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The EHRC rulebook
just changed.
Have your policies?

The EHRC's updated code of practice is the most significant equality law development since 2011. If your policies were written against the old guidance, they may already be out of date. We are offering a free audit to help you find out.

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Free · Limited availability

We are offering a free policy audit to help UK employers identify where their policies need to change.

Policies drafted against the 2011 code may no longer reflect current legal expectations. Request your free audit and we will tell you exactly where the gaps are.

9 protected characteristics covered by the updated code
15 years since the last major update to the code

Why act now

Your existing policies may not reflect the updated law.

The EHRC has published its first major update to the code of practice for services, public functions and associations since 2011. The updated code reflects the Supreme Court's ruling that "sex" in the Equality Act means biological sex, incorporates significant new case law on disability - including hidden impairments, fluctuating conditions, and neurodiverse conditions - and consolidates previously separate guidance on age discrimination.

The practical implication for employers is straightforward: any policy drafted against the previous code may now be inconsistent with current legal expectations. That includes equality and diversity policies, disability and reasonable adjustment policies, attendance and absence policies, and any policies that reference "gender" where they should now reference "sex".

You do not need to wait for employer-specific EHRC guidance to begin reviewing your policies. The principles in the updated code are clear. Acting now means you identify gaps before they become claims.

What has changed in the updated code

  • "Sex" in the Equality Act now means biological sex following the Supreme Court's ruling in For Women Scotland v Scottish Ministers
  • Single-sex services guidance updated with clearer proportionality framework
  • Gender reassignment protections reaffirmed - the clarification of sex does not diminish them
  • Disability definition expanded to explicitly cover hidden impairments, fluctuating conditions, and neurodiverse conditions including ADHD, autism, dyslexia, and dyspraxia
  • Gender pay gap reporting terminology updated from "gender" to "sex" throughout
  • Age discrimination guidance consolidated into the main code for the first time
  • Courts and tribunals are required to take the updated code into account when deciding cases

Get started

Not sure which of your policies are affected? We will tell you - for free.

Send us your policy suite and we will identify every document the updated code touches. No cost, no obligation.
Request your free audit →

What TWIC reviews

A thorough review across six policy areas.

Our audit covers every area of your policy framework that is touched by the updated code. We do not produce a generic checklist - we review your actual documents and tell you specifically what needs to change.

Equality, Diversity & Inclusion Policy

  • Alignment with updated protected characteristics guidance
  • Correct use of sex vs gender terminology
  • Coverage of all nine protected characteristics
  • Consistency with updated code principles

Disability & Reasonable Adjustment Policy

  • Updated disability definition including hidden impairments
  • Explicit reference to fluctuating conditions
  • Neurodiversity coverage - ADHD, autism, dyslexia, dyspraxia
  • Reasonable adjustment process and documentation requirements

Single-Sex Services & Facilities

  • Proportionality framework for single-sex provision
  • Dignity, privacy, and safety considerations
  • Gender reassignment protections clearly maintained
  • Decision-making process documented and justifiable

Attendance, Absence & Capability

  • Disability-related absence handled separately from general absence
  • Fluctuating conditions accounted for in absence triggers
  • Reasonable adjustment duty reflected throughout
  • Return-to-work process legally compliant

Gender Pay Gap Reporting

  • Terminology updated from gender to sex throughout
  • Data collection forms and processes updated
  • GRC holder recording guidance applied
  • Reporting templates aligned with updated EHRC guidance

Manager-Facing Guidance & Procedures

  • Manager guides reflect updated disability definition
  • Adjustment conversation frameworks updated
  • Disciplinary and capability guidance consistent with reasonable adjustment duty
  • Terminology consistent with updated code throughout

How it works

We review your actual documents, not a generic checklist. And it is free.

Every audit is based on the policies you submit. You receive specific, line-level recommendations - no cost, no broad observations that leave you guessing what to change.
Start your free audit → Read the briefing

What you receive

A clear picture and a clear plan.

Every free audit produces the same four deliverables. You receive an honest assessment of where your policies stand, specific recommendations for every gap we identify, and the practical support to act on them - at no cost.

01

Written audit report

A clear, non-legalistic document that sets out every policy reviewed, the specific gaps identified, the legal risk associated with each gap, and a prioritised list of recommended changes. Written for HR professionals and business owners, not lawyers.

02

Policy-by-policy gap analysis

A structured comparison of your current policy wording against the updated code requirements, with specific change recommendations for each document. Includes suggested replacement language where relevant.

03

Prioritised action plan

A clear, sequenced action plan distinguishing between urgent changes (high legal risk), important updates (medium risk), and good practice improvements. Designed to help you prioritise your time and resource effectively.

04

Debrief consultation

A 15 minute debrief call with a TWIC specialist to walk through the findings, answer your questions, and agree on next steps. We also signpost where additional support - such as manager training or policy redrafting - may be needed.

Ready to proceed

Free. No obligation. Turnaround typically two to three weeks from scoping.

Fill in the form below and we will confirm scope, timeline, and next steps. There is no cost and no commitment.
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Request your audit

Request your free audit.

Complete the form and we will be in touch to discuss your requirements and confirm the scope of your free audit. There is no cost and no obligation.

  • No obligation - we will discuss your needs before confirming anything
  • Audit turnaround typically two to three weeks from scoping
  • Delivered by an experienced TWIC inclusion specialist
  • Available to organisations of all sizes across all sectors

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