Access arrangements are the way in which awarding bodies for public examinations in England, such as the General Certificate of Secondary Education, make reasonable adjustments for students with special educational needs and disabilities. SENCos have expressed concerns about the onerous nature of managing requirements for access arrangements, both administratively and practically, but there has been little explanation of why an apparently straightforward process proves so challenging. In this study, the development of a whole-school system to improve the administrative and practical management of access arrangements is used to seek to understand how the requirements set (and re-set) annually interact with school systems and processes to render the administration of access arrangements potentially complex, time-consuming and unpredictable. Scotland's flexible, school-led framework of requirements for the management of public examination assessment arrangements is highlighted as potentially more fit-for-purpose for the organisation of statutory reasonable adjustments for educational assessment.