The trust suspended its Access to Buildings programme, which gave grants to charities to improve their disabled access, this summer, after it realised that the Act would cause it to contravene its own grants guidance.
The guidance precludes the trust from making charitable grants that relieve the recipient of expenditure that they are "under a statutory duty to incur". Part three of the Act, introduced on 1 October, requires all organisations by law to make reasonable adjustments to improve disabled access.
The trust fast-tracked 19 such grants worth around £2m in September - four times the usual number - to ensure applicants got their money before the October cut-off.
The trust is to meet the Charity Commission this week to discuss amending the relevant clause in the guidance. Clare Thomas, the trust's chief grants officer, said: "The clause was designed to exclude statutory bodies from receiving our grants, such as state schools applying for teacher funding."
The Access to Buildings programme gave away £2.6m last year, and this year has already allocated £2.7m since April. It has advised remaining applicants to apply to the trust's Access Audit grant stream, which offers charities up to £5,000 to appraise what they must do to make their building accessible.
Lloyds TSB Foundation for England & Wales has not funded any charities this year for building work done to comply with the Act, unless applications were worded to make the upgrade part of a wider bid to help a charity meet its objectives.
"Where statutory funding starts and stops is becoming increasingly blurred," said Christine Muskett, company secretary at the foundation. "Now the Government is positively responding to charities' calls for legislation, the space for charitable funding is reducing."