Are Disabled People Shaping Your Decisions?
The EHRC's accessible transport principles call time on performative engagement.
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The Equality and Human Rights Commission (EHRC) has published its Guiding Principles for Accessible Transport, and if you work in transport, you should take note. There are seven principles in total, covering everything from communication to complaints to continuous improvement. They apply to England and Wales. I want to focus on the first one, as it’s the most important and the solution to many of the issues we’re facing today. It’s one where the transport sector still gets it spectacularly wrong: Active Involvement.
The principle states that disabled and older people should be “closely consulted and actively involved in decisions affecting the accessibility of services, including at the start of new projects and during reviews of existing services.” It also states that evidence from disabled and older people should inform assessments of the potential and actual impacts of transport policies and practices.
Nothing About Us, Without Us
None of this should be new. And yet, here we are. I’ve written before that the most important voices in accessibility conversations are those who are disabled. I find it baffling how many organisations still separate the topics of accessibility and disability from each other, as if you can design accessible services without involving the people who actually need them.
They have non-disabled teams, they don’t get disabled people involved, and they think they’re doing something good, but it doesn’t work like that. If you’re lucky, project teams try to follow the rules and guidelines. If you don’t understand what the rules are for practically, it’s easy to fulfil them, but make mistakes. E.g., the 1.50m next to an accessible toilet is needed to transfer from a wheelchair onto the toilet. If you put a hand dryer there or a bin or whatever, the whole space becomes unusable. It’s an empty space with a purpose.
The EHRC putting Active Involvement as Principle Number One is not a coincidence. It’s a signal. It tells you that they consider genuine engagement with disabled and older people to be the foundation on which everything else rests. Not communication, not complaints handling, not data collection, involvement.
And the word “active” matters. This is not about sending out a survey once a year and ticking a box. It’s not about having an accessibility panel that meets twice a year over biscuits, where everyone agrees and never influences a single decision. Active involvement means disabled and older people are in the room when decisions are made. At the start. Not after the plans are drawn up, not after the procurement contract is signed, not after the new app has been built. At the start.
The Consultation Theatre
Let’s be honest about what happens in many organisations. There is a consultation. Disabled people are invited. They share their experiences, their frustrations, their needs. Notes are taken. Everyone feels good about the process. And then nothing happens. The feedback disappears into a report that no one reads, or, worse, gets cherry-picked to support decisions that were already made.
I’ve seen this pattern so many times and there is a term for it: performative engagement. Inviting disabled people, asking for their demands and needs, and then doing nothing except using this engagement to tell the world there was engagement with disabled people.
That creates a really bad culture for stakeholder engagement in the long term because people will be less and less willing to give input if they feel it’s not appreciated and, in fact, abused. Or you always invite the same disabled people where you know they nod to everything. No critical friend approach, approbation by default.
The EHRC’s principle challenges this directly. It doesn’t just say “consult.” It says “closely consulted and actively involved.” There’s a difference between asking someone what they think and giving them genuine influence over the outcome. If your engagement process doesn’t change anything, it’s not engagement. It’s theatre.
What Active Involvement Actually Looks Like
So what does genuine active involvement look like in practice? Here are some indicators:
Disabled people are involved from the design stage. Not brought in to review a finished product, but included when the brief is written. If you’re redesigning your booking system, disabled customers should be shaping the requirements, not testing a finished product that was designed without them.
There is a feedback loop. When disabled people give input, they can see what happened with it. Did it influence the decision? If not, why not? Transparency builds trust. Silence destroys it.
The voices are diverse. Disability is not a monolith. A wheelchair user, a blind person, a Deaf person, someone with a learning disability, an autistic person and an older person with reduced mobility will all have different needs and perspectives. If your panel consists of one or two people who are easy to work with and never challenge you, you’re picking the convenient voices, not the representative ones. And make sure they have the right approach to disability. Social Model of disability, not the medical model. No service, product, or organisation will improve for disabled people with a medical model worldview. That’s a hill I will die on.
Involvement is resourced. Asking people to give their time, expertise, and emotional energy for free is not respectful. If you pay your consultants, pay your disabled advisors and consultants as well. Their lived experience is expertise, and it should be valued as such.
It’s ongoing, not a one-off. Active involvement is not a project with a start and end date. It’s a continuous relationship. Services change and new barriers emerge. The conversation should never stop.
Hire disabled people into your teams. Seriously, I still don’t understand why I don’t meet more disabled people in transport teams. And not just the accessibility team, the project team lead and the IT manager too. It can improve not only the projects but the company culture as well. If you don’t know where to start, try Evenbreak.
And to the disabled readers: Please don’t participate in window dressing. Getting paid is a really good indicator of whether the company is serious or just doing window dressing, but not the only one. Window dressing is actually more harmful than doing nothing. So please, don’t take part in it.
The Legal Backbone
The EHRC’s guiding principles are not law in themselves, but they are informed by equality and human rights law, and the EHRC has made it clear that it will use these principles in its engagement with the sector. That’s a polite way of saying: we will measure you against this.
The Equality Act 2010 already requires service providers to make reasonable adjustments for disabled people. The Convention on the Rights of Persons with Disabilities, Article 9, requires equal access to transport. Active involvement of disabled people is not a nice-to-have. It’s embedded in the legal framework that applies to organisations in the UK already. What the EHRC has done with these guiding principles is translate those legal obligations into practical expectations.
The Uncomfortable Truth
Here’s the uncomfortable truth for accessibility managers: if your organisation has been doing engagement badly, or not at all, this principle will expose that. And if you’ve been doing it well, this is your moment to demonstrate it.
I strongly believe that if accessibility work and initiatives are not based on the social model of disability, they cause more harm than good. The social model says that people are disabled by barriers in society, not by their impairments. Active involvement is the social model in action. You can’t identify and remove barriers if you don’t talk to the people who experience them. And you can’t talk to them meaningfully if you don’t share power, listen properly, and act on what you hear.
The EHRC has also made something else clear: regulators and scrutiny bodies have a responsibility to use equality data to compare performance across the sector and bring operators together to promote good practice.
What To Do Now
I would recommend to any organisation that wants to improve their customer experience to start with Active Involvement and ask themselves honestly: are disabled and older people genuinely influencing our decisions, or are we just doing that because a regulator told us so?
Audit the current engagement. Who is involved? When are they involved? What happens with their input? If these questions can’t get answered clearly, that’s the starting point.
Talk to disabled people. Not at them, not about them, but with them. As equal partners and critical friends. That’s what Active Involvement means, and the EHRC has just made it Principle Number One for a reason.
Some interesting links
Five more London Underground stations have been given a second chance to become step-free, if Transport for London can secure the funding. The stations considered are Barkingside, Brent Cross, Preston Road, Queensbury and Totteridge & Whetstone, writes Ian Mansfield.
The Law Commission has launched a review of the current laws governing the accessibility of transport for disabled people across England and Wales. The objective of the review is to make recommendations to simplify and consolidate the legal framework and supporting end-to-end journeys by disabled people across Great Britain.
More than half of UK local authorities are finding it difficult to make public electric vehicle charging infrastructure accessible to disabled drivers, according to new research from charge point operator Believ.
Something to watch
What Gareth Dennis says… This is how transport disables people.
Bits, Bobs & Jobs
The BBC is searching for a Senior Accessibility Specialist for the Accessibility and Design Integration team, nationwide.
LNER is searching for an Accessibility Improvement Manager - 24 month Secondment in York.
Saying No Is Disability Advocacy: Why People with Disabilities Must Stop Over-Explaining and Start Setting Boundaries - “Disability policy has advanced historically not through quiet acceptance but through organised pressure, litigation, protest, and sustained narrative change.”
What I’ve just read: Come what may - An uplifting guide to navigating hard times from the UK’s leading expert on recovery by Lucy Easthope - My rating: 4/5
Some final words
The Accessible Link is a reader-supported publication.
Who is writing this newsletter?
I’m Christiane Link, and I improve the customer experience in aviation, transport, and travel. I worked as a journalist for over two decades and travelled extensively for business and leisure. I’m a wheelchair user.
Work with me
Whether you're a Customer Service Director, a Head of Customer Experience, a corporate Accessibility Manager, a DEI leader, a transport planner, or a member of a disabled employee resource group, I can help you make your organisation more inclusive. You can book me for speaking engagements or hire me as a consultant for your accessibility or DEI strategy, communications advice and other related matters. I have worked for airlines, airports, train operators, public transport providers, and companies in other sectors.
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