Since October 2024, a significant and largely under-discussed change to England’s Building Regulations has been in effect. For anyone involved in office fit-outs, refurbishments or the ongoing management of commercial premises, it is worth understanding what has changed, what it means in practice, and where the wider regulatory picture is heading.
What is Approved Document T?
The Building (Amendment) (England) Regulations 2024 introduced a new functional requirement – Requirement T1 – under a new Part T of Schedule 1 to the Building Regulations 2010. It came into force on 1 October 2024 and applies to new buildings and material changes of use across England.
In straightforward terms: non-residential buildings must now provide separate, single-sex toilet facilities as the default. Universal toilets – fully enclosed, individually accessible rooms – may be provided in addition to single-sex provision, or where space genuinely precludes single-sex provision. Gender-neutral shared facilities, previously adopted by some operators and developers, no longer meet the requirements of the regulations for new builds and qualifying refurbishments.
The four compliant toilet types identified in Approved Document T are:
- Type A – Fully enclosed, self-contained ambulant universal toilet
- Type B – Fully enclosed, self-contained universal toilet
- Type C – Ambulant single-sex toilet cubicle (not self-contained)
- Type D – Single-sex toilet cubicle (not self-contained)
All toilet accommodation must also have clear and appropriate signage.
Does this apply to my building?
The requirement applies to new buildings and to buildings undergoing a material change of use where toilet facilities are included in the scope of works. It does not retrospectively require existing buildings to alter their current provision – but any qualifying refurbishment or fit-out project from October 2024 onwards must comply.
Transitional provisions apply to projects where a building control application was submitted before 1 October 2024 and works were sufficiently progressed by April 2025. Beyond that window, compliance with Part T is required for all applicable projects.
It is also worth noting that Approved Document T should be read alongside Approved Document M, which governs accessibility. Accessible provision and the design of universal toilets are addressed under both documents and must be considered together.
The wider compliance picture
Part T sits alongside longer-standing obligations that all office occupiers and building managers should already be meeting. The Workplace (Health, Safety and Welfare) Regulations 1992 – still the primary framework for workplace welfare facilities – require employers to provide suitable and sufficient sanitary and washing facilities for their workforce. The approved code of practice sets minimum ratios: one toilet and washbasin for every 1–15 workers, scaling up from there.
Separately, the Supreme Court’s April 2025 ruling clarifying that “sex” in the Equality Act 2010 means biological sex has implications for how workplace toilet facilities are designated and managed. The Equality and Human Rights Commission’s updated guidance makes clear that single-sex facilities should be designated for use based on biological sex, and that providing inadequate facilities for either sex can constitute direct sex discrimination. Employers are expected to have a clear, consistently applied and lawfully grounded policy.
What this means for facilities managers and office occupiers
For most existing office buildings, the immediate practical question is not one of retrospective compliance but of future planning. Any refurbishment project that includes washroom works should now be considered in the context of Part T – both to ensure any notifiable works comply, and to avoid the cost and disruption of having to revisit provision shortly after a project completes.
Beyond the regulatory dimension, there is a straightforward operational case for reviewing washroom provision as part of any office improvement programme. Well-designed, well-maintained facilities remain a meaningful contributor to employee experience – and in a market where workplaces are competing to justify the commute, the quality of welfare facilities carries more weight than it once did.
Key considerations for any office washroom review include:
- Adequate provision for current headcount under the Workplace Regulations 1992 ratios
- Single-sex provision in line with Part T for any qualifying refurbishment scope
- Accessibility – both regulatory compliance under Part M and genuine usability for all employees
- Whole-life costs – durable materials, low-maintenance systems and long-term performance rather than lowest upfront specification
- Sustainability – water-efficient fittings, reduced maintenance requirements and materials with longer lifecycles
Planning a refurbishment?
If an office washroom project is on the horizon – whether as part of a wider fit-out, a reactive response to ageing facilities, or a proactive estates review – the regulatory environment makes early planning more important than ever. Understanding what Part T requires, and how it interacts with existing obligations, is a sensible starting point before any specification work begins.
At Interfix, we work with facilities managers, property teams and office occupiers across London and the South East to deliver washroom refurbishments that are compliant, practical and built to last. We are happy to advise on the implications of Part T and the wider regulatory picture for your specific building and project scope.
Get in touch to arrange a free site visit and no-obligation consultation.
