Council facilities checklist: trans-inclusive physical environment

This checklist is for facilities managers, estates leads and building managers in councils implementing the 2026 EHRC Services Code. Use it as a building-by-building walk-survey template. The governing principle throughout is simple: sign by contents, not by eligibility — signs should describe what is inside a facility, not who is allowed to enter it.

This is the public-facing buildings checklist. It is distinct from the toilets and signage playbook, which covers the workplace and service-provider signage regime. The executive briefing sets out the legal position in concise form for councillors and senior officers.

The EHRC Services Code 2026 is in force from 5 August 2026. The Equality Act 2010 duties and the Public Sector Equality Duty apply now, unchanged. Nothing in this checklist is legal advice; it is a practical facilities tool grounded in the current legal frame.

How to use this checklist

Complete one checklist per building. Walk the building with a clipboard or tablet. Be specific — note every gendered or eligibility-based sign, every missing transfer side, every cord that does not reach the floor. The output is a building-level baseline. Aggregate across the estate to identify common gaps, prioritise quick wins, and build the capital-work programme for items that need budget.

Building details

• Building name:
• Address:
• Date of survey:
• Surveyed by:
• Building type: (civic, library, leisure centre, community facility, other)
• Council control: (direct / landlord / shared / commissioned)

Signage audit

• Signage basis — do signs show what the facility contains, or who may use it (gendered/eligibility)? Note every gendered or eligibility-based sign:

• All-gender provision — is there all-gender provision alongside sex-specific? Are self-contained single rooms signed all-gender by default?

• Third spaces — is any facility labelled or used as a separate “trans” facility? (Should be none.)

• Transfer side stated — does every accessible WC sign state left- or right-hand transfer?

• Changing Places — is there a ceiling hoist and adult changing bench on site? If not, is the gap flagged and the nearest Changing Places signposted?

• Ambulant accessible provision — are there grab-railed cubicles for people who walk but need support?

• Baby change — where is it, and is it only in the accessible or women’s WC? (It should be available to all carers.)

• Family room — is there provision for a parent or carer with children?

• Menstrual provision — are bins and products in all relevant toilets (including all-gender and men’s), not only those for women?

Configuration and privacy

• Configuration — single-user rooms, multi-cubicle washrooms, urinals present (and cubicle count remaining)?

• Floor-to-ceiling privacy — do cubicle doors and partitions go from floor to ceiling?

• Full-height lockable doors — on every cubicle and single-user room?

• Lighting — appropriate, not assumed? (Bright light aids some people and excludes others.)

• Ablution / washing — taps for washing; squat provision where feasible?

Accessible WC essentials

• Transfer space clear — no bins, cleaning equipment or supplies stored in the accessible WC?

• Red emergency cord — reaches the floor? (Cords are often tied up or cut by cleaners.)

• Shelf — present and not removed? (Needed for stoma/ostomy care and medication management.)

• Hooks, soap, toilet roll, brush — all present?

Published access information

• Website page — is there a facilities page on the council website with a photo and contents list for each toilet and changing room?

• Staff briefed — can reception and frontline staff direct people to the full range of provision, not just the nearest door?

• Maps — in larger buildings, are there maps with photos showing where facilities are?

Reasons recorded

• Audit on file — the completed checklist, the EqIA (if carried out), any consultation, the decision and contemporaneous reasons, on file?

• Decision record — for each signage or provision change, is there a decision record completed?

Quick wins (low-cost, high-impact)

Where budget is tight, do these first — most cost very little and they address the majority of the harm:

1. Relabel self-contained single rooms with contents-based, all-gender signage.
2. Add the transfer side to every accessible WC sign.
3. State “Changing Places” only where it is true; signpost the nearest real one otherwise.
4. Put the red cord down, clear the transfer space, restore the shelf, add hooks, soap and toilet roll.
5. Add menstrual bins and products to all-gender and men’s toilets.
6. Publish a facilities page on the council website with a photo and contents list for each toilet and changing room.
7. Brief frontline and cleaning staff on what each sign means and why.

Items 1–5 are same-day or next-week actions for a facilities team with no capital budget. Items 6–7 are low-cost communications work that magnify the impact of the physical changes.

Review triggers

Re-survey the building when any of the following occur:

• A change in law or statutory guidance (including further EHRC Code updates).
• A refurbishment, refit or change of use that affects toilet, changing-room or shower provision.
• A complaint or challenge about facilities that signals a gap the audit did not surface.
• A change of tenant, managing agent or commissioned provider where the council does not control signage directly.
• A new building acquisition or lease surrender.

Set a review date no more than 12 months from the date of survey, even if no trigger fires.

• Next review date:
• Review owner:

What this is not

This checklist is a practical facilities tool, not a compliance certificate. Meeting Building Regulations Approved Document T and BS 8300 is a minimum, not proof of inclusive or lawful provision. For formal proceedings or contested matters, instruct a solicitor or barrister.

Take this further

The toilets and signage playbook covers the design principles in more detail. The single-sex spaces manager decision framework sets out the proportionality test for any restriction.

For the full council facilities guidance — design standards, commissioning contract clauses, localisation templates, policy review prompts and expert review triggers — see Consulting.

This checklist provides general information and does not constitute legal advice. It is a scaffold to support your own facilities audit and decision-making. Adapt it to your context and take specialist advice where your decisions warrant it.