steps to record on local systems

Organisations use their own systems and processes to record reasonable adjustment information on their own electronic systems and notes, ready for sharing via the National Care Records Service (formerly known as the NHS Spine) sharing to the National Repository in phase 2.

How can I do this? 

Suggestions on how to achieve this are shown below (note this is not an exhaustive list).

Consent 

Information recorded on the reasonable adjustment digital flag is shared under the lawful basis of implied consent and, as such, people can raise objections to their data being shared at any time, unless there is a valid reason why it should be shared. 

The Mental Capacity Act 2005 should be consulted with regard to decisions about capacity and competence.  

Phase 2: 2 practical actions for providers

Organisations must ensure readiness to share information digitally to and from the digital flag, either via a FIHR® API or via the National Care Records Service.

Organisations must ensure that their suppliers have engaged NHS England to commence the onboarding process for integration and have established a process to upload and download reasonable adjustment digital flag information via the National Repository. More information on these aspects can be found within the key documents section on this webpage and in the Guide to using the reasonable adjustment flag in the National Care Records Service

Resources

• Examples of how organisations are achieving compliance and resources to support you, including examples of the 6-step process on the NHS Futures platform (login required – you can request membership via the link)
• Reasonable adjustment digital flag Information standard and implementation guidance
• Guide to using the reasonable adjustment flag in the National Care Records Service
• National Care Records Service – includes user guide
• National Care Records Service IT customer support portal

Other key relevant policy and guidance: 

• Equality Act 2010
• Accessible information standard