Technically, a Disability Access Certificate is not required in advance of commencement of work. However, a person shall not carry out works in contravention of Part M of the Second Schedule to the Building Regulations 2000 or any conditions subject to which a Disability Access Certificate is granted (where a Disability Access Certificate is required). 

To avoid potentially expensive remedial work,  it would be considered good practice to apply for a Disability Access Certificate at the same time as a Fire Safety Certificate, therefore ensuring that the Disability Access Certificate and any conditions pertaining to it are set out prior to commencement of works.  

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