Summary: Mr X complained the Council has failed to make appropriate reasonable adjustments to enable him to renew his blue badge. And that it failed to communicate with him in line with agreed reasonable adjustments. We found the Council’s failure to properly consider Mr X’s request for reasonable adjustments regarding his blue badge renewal is fault. As is the Council’s failure to ensure its records were correct and up to date. These faults have caused Mr X unnecessary difficulties, distress and frustration. The Council will apologise and make a payment to Mr X. It will also work with Mr X to verify his identity and update its records.

The complaint

1. Mr X complained the Council has failed to make appropriate reasonable adjustments to enable him to renew his blue badge. Mr X says he is blind and housebound and only leaves the house to attend unavoidable hospital appointments/procedures where there are no alternatives. Without a blue badge attending hospital appointments has been very difficult.
2. Mr X also complained the Council has failed to send copies of its letters on an audio CD and did not return his call as arranged.

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The Ombudsman’s role and powers

3. We investigate complaints about ‘maladministration’ and ‘service failure’. In this statement, I have used the word fault to refer to these. We must also consider whether any fault has had an adverse impact on the person making the complaint. I refer to this as ‘injustice’. If there has been fault which has caused significant injustice, or that could cause injustice to others in the future we may suggest a remedy. (Local Government Act 1974, sections 26(1) and 26A(1), as amended)
4. If we are satisfied with an organisation’s actions or proposed actions, we can complete our investigation and issue a decision statement. (Local Government Act 1974, section 30(1B) and 34H(1), as amended)

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How I considered this complaint

5. I considered information provided by Mr X and the Council as well as relevant law, policy and guidance.
6. Mr X and the Council had an opportunity to comment on my draft decision. I considered any comments before making a final decision.

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What I found

Relevant law and guidance

7. The reasonable adjustment duty is set out in the Equality Act 2010 and applies to organisations which carry out a public function. Service providers are under a positive and proactive duty to take steps to remove or prevent obstacles to accessing their service. If the adjustments are reasonable, they must make them. The duty is 'anticipatory'. This means service providers cannot wait until a disabled person wants to use their services and they must think in advance about what disabled people with a range of impairments might reasonably need.
8. Our Principles of Good Administrative Practice set out our expectations of councils. We expect councils to be citizen focussed. This means they need to:
• Ensure people can access services easily
• Respond to needs flexibly
• Adopt an inclusive approach.
9. We cannot decide if an organisation has breached the Equality Act as this can only be done by the courts. But we can make decisions about whether or not an organisation has properly taken account of an individual’s rights in its treatment of them.
10. A blue badge allows people with disabilities to park closer to their destination for free. Department for Transport (DfT) guidance on blue badges (Blue Badge Scheme Local Authority Guidance (England) May 2022) includes advice for councils on how to assess eligibility and the checks it should carry out to prevent abuse of the scheme.
11. To apply for a blue badge applicants must provide:
• Proof of identity;
• Proof of address;
• A recent photograph;
• Their national insurance number; and
• Contact details

What happened here

12. Mr X has had a blue badge for many years. When Mr X applied to renew his blue badge in 2025 the Council confirmed he was eligible without further assessment and asked him to provide proof of identity and a current photograph.
13. Mr X complained that in asking him to provide proof of identity and a photograph the Council had failed to fully consider his agreed reasonable adjustments or the Equality Act 2010. Mr X said that following a previous complaint to the Ombudsman the Council had agreed it would not require him to provide proof of identity in the future. He also asserted that requiring him to obtain a photograph and identification was contrary to the Equality Act. Mr X wanted the Council to make a reasonable exception to its normal working procedures by working with him to find other ways to meet their requirements.
14. Mr X wanted the Council to use the photograph on his current blue badge for his new badge and to not require him to provide evidence of identification.
15. The Council responded to Mr X’s complaint in early August 2025. It explained that over the last 12 to 18 months its blue badge service had been through a process of improvement and redesign. It had identified that its previous ways of working were not as robust as the DfT guidance recommends. This left its practices open to risk of an increased level of blue badge fraud and misuse.
16. The Council had not previously required a new photograph at each application as long as the previous photograph remained suitable. Under its new operating procedures the Council now required all applicants to provide a photograph that complied with The Disabled Persons (Badges for Motor Vehicles) (England) (Amendment) No.2 Regulations 2011. It said the photograph used in Mr X’s previous blue badge did not meet the requirement of being “taken within the month prior to the date of the application.”
17. The Council recognised it may be difficult for Mr X to take his own photograph. While the Council does not offer an in-person service to take photographs of applications, it confirmed it could arrange this for Mr X as a reasonable adjustment. The Council said it could arrange for someone to meet Mr X at one of its customer service access points to take his photograph.
18. In relation to Mr X’s identification, the Council said it was previously able to access a system used by another Council service to verify his identity. However the system had been decommissioned and the replacement system could not be used for this purpose. The Council also told Mr X it could not locate an earlier email committing the Council to not requiring evidence of his identification.
19. The Council suggested an alternative reasonable adjustment of allowing flexibility on the type of identification Mr X could provide. It said if Mr X could not provide any of the identification types set out in its blue badge policy, he could suggest an alternative and provide it when he visited to have his photograph taken. The Council would then scan and upload this together with Mr X’s photograph to his application.
20. It said that where individuals inform the Council of their needs it makes every attempt at supporting them whilst remaining compliant with its verification requirements.
21. The Council said it did not deem it a reasonable adjustment to exclude Mr X from the regulations that govern the blue badge scheme. But it was committed to ensuring he was supported in the application process.
22. A council officer telephoned Mr X to read the Council’s response to him. Mr X was not satisfied with the Council’s response and was concerned the Council had not acknowledged the impact on his health during this process. He requested a hard copy of the response letter and an audio CD with a recording of the letter so that he could consider the matter before escalating his complaint to stage two of the complaint process. Mr X asked for a call back on 4 September 2025 so that he could provide his response and escalate his complaint.
23. The Council did not call Mr X on 4 September 2025 so Mr X contacted the Council. Mr X was unhappy the Council had not called him and that it sent him an email to inform him of an extension of its response time, contrary to his agreed reasonable adjustments. The Council sent Mr X a further email on 8 September 2025 advising that use of email to communicate short basic information was agreed as a reasonable adjustment. It therefore considered it was appropriate for the Council to contact Mr X by email.
24. The Council then responded at stage two of the complaints process on 18 September 2025. The stage two investigation supported the conclusions of the stage 1 investigation.
25. Mr X remains dissatisfied and has asked the Ombudsman to investigate his concerns. Mr X says he only needs the blue badge to get to the hospital. And that the people who help him find it difficult to park and assist him without a blue badge. Mr X says the situation has had a detrimental effect on his health and is causing him distress. Mr X also complained he had not received an audio CD with the complaint response of 7 August 2025, and that the Council had failed to call him on 4 September 2025 as agreed.
26. In response to my enquiries the Council says it agreed a series of reasonable adjustments with Mr X in April 2023. It has also agreed additional reasonable adjustments for the blue badge service to support him in navigating the process. In relation to the blue badge process the Council has:
• enabled Mr X to apply for a blue badge over the phone, which is not a service it provides for all customers;
• communicated with the hospital’s parking team to ensure Mr X is not penalised for parking in a disabled parking space with an expired badge when visiting the hospital. This is not something it does for all customers. The Council’s records show that when it told Mr X of this arrangement he was concerned he was too much to deal with. Mr X already had a lot of contact with the hospital and found phone calls difficult as he cannot write down telephone numbers so has to remember them. He was however happy for the officer to liaise with the hospital and to provide Mr X’s contact details so that the parking manager would contact him.
• ensured that throughout the complaint process, all responses have been provided in audio format in line with his reasonable adjustments. It has also provided the complaint responses over the telephone so that Mr X receives them quicker.
• offered for Mr X to provide identification outside its exhaustive list of ID types as he is struggling with providing proof of identification;
• offered a home visit on multiple occasions by its Sight and Hearing team to take his photograph and obtain his proof of identification without Mr X needing to attend a customer access point.
27. The Council says it was unaware when responding to Mr X’s complaint in August 2025 that Mr X was housebound. Had it been, the Council would not have suggested Mr X attend a customer service access point. The Council says Mr X’s blue badge application was made on the basis he is registered blind. As being registered blind meant Mr X automatically qualified for the blue badge scheme, it was not necessary to ask additional medical or health questions.
28. The Council says it identified Mr X was housebound following his contact with its adult social care helpdesk on 15 September 2025. The Council’s records show Mr X contacted the Council on 15 September 2025 to ask that a social worker visit to take photographs of himself and his wife for their blue badges. He told the Council they both have significant medical conditions, could not work technology, and did not have any support locally. Mr X also said he and his wife were housebound so could not go out to have their photograph taken.
29. An officer from the Council’s Sight and Hearing team contacted Mr X to arrange to visit him to take the photograph and verify his proof of identity. The records show Mr X told the officer finding documents to prove his identity would be difficult. As Mr X is blind, and his wife has other medical conditions they would need someone to look through their drawers for the documents which Mr X felt would be unacceptable. The officer arranged to visit Mr X on 17 October 2025. Mr X subsequently asked the officer not to visit at that time as his wife was in hospital. The officer agreed to call Mr X again in one month’s time. Mr X and his wife’s personal circumstances have meant the visit has not yet been rearranged.
30. The Council says that while it can and does use Council Tax records and the Electoral Register to verify an individual’s residency, it cannot use these systems to verify identity. It says it had previously used a legacy adult social care system to verify Mr X’s identity. However this system has been decommissioned and the replacement system does not contain any verification the person is who they say they are.
31. In addition the Council says that to comply with the General Data Protection Regulations its systems apply an automatic data retention policy. This automatically deletes any previous evidence so information from Mr X’s previous blue badges is no longer available.
32. Mr X maintains the Council has not made appropriate reasonable adjustments. He has provided copies of correspondence from the Council confirming the arrangements it had agreed regarding Mr X’s proof of identity in 2023 and confirming the Council has been aware since at least 2022 that he is housebound.
33. These documents show that on 28 July 2023 a council officer set up a unique reference code which the officer and Mr X could use to enable the Council to verify Mr X’s identity to a third party. This system would allow the Council to confirm Mr X’s name and address to another agency seeking to verify his identity. Mr X is disappointed that the Council was unable to locate this email and that he has had to rely on others to assist him in providing it. And that the Council does not have a wider record of this agreement so that all services are aware.
34. Mr X says he has offered several alternative methods for verifying his identity which have been used by other organisations, but the Council has refused.
35. Mr X has also provided copies of previous complaints he has made to the Council in August 2022, 17 February 2023, and June 2023. In each case Mr X has dictated his complaint to a council officer who has written this up and emailed a copy to him. As these complaints all refer to Mr X being housebound Mr X disputes the Council was unaware until September 2025.
36. In addition Mr X has provided a transcript of a call between himself and a council officer in August 2024. This record notes that the email address previously used by the Council to contact Mr X was no longer available and cannot be used. Mr X complains the Council has failed to update its record of his agreed reasonable adjustments and wrongly contacted him by email in September 2025.

Analysis

37. It is not the Ombudsman’s role to decide whether Mr X’s requests for adjustments were reasonable, or whether the Council could offer alternative adjustments. But we can look at how the Council considered the requests for reasonable adjustments.
38. The Council has previously allowed Mr X to renew his blue badge without providing evidence of his identity or a new photograph. This was clearly beneficial to Mr X but was not in line with the relevant legislation or guidance.
39. We expect councils to abide by the statutory and legislative requirements and guidance and would not criticise the Council for reviewing and amending its procedures to ensure they are compliant. However, we would also expect the Council to make appropriate adjustments to ensure that any changes in its procedures do not place people with disabilities at a substantial disadvantage.
40. It is clear the Council has made a number of reasonable adjustments in relation to its communication with Mr X and in enabling him to renew his blue badge over the telephone.
41. It has also considered Mr X’s request to use an old photograph and to not require him to provide proof of his identity. The Council did not agree to Mr X’s requests as it did not consider it was a reasonable adjustment to exclude him from the regulations that govern the blue badge scheme. It instead offered alternative adjustments.
42. The initial offer to take Mr X’s photograph and view his proof of identity at a customer service access point was not appropriate as the Council was or should have been aware that Mr X and his wife are housebound. Mr X had informed the Council he had a number of serious health conditions and was housebound in multiple contacts with the Council over previous years and this should have been noted.
43. The Council subsequently agreed to arrange for an officer to visit Mr X at home. This is an appropriate response. Mr X and his wife’s personal circumstances meant this visit had to be postponed and has not yet taken place. I consider the Council should liaise with Mr X to arrange an appropriate visit.
44. The Council also contacted the hospital to ensure Mr X could still park in a disabled bay with his expired blue badge while applying for a new one. This is also an appropriate adjustment.
45. There is no record of how the Council has considered Mr X’s suggested alternative methods for verifying his, and his wife’s identity. I consider the Council should have explored this issue further, and the failure to do so is fault. Particularly as Mr X and his wife are unable to look for or locate any of the accepted documents or even a wider range of written documents to prove their identity. For the Council to view any documents while visiting Mr X’s home to take their photographs the officer would first need to find an appropriate document by looking through their drawers. This suggestion understandably causes Mr X concern.
46. The Council’s failure to keep an up to date record of agreed reasonable adjustments for its communication with Mr X is also fault. Mr X had informed the Council he is no longer able to access emails and that this form of contact was not to be used after August 2024. Yet the Council’s records still show emails can be used for short communications, and as a result officers sent Mr X emails in September 2025. The Council should immediately update its records.
47. The Council has provided evidence a recording of the stage one complaint response of 7 August 2025 was made and dispatched to Mr X on 29 September 2025. It is therefore unclear why Mr X has not received a copy, but I do not consider this to be due to fault by the Council. Mr X has confirmed that as matters have moved on he no longer requires a recording of the complaint response.
48. However the failure to call Mr X on 4 September 2025 was fault. The Council’s notes clearly record Mr X’s request for a call on 4 September 2025. Mr X wanted to discuss his concerns and escalate his complaint once he had received and had an opportunity to consider the recording of the stage one response. The Council accepts Mr X requested a call but says the records to not confirm this was agreed. It does not therefore consider it was at fault. I disagree. If the Council was unable to agree to Mr X’s request for a call on 4 September 2025, it should have told him and offered alternative arrangements for Mr X to discuss his concerns. The Council completed the stage two complaint process without affording Mr X the opportunity to discuss his concerns. This is fault.
49. These faults have caused Mr X unnecessary difficulties, distress and frustration. The Council should make a symbolic payment to recognise this.
50. We would generally recommend the Council apologise for the faults identified and the injustice this has caused. However Mr X does not want an apology. He says the Council has apologised for failings in its service and in its record keeping in the past, but the issues have continued.

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Action

51. The Council will:
• Pay Mr X £300 to recognise the difficulties, distress and frustration he has experienced as a result of the faults identified;
• Discuss and agree with Mr X an appropriate means of verifying his and his wife’s identity;
• Arrange with Mr X a home visit to take his and his wife’s photograph, taking account of their current sensitive circumstances, in order to progress their applications to renew their blue badge.
• Ensure the Council’s records correctly reflect Mr X’s reasonable adjustments for communication and service provision.
52. The Council should take this action within one month of the final decision on this complaint and provide us with evidence it has complied with the above actions.

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Decision

53. I find fault causing injustice. The Council has agreed actions to remedy injustice.

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Investigator's decision on behalf of the Ombudsman