Latest on the Reasonable Adjustment Digital Flags (RADF)
A new Information Standards Notice (ISN) was published in December 2025 which makes it mandatory for all NHS, health and social care service providers that are publicly funded to be able to share, read and write reasonable adjustment digital flags by 30 September 2026.
Once implemented nationally, it will be a game changer for millions of disabled people, making it easier for them to receive reasonable adjustments whenever and wherever they use health and social care services that are publicly funded.
How does it work?
In short, the reasonable adjustment digital flag provides a national visible marker on a person’s record (available via the NHS’s National Care Records Service) which indicates any reasonable adjustments needed by a person with a disability whenever they are seen or treated.
Reasonable adjustments are tailored to an individual’s needs and may include things like providing wheelchair access, providing information in large print or enabling a supporter or carer to accompany a disabled person to a meeting. They are a legal requirement under the Equality Act 2010 to ensure NHS, health and social care services are as accessible to disabled people as they are to everyone else.
The new information standard has 3 important changes:
1. Change in law from advisory to mandatory status
All NHS and other publicly-funded health and social care service providers that are not yet using the reasonable adjustment digital flag, MUST, from December 2025, ensure that they are familiar and compliant with the requirements in the new information standard and its accompanying guidance. See this summary checklist of actions for service providers. It follows legal changes in the Health and Care Act 2022 Amendment to the Health and Social Care Act 2012. Previously the requirement was advisory only.
2. Consent for the reasonable adjustment digital flag has changed from explicit consent to implied consent
The new information standard changes the basis of consent required by a provider to share a person’s personal information from explicit to implied consent. However, 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 regards to decisions about capacity and competence.
3. Full national compliance timeline has changed
All NHS and other publicly-funded health and social care providers must fully comply with the reasonable adjustment digital flag by 30 September 2026. If their supplier’s system software has not completed the onboarding process by this date providers must instead be able to share, read and write reasonable adjustment data directly via the NHS’s National Care Records Service.
Three things that NHS and publicly-funded health and social care providers must now do:
1. They must ensure all staff who use disabled people’s records continue to learn about and understand reasonable adjustments. Free training is provided in partnership by NHS England and e-Learning for Health here: Reasonable adjustment digital flag - eLearning An updated version covering all health and social care sectors is expected to be launched by March 2026.
2. They must identify people who need reasonable adjustments to access their care, record and regularly review these on their own IT systems or via the NHS’s National Care Records Service (previously known as “the spine”). This is in preparation for the data to be shared with other health and social care providers via the National Care Records Service by 30 September 2026.
3. The new information standard requires that all NHS and other publicly-funded health and social care service providers must be able to share, read and write reasonable adjustment data by 30 September 2026.
Providers whose software suppliers have completed the national registration and onboarding process by this date will be able to use their software to access the digital flag. Alternatively, they can directly access the National Care Records Service data via its online portal.
Health and social care providers are advised to establish if their software supplier has registered their interest in the onboarding process for reasonable adjustments. They can do so by consulting NHS England’s national supplier interest list or Information about suppliers (NHS Futures collaboration workspace login required).
If their supplier’s software isn’t registered, providers should ask them to do so.
Suppliers can use this link to register: Patient Flag API supplier interest form - NHS England Digital
Details of how to read and write reasonable adjustments are here: Guide to Using the Reasonable Adjustment Flag in NCRS – NHS England Digital
Which health and social care providers MUST comply?
All NHS and other health and social care providers that are wholly or partly funded by the NHS, local government (councils) or integrated care boards, must comply with the new information standard. They include providers in these sectors:
- NHS primary care – general practice, community pharmacy, dental and eye care
- NHS secondary care (all NHS trusts and foundation trusts) – planned and elective care, urgent and emergency care, mental health care, maternity care, ambulance services, out of hours GP services
- NHS specialist acute care (all NHS trusts and independent sector) – commissioned services such as transplants
- NHS community health care (all NHS trusts and independent sector providers) – community mental health care, community nursing, occupational therapy, health visiting, community midwifery, child health, palliative care and many other services
- All providers of NHS and/or social care from the voluntary and community or private sectors
- All other NHS-funded services – for example, health services in prisons and police custody suites, high street optometry and audiology services, other community services
- Public health services – including advice and information, for example, sexual health services
- All publicly-funded social care services – for example, residential care, home care, domiciliary care, day care, respite care and other community services.
More information
There is more about reasonable adjustments and digital flags (RADF) here: NHS England » Reasonable adjustments.
Over the coming weeks we will provide progress updates via a range of channels, including via NHS Futures’ workspace, Flagging Reasonable Adjustments – everything I need to know - Futures. (login required, please apply for free membership using a “nhs.net” or “gov.uk” email address). For social care providers without this option contact the email below.
Contact the support team
If you have any questions for me or for my programme colleagues, please contact the national reasonable adjustment digital flag mailbox at this address: [email protected]
