RSUA has called on the Department for Communities (DfC) to strengthen the Northern Ireland Disability Strategy 2025–2035 by setting clearer delivery mechanisms, improving how progress is measured and raising the level of ambition across a number of specific commitments.
In our response to a public consultation, RSUA welcomed the Strategy’s aim of embedding equality, choice and control across public services, but emphasised that its success in relation to the built environment will depend on translating proposals into detailed, time-bound actions.
Background
The Disability Strategy aims to establish a decade-long framework to improve outcomes for Deaf and disabled people across Northern Ireland, including commitments on accessibility, housing and the public realm.
A draft version of the Strategy was issued as part of a consultation process that closed for responses on 20 March 2026.
Action Plan absence
We raised concerns about the current absence of an Action Plan, promised by the Department at an unspecified time in the future. RSUA highlighted that the Strategy was limited by its inability to link strategic commitments concerning the built environment with meaningful detail or timelines for delivery.
We also noted that progress on many commitments could begin before an Action Plan is formally published.
Outcome indicators
Referring to Outcome 2, which states that “Deaf and disabled people can access our built environment, facilities and transport on an equal basis,” we noted that there were only two indicators of progress for seven strategic commitments.
These indicators both focus on transport and do not capture progress on wider commitments such as inclusive design, public realm improvements and accessibility upgrades.
RSUA therefore recommended developing additional indicators to measure progress across all strategic commitments under Outcome 2.
Strategic commitments
We also commented on several specific commitments within the Strategy, including:
We welcomed the ambition to embed inclusive design standards, including BS 8300, within government procurement and to develop proportionate accessibility requirements for buildings.
RSUA recommended including a target date for delivery and suggested integrating PAS 6463 into procurement policy and future Building Regulations to better address neurodiversity and sensory processing differences.
We noted that the Strategy referred to future NICS Estates projects complying with Building Regulations for Changing Places Toilets.
RSUA raised concerns that this reflected meeting a baseline for compliance rather than an ambitious programme of work.
We suggested that commitments stopping at compliance should be removed from the main document or presented separately as “progress to date” to better distinguish them from strategic objectives.
We supported the Strategy’s focus on improving the availability of suitable housing for Deaf and disabled people. RSUA agreed on the importance of reflecting Deaf and disabled people’s views in implementing this work, updating housing need assessments and completing the review of the Disabled Facilities Grant.
We also highlighted the need for adequate resourcing of the Disabled Facilities Grant to ensure high quality design outcomes, noting that under-resourcing risks prioritising functionality to the point of discarding design quality.
We supported the development of guidance on Inclusive Design to improve housing standards for people with cognitive and sensory impairments.
RSUA reiterated the opportunity to integrate PAS 6463 into this work and recommended including a target date for publication.
Further engagement
Our full response can be viewed here.
If you have any questions or comments about this response, please contact Curtis Large, RSUA Policy and Public Affairs Officer, at curtis@rsua.org.uk
