UK Accessibility Law and Website Accessibility Compliance

UK website accessibility law works through two main pieces of legislation, and they apply to different organisations in different ways. The Equality Act 2010 sets a general duty for both public and private sector service providers. The Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 adds a stricter, more specific set of technical requirements, but only for public sector bodies. Understanding which law applies, and what each one actually requires, is the starting point for UK website accessibility compliance.

The Equality Act 2010

The Equality Act 2010 places a duty on service providers, both public and private, to make reasonable adjustments for disabled people. This duty applies broadly across England, Scotland, and Wales, covering any organisation that provides a service to the public, including through a website.

The Act does not name a specific technical standard. Instead, it is outcome-based: if a disabled person cannot access a service because a website is hard to use, the provider may be failing its duty to make reasonable adjustments. In practice, meeting the Web Content Accessibility Guidelines (WCAG) at Level AA is treated as the benchmark for demonstrating that a website meets this duty.

Failing to meet this duty can expose an organisation to a discrimination claim, since an inaccessible website can be treated as a barrier to service in the same way a physical barrier would be.

In Northern Ireland, the equivalent legislation is the Disability Discrimination Act 1995, which places a comparable reasonable adjustment duty on service providers.

Public Sector Bodies Accessibility Regulations 2018

The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 came into force on 23 September 2018 and apply specifically to public sector organisations, including central government departments, local authorities, NHS bodies, and a wide range of other publicly funded bodies. Some non-government organisations, such as charities, are also in scope if they are mostly publicly funded or provide services that are essential to the public or aimed at disabled people. Public service broadcasters are exempt, and primary and secondary schools and nurseries are only partially exempt, meaning they still need to make content needed for essential administrative functions accessible, such as an online form for meal preferences.

The regulations require public sector websites and mobile apps to be perceivable, operable, understandable, and robust. They do not name WCAG directly, but meeting WCAG 2.2 at Level AA is how organisations meet this requirement in practice. Organisations can claim an exemption from certain requirements if meeting them would represent a “disproportionate burden,” but this requires a documented assessment weighing the cost of the change against the benefit to disabled users. Lack of time, budget prioritisation, or awareness does not qualify as a valid reason.

The Accessibility Statement Requirement

Every public sector website and mobile app in scope must publish and regularly review an accessibility statement. The statement needs to explain how accessible the site is, list any known issues, and describe how users can report accessibility problems. If an organisation has claimed a disproportionate burden exemption for any part of its site, that needs to be documented in the statement as well.

The statement for a website should be published as an HTML page on the site itself, usually linked from the footer so users can find it from any page. For mobile apps, the statement can be made available in the app store or on the organisation’s website.

Enforcement and Monitoring

The Government Digital Service (GDS), part of the Department for Science, Innovation and Technology, monitors compliance on behalf of the Minister for the Cabinet Office by examining a sample of public sector websites and apps each year. If GDS finds that a body has failed to publish an accessibility statement, or that the statement is inaccurate, it can publish the organisation’s name along with its decision.

Separately, the Equality and Human Rights Commission in England, Scotland, and Wales, and the Equality Commission for Northern Ireland, enforce the underlying accessibility requirement. An organisation that fails to meet it is treated as failing to make reasonable adjustments under the Equality Act 2010 or the Disability Discrimination Act 1995, which opens the door to investigations, unlawful act notices, and court action.

Intranets and Extranets

The regulations also cover internal intranets and extranets used by disabled employees working in or with the public sector. Intranet and extranet content published before 23 September 2019 is exempt from these requirements unless it undergoes a major revision after that date, at which point it needs to be brought into compliance.

What UK Law Actually Requires: WCAG 2.2

Current UK government guidance confirms that public sector websites and mobile apps meet their legal requirement by conforming to WCAG 2.2 at Level AA. This is a change from the position when the regulations first came into force in 2018, when WCAG 2.1 was the applicable version. As WCAG has been updated, government guidance has been updated in step, and GDS began monitoring public sector sites against the new WCAG 2.2 criteria in October 2024.

WCAG 2.2, published by the W3C in October 2023, adds several success criteria beyond WCAG 2.1, including requirements that keyboard focus is not hidden behind other content, alternatives to drag-based interactions, minimum target size for clickable elements, consistent help placement across pages, reducing redundant data entry for users completing multi-step processes, and login methods that do not rely on memory or puzzle-solving. For any organisation building or updating a public sector site, building directly to WCAG 2.2 AA avoids paying for a second round of fixes later.

Private Sector Exposure Beyond the Public Sector Regulations

The 2018 regulations do not apply to private businesses. However, private sector organisations are not exempt from accessibility obligations altogether. The Equality Act 2010’s reasonable adjustments duty applies just as much to a private retailer’s website as it does to a local council’s. A private business with an inaccessible website faces a real risk of discrimination claims, even without a specific regulation naming a technical standard.

UK Businesses Trading Into the EU

Organisations that sell into the European Union have a separate layer of obligations to consider under the European Accessibility Act, which sets accessibility requirements for certain consumer-facing products and services, including e-commerce, banking, and transport. This is EU legislation rather than UK domestic law, and it applies based on where a business trades rather than where it is based, so it is worth treating as a distinct compliance question rather than folding it into UK obligations.

What Website Accessibility Compliance Looks Like in Practice

Meeting these obligations, whether under the Equality Act or the 2018 regulations, generally comes down to the same practical steps, with the accessibility statement being a legal requirement for public sector bodies and good practice for everyone else.

Accessibility Audits

A manual audit against WCAG 2.2 AA is the most reliable way to identify where a website falls short, since automated scanning tools catch only a portion of the issues that affect real users. Automated scanners can flag straightforward errors like missing alt attributes, but they cannot judge whether alt text is genuinely descriptive or whether a keyboard trap stops someone from completing a form. A manual audit tests the site the way a disabled user actually would, using a screen reader and keyboard navigation, which produces a compliance picture that holds up under real scrutiny.

Remediation

Common issues include missing or poor alternative text, insufficient colour contrast, content that cannot be operated by keyboard alone, and missing ARIA labelling on interactive elements. Fixing these requires both structural code changes and content-level corrections, and the two often surface together. A button built as a styled <div> needs a code fix before it will be announced correctly to a screen reader, while an image labelled “image1.jpg” needs a content rewrite. Prioritising fixes by user impact matters more than working through an audit report in order, since a checkout-page keyboard trap can block a transaction entirely while a minor footer contrast issue affects far fewer users.

Publishing and Maintaining an Accessibility Statement

For public sector bodies, publishing an accessibility statement is a legal requirement, not just best practice. It needs to reflect the site’s actual current state, not a one-time snapshot from launch, and should be reviewed whenever significant changes are made. A statement that still describes issues fixed a year ago, or omits problems from a recent redesign, does not satisfy the regulations even if it was accurate at launch. It should also explain how users can report accessibility problems, since that is the mechanism the regulations rely on before issues escalate to a formal complaint.

Getting a professional accessibility audit is the most direct way to understand where a site stands against WCAG 2.2 AA and the Equality Act’s reasonable adjustments duty, and to build a remediation plan around actual findings rather than assumptions. UK accessibility law is not a one-time checklist to clear and forget. Standards evolve, sites change, and an organisation compliant at launch can drift out of compliance within a year through routine updates and redesigns. An audit gives a clear, current baseline and turns compliance from an abstract legal obligation into a concrete, prioritised set of fixes that protect both users and the organisation.