Accessible Information: Why "We Meet the Standard" Usually Means "We Meet Part of It"
If you asked most independent healthcare providers whether they comply with the Accessible Information Standard, you'd get a confident yes. Ask them to show you the evidence, and the confidence tends to thin out fast.
That gap matters more than it used to. The Standard was refreshed in 2025, a self-assessment framework now sits alongside it, and CQC has built it directly into how it tests the responsive key question. What used to be a soft expectation is now something you're asked to evidence — and increasingly, something a regulator will go looking for even if you don't offer it up.
This piece is about two things. First, the specific places providers tend to fall short, often without realising it. Second, something that doesn't get said often enough in governance circles: accessible information shouldn't be a favour someone has to ask for. If a person has to request it, and request it again at the next appointment, and again with the next clinician, the standard hasn't really been met — it's just been made conditional on the patient doing the work.
What the standard actually asks for.
The Accessible Information Standard (AIS, formally DAPB1605) has been a legal requirement for NHS and publicly funded adult social care providers since August 2016, and it explicitly covers private hospitals and organisations delivering NHS-funded care, not just NHS trusts. It applies wherever someone's ability to access or understand information, or to communicate with staff, is affected by a disability, impairment or sensory loss — and that includes carers and family members with needs of their own, not only the patient in front of you.
The standard sets out a sequence of steps organisations are expected to follow: identify a person's information and communication needs, record them clearly, flag them so they're visible wherever that person is seen, share them appropriately with other providers involved in their care, and meet them in practice. Following the 2025 update, a sixth step was formally added: review. Needs aren't static — they change, and the standard now expects providers to check in on them over time rather than recording something once and treating it as settled indefinitely.
None of this is exotic. It's closer to good clinical record-keeping than to a specialist accessibility project. Which is partly why it gets missed — it doesn't look like the kind of thing that needs a policy.
Where providers actually fall down
In our experience working across independent and private providers, the gaps rarely come from ill will. They come from treating the standard as a document rather than a live operational habit. A few patterns come up again and again.
Recording without flagging. A need gets noted in a consultation summary or an admissions form, and then it sits there — technically recorded, practically invisible. If a receptionist booking a follow-up, or a locum seeing the patient for the first time, has no way of seeing that flag at the point of contact, the recording has achieved nothing except paperwork. The test isn't "did we write it down somewhere," it's "would the next person interacting with this patient know, without having to ask."
One-off identification. Needs are often captured once, at registration or first assessment, and never revisited. Someone's hearing changes. Someone develops a condition that affects reading. Someone's preferred communication method shifts after a stroke or a diagnosis. The 2025 review requirement exists precisely because static records go stale, but a lot of providers haven't yet built review into any recurring process — it's not on a care plan cycle, not on an annual check, nowhere.
Treating it as a specialist add-on. Some providers have built genuinely good processes for patients who are already known to have a sensory impairment — an established deaf patient, for instance, has clear provision. But the standard applies far more broadly than that, and the identification step is supposed to be routine for everyone, not triggered only when a need is already obvious. If your process only switches on once someone discloses something, you've skipped the "identify" step entirely and gone straight to "meet," which only works for the people who already know to ask.
No audit trail. This is the one that catches people out with CQC. Since the self-assessment framework was introduced, providers are expected to be able to show their own performance against it, including publishing that self-assessment and the actions taken to close gaps. "We do this" isn't evidence. A register of identified needs, a record of flags applied, a note of when needs were last reviewed, a documented reason on the rare occasion a "should" requirement wasn't met — that's evidence. Very few independent providers have this ready to hand over, because until recently nobody was really asking for it.
The sector data behind this isn't flattering. Freedom of Information research found only around a third of NHS trusts considered themselves fully compliant, and a smaller fraction still could actually evidence having audited their own compliance. A 2025 report on deaf people's experience found the majority had never once been asked, at any point of contact, whether they had a communication need. These are NHS figures, but there's no reason to assume independent providers are, on average, doing better — most are smaller, with less dedicated equality and diversity resource, and the same instinct to assume "we'd know if it were a problem."
The part that doesn't get said enough: this isn't something people should have to ask for
Here's the bit we think gets lost in a lot of AIS compliance work, which tends to focus heavily on process and documentation and rather less on what it actually feels like from the other side of the desk.
The whole design of the standard is proactive. Identify, record, flag, share, meet, review — every one of those verbs describes something the organisation does. Not one of them says "wait for the patient to ask." And yet in practice, a huge amount of accessible provision in health and care still runs on the patient having to raise it — often more than once, often with someone new each time, often having to explain the same thing to a receptionist, then a nurse, then a consultant, because none of it was flagged anywhere they could see it.
That's not a technical failure of the standard. It's a failure to build it into the default pathway rather than treating it as an exception process for people who self-advocate. And self-advocacy under those conditions has a cost. Having to explain a disability or communication need repeatedly, to strangers, in a clinical setting, while also trying to manage whatever brought you there in the first place, is exhausting in a way that "just ask us" doesn't account for. It also quietly filters who gets accommodated well: people who are confident, who know their rights, who have the energy that day to push. Everyone else falls through — which is exactly what the RNID and SignHealth findings suggest is happening at scale.
Good governance on this doesn't stop at "we have a policy that says people can request accessible formats." It asks a harder question: does our default pathway assume the need might be there before anyone has said a word? Is identification something we do routinely, as a matter of course, the same way we routinely ask about allergies — or is it something that only kicks in once a patient has already had to flag themselves as different from the standard case? Access shouldn't be a favour granted on request. It should be the starting assumption, with the burden of building the process sitting with the provider, not the burden of asking sitting with the patient.
What this means practically for boards and governance leads
A few concrete things worth checking, beyond "do we have an AIS policy":
Can a member of front-line staff — reception, not just clinical — see a flagged communication need at the point of contact, without having to dig for it or ask a colleague?
Is there a defined trigger for reviewing recorded needs, rather than leaving review to happen only if something goes wrong?
Is identification built into a standard part of your pathway (registration, pre-assessment, annual check) for everyone, or does it only activate once someone discloses something?
If CQC asked for your self-assessment against the framework tomorrow, could you produce it, along with an action plan for the gaps it shows, within a day?
Where a "should" requirement in the standard genuinely isn't being met, is there a documented, credible reason on file — or is it just not happening, with no record of why?
None of this needs to be complicated. It needs to be built in as routine rather than treated as a specialism, and it needs an evidence trail that exists whether or not anyone ever asks to see it. That's the difference between an organisation that meets the standard and one that's confident it does.
If you want a structured way to work through where your own service stands against the AIS — identification, flagging, review cycles, and the self-assessment evidence CQC will expect to see — this is exactly the kind of gap analysis we build into the Harbour Governance toolkit. Get in touch if it would help to talk it through.
