It is mandated that all NHS services (including general practice) will implement the Reasonable Adjustments Digital Flag by 30th September 2026.
We understand that this is currently unavailable in EMIS or SystmOne (but is available in Medicus). Currently it can only be accessed via the National Care Record Service (NCRS)
How do the digital flags work?
Each reasonable adjustment digital flag provides a national visible marker on a person’s record (available via the National Care Records Service) which indicates any reasonable adjustments needed by a person with a disability, whenever they are seen or treated within allpublicly-funded health or social care services.
Reasonable adjustments are already a legal requirement under the Equality Act 2010 for all providers of publicly-funded health or social care services, helping ensure their services are as accessible to disabled people as they are to everyone else. The reasonable adjustment digital flag supports providers to deliver this.
What are reasonable adjustments?
Reasonable adjustments are tailored to an individual’s needs. They may include adjustments like providing wheelchair access, providing information in large print or making provision so that a supporter or carer can accompany a disabled person during an appointment or meeting.
What has changed as a result of the new information standard?
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 requirements 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, health and publicly funded 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 the reasonable adjustments they need 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 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. NB the list includes:
- AccuRx
- Ardens
- Econsult
- Engage
- Eclipse
- TPP
- Optum (EMIS)
Details of how to read and write reasonable adjustments are available here: Guide to Using the Reasonable Adjustment Flag in NCRS – NHS England Digital
For comments or queries please email the LMC.