Changing Places building regulations: Part M, Part T and BS 8300-2 explained

If you are planning toilet provision for a new public building, a refurbishment or a leisure scheme, you are now working to two separate sets of rules that arrived within a few years of each other. They are easy to mix up, and meeting one does not mean you have met the other.

Approved Document M tells you whether you need to provide a Changing Places toilet at all. Approved Document T tells you how the rest of the toilet accommodation should be arranged.

We get asked about this every week, so here is a plain summary of what each one asks for and where projects tend to get caught out.

The difference between an accessible toilet and a Changing Places toilet

A standard accessible toilet, sometimes called a Doc M toilet, is designed for one person using it on their own or with a little help. It is usually around 2.2m by 1.5m.

A Changing Places toilet is a very different facility. It is designed for people who cannot use a standard accessible toilet, including people with profound and multiple learning disabilities, motor neurone disease, multiple sclerosis, cerebral palsy and spinal injuries. Many need up to two assistants with them, along with specialist equipment. Around 250,000 people in the UK rely on these facilities.

One point is worth being very clear about. A Changing Places toilet is provided in addition to your accessible toilets and baby change facilities, never instead of them. Converting an existing accessible WC into a Changing Places toilet does not make a building compliant. It makes it non compliant twice over.

Part M: which buildings need one

Amendments to Approved Document M, Volume 2 (Buildings other than dwellings) came into effect on 1 January 2021 in England. A new sub paragraph, 5.7(e), requires at least one Changing Places toilet in the following buildings:

• Assembly, recreation and entertainment buildings with a capacity of 350 or more people
• A collection of smaller buildings on one site, such as zoos, theme parks and venues for sport and exhibitions, with a capacity of 2,000 or more people
• Shopping centres, malls and retail parks with a gross floor area of 30,000m² or more
• Retail premises with a gross floor area of 2,500m² or more
• Sport and leisure buildings with a gross floor area of more than 5,000m²
• All hospitals and primary care centres
• All crematoria and cemetery buildings

"Assembly, recreation and entertainment" is defined quite broadly and covers venues such as art galleries, cinemas, concert halls, conference centres and amusement arcades. If your scheme sits close to one of these thresholds, it is worth reading the note to 5.7(e) rather than assuming.

The requirement applies to new build, extensions and material changes of use. It is not applied retrospectively to existing buildings. That is why so many town centres, parks, beaches and older leisure sites still have no provision at all, and why retrofit and modular options matter so much.

If your project is outside England, Scotland, Wales and Northern Ireland each have their own technical standards with different thresholds. Check the relevant national guidance early, because you cannot assume the rules match.

What a compliant Changing Places toilet includes

Part M points you towards BS 8300-2:2018, the code of practice for designing an accessible and inclusive built environment, along with guidance from the Changing Places Consortium.

The essentials are:

• Minimum 12m² of clear internal space, usually 3m wide by 4m long, with a ceiling height of at least 2.4m. Ceiling height matters as much as floor area, because the ceiling has to carry the hoist track.
• A full room cover ceiling tracked hoist, conforming to BS EN ISO 10535, with a safe working load of 200kg. Mobile hoists are not accepted as a substitute, because they limit flexibility and long term use.
• A height adjustable, adult sized changing bench, with a wide tear off paper roll to cover it.
• A centrally placed WC, with clear space either side for two assistants, plus drop down support rails.
• A height adjustable wash basin, with space underneath for a wheelchair.
• A privacy screen or curtain.
• A doorway with a clear opening width of 1,000mm and a level threshold. Outward opening is preferred. Where the door has to open inwards, allow an 1,800mm turning space.
• A large waste bin for disposable pads, non slip flooring, an emergency alarm, a colostomy shelf, a full length mirror and coat hooks at appropriate heights.
• A sign at the entrance showing where the nearest standard accessible toilet and baby change facility can be found.

For the reference layout, see section 18.6 and Figure 48 of BS 8300-2:2018, along with Annexes F and G.

Part T: the newer rule people are still missing

Approved Document T, covering toilet accommodation, came into force on 1 October 2024. It applies in England to new buildings other than dwellings, and to buildings undergoing a material change of use.

Part T came about because of concerns around privacy, dignity and safety as publicly accessible toilets were increasingly converted into shared, gender neutral facilities. In short, it requires toilet accommodation in non residential buildings to be provided as separate single sex facilities with single sex hand washing. Universal toilets, which are fully enclosed and self contained, can be provided as well where space allows.

The document sets out four types:

• Type A, a fully enclosed self contained ambulant universal toilet
• Type B, a fully enclosed self contained universal toilet
• Type C, an ambulant single sex cubicle that is not self contained
• Type D, a single sex cubicle that is not self contained

Two things are worth being clear on.

First, a universal toilet under Part T is not a wheelchair accessible toilet, and it is definitely not a Changing Places toilet. Your Part M obligations sit entirely separately and are not affected.

Second, Part T does not set the number of toilets you need. That is still a Part G and BS 6465-1 calculation, alongside sector guidance such as Sport England's, the Workplace (Health, Safety and Welfare) Regulations ACOP, or NHS England's HBN 00-02. Part T also does not apply to schools or early years settings, which have their own premises regulations.

For public toilet schemes, the practical effect is space. Part T tends to increase the floor area needed for toilet cores. When a scheme has to satisfy Part T and also accommodate a 12m² Changing Places facility, the overall footprint can end up considerably larger than expected at feasibility stage. In our experience that is one of the most common reasons projects stall between concept and planning.

Five things that catch projects out

Finding out too late. The Changing Places requirement often gets picked up at building control stage, by which point the footprint, drainage and structure are already fixed. Ceiling height in particular is expensive to change late in the day.

Under specifying the hoist. A wall mounted or mobile hoist will not meet the standard. You need full room ceiling track coverage and a structural fixing designed for a 200kg safe working load.

Treating it as a replacement. It is an addition. Your existing accessible and baby change provision has to stay.

Forgetting the running costs. Cleaning, maintenance, hoist servicing and equipment inspection are ongoing commitments rather than one off costs. Where grant funding has been involved, authorities have generally had to certify that revenue funding is in place for the lifetime of the asset.

Not registering the facility. Once it is built and approved, register it so it appears on the national map and families can actually find it. An unregistered facility is invisible to the people it was built for. You can register through the Changing Places Consortium.

What if the building already exists?

Most of the gaps in the UK are in existing buildings and open public spaces, where Part M does not apply retrospectively but the need is greatest. Seaside towns, country parks, high streets, transport hubs and National Park sites all fall into this category.

There are usually two routes.

Internal adaptation works where you can find or combine 12m² with 2.4m of ceiling height, and where the structure will take a hoist track. It is often the cheapest option in principle and the most disruptive in practice.

A modular Changing Places building is manufactured off site and installed as a complete unit. It can stand alone, form part of a wider modular toilet block, or connect to an existing building through an internal door. Because it is built in our factory to a known specification, compliance is designed in from the start rather than worked out on site, and installation takes weeks rather than months. For parks, beaches, coastal sites, listed buildings and anywhere the existing structure cannot be altered, it is usually the only realistic option.

Common questions

Is a Changing Places toilet a legal requirement?

In England, yes, for the building types and thresholds listed in paragraph 5.7(e) of Approved Document M, Volume 2. This applies to new build, extensions and material changes of use since 1 January 2021. It is not applied retrospectively to existing buildings.

How big does a Changing Places toilet need to be?

A minimum of 12m² of clear internal space, usually 3m by 4m, with a ceiling height of at least 2.4m.

What is the difference between a Changing Places toilet and a Space to Change facility?

A Space to Change facility is a smaller solution, typically around 7.5m², that adds an adult sized changing bench and a hoist to an existing accessible toilet. It does not meet the full Changing Places standard and cannot be registered as one, but it can make a real difference on sites where 12m² genuinely is not available.

Does Approved Document T replace Approved Document M?

No. They cover different things. Part T deals with single sex and universal toilet provision. Part M deals with accessible and Changing Places provision. A compliant scheme meets both.

Do the same rules apply in Scotland, Wales and Northern Ireland?

No. Each has its own technical standards, so check the relevant national guidance at the start of your project.

We can help you get it right first time

We have been building public toilets since 1969, and we manufacture our Changing Places modular buildings here in the UK. That gives us full control over the build and means compliance is built in rather than bolted on. We have delivered Changing Places facilities for local authorities and National Park authorities across the UK and Ireland, and we look after them afterwards through our cleaning and maintenance service.

If you are at feasibility stage and want to know what your site can realistically take, or you have a Part M requirement and a footprint that will not accommodate a traditional build, we would be glad to talk it through.

Planning a project in Scotland? Read our guide to Changing Places Toilets in Scotland.