Single-sex toilets: new requirements

Provision of single-sex toilets in non-domestic buildings in England is now regulated under Building Regulations. Hywel Davies explains the new requirements.

'T’ was, very conveniently, the next available letter for this addition to Schedule 1 of the Building Regulations. The Building (Amendment) (England) Regulations 2024 and Approved Document T introduce a requirement that non-residential buildings be provided with separate, single-sex toilets as the default (additional universal toilets may be provided where space permits). The amendment came into force on 1 October 2024 and applies only in England as building regulations are devolved.

The Regulations amend the Building Regulations 2010, introducing a new functional requirement, T1. This states that “toilet accommodation in buildings other than dwellings

a must consist of-
i reasonable provision for male and female single-sex toilets, or –
ii where space precludes provision of single-sex toilets, universal toilets, and may consist of universal toilets in addition to single-sex toilets.”

In these regulations “single-sex toilet” means toilet facilities that are intended for the exclusive use of persons of the same sex and provide washbasins and hand-drying facilities. These are to be located either in the toilet room or cubicle, or in a separate area intended for use only by persons of that sex.

“Universal toilet” means toilet facilities which are provided in a fully enclosed room which contains a water closet and washbasin and hand-drying facilities and is intended for individual use by persons of either sex.

Part T simplified

• non-residential buildings to have separate single-sex toilets, with single-sex shared or individual hand-washing facilities
• universal toilets can be provided in addition to single-sex provision where space allows; and
• where there is insufficient space to provide single-sex toilets, fully enclosed universal toilets should be provided.

Dwellings, en-suite facilities in individual residential rooms and care homes, premises used for early years provision, schools and cellular accommodation in custodial facilities are all exempted.

Part T does not address the number of toilets to be provided in a building. The guidance on that is elsewhere: Chapter 11 of BS 6465-4 contains a method to calculate the number of sanitary appliances for public toilets. Guidance on the number of toilets required for a building type is provided in paragraphs 4.12 to 4.14 of Approved Document G, which also covers provision of handwashing facilities.

There will be debate about what “reasonable provision of single-sex toilets” looks like. The obvious intention of the regulation is that single-sex provision is the priority, with universal allowed if space permits or in locations such as industrial units with only a single toilet. It is for building inspectors to decide what is reasonable.

The difference between a single-sex and universal toilet is minimal and so it may be that occupiers will be able to adjust the provision in line with the occupancy of their building or floor to reflect the needs of those using the facilities every day.

If you’re working on non-domestic projects, you need to be aware of Approved Document T: b.link/ApprovedDocT

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