Is Website Accessibility a Legal Requirement in the UK?

Many UK business owners assume that accessibility is only a requirement for government websites. That is only partly true. This article explains what the Equality Act 2010 says about services online, how claims and time limits work, what the public sector rules and the European Accessibility Act mean for you, and a practical plan you can start this week. For the market overview, see our UK accessibility compliance page.

What the Equality Act requires of a private website

The Equality Act does not mention WCAG or any other technical standard. What it does set out is a set of duties that can be applied to a website. Under section 29(1), a service provider “must not discriminate against a person requiring the service by not providing the person with the service”. Under section 29(7)(a), the duty to make reasonable adjustments applies to service providers too.

Section 20(3) explains that duty. Where a provision, criterion or practice puts a disabled person at a substantial disadvantage, the provider must take the steps that it is reasonable to have to take to avoid that disadvantage. The Equality and Human Rights Commission’s summary guidance on services says that a website offering services, such as online shopping, falls within this framework, and that providers should plan ahead rather than wait for a disabled person to ask for an adjustment. That guidance is a summary based on the law as it stood in 2014, so check the current Code of Practice before relying on any specific point.

In practice, the questions are concrete. Can a disabled customer complete the things your business offers online, such as booking, paying or getting in touch? And what would it reasonably cost to remove the barriers? For example, an online shop whose checkout cannot be completed with a keyboard or a screen reader may be putting disabled customers at a substantial disadvantage. Whether that is unlawful depends on the facts, including what steps were reasonable. The Act does not decide this for you, which is why evidence of what you checked and fixed matters.

Which rules apply to you: public sector, UK services or EU consumers

Three different rules are often confused. Only one of them is aimed at private businesses in the UK, and it is the general duty above. The table shows the scope of each.

The Public Sector Bodies Accessibility Regulations 2018 apply to public sector bodies, as defined in regulation 3. The 2022 amendment removed the reference to a specific WCAG version and now refers to Level A and AA. Government guidance from the Department for Education currently points to WCAG 2.2 AA. If you are a private company, these regulations do not bind you, but they show the benchmark that public bodies are held to, which many advisers use as a sensible reference point.

Claims, time limits and what a court can award

A claim under Part 3 of the Equality Act, which covers services, is brought in the county court in England and Wales or the sheriff court in Scotland. The time limit is short. Under section 118(1), proceedings may not be brought after the end of six months starting with the date of the act to which the claim relates, unless the court considers a later date just and equitable. For ongoing failures, the rules in section 118(6) and (7) treat a failure to act as occurring when the provider decided not to act, or, if no such decision can be identified, when the period in which it might reasonably have been expected to act ended.

On remedies, section 119 allows the court to award the remedies it could grant in the High Court, and damages can include compensation for injury to feelings. You will often see Vento bands cited in these discussions. They are presidential guidance for employment tribunals, and the Ninth Addendum, dated 30 March 2026, applies to claims presented on or after 6 April 2026. Law firms report the bands as lower £1,300 to £12,600, middle £12,600 to £37,700, upper £37,700 to £62,900, and exceptional above £62,900. We have not checked these figures against the judiciary’s own PDF.

A county court is not bound by the Vento guidance. Treat the bands as an indicator of how injury to feelings has been valued in employment cases, not as a cap or an expected award for a website complaint. Each case turns on its facts, including how long the barrier lasted and what the business did when it was told about it.

If you sell to EU consumers: the European Accessibility Act

Directive (EU) 2019/882, the European Accessibility Act (EAA), applies to listed services provided to consumers after 28 June 2025. The list includes e-commerce services under Article 2(2)(f). The Directive does not limit its scope by where the provider is established. On that wording, a UK business that sells covered services to consumers in the EU is likely to be in scope, subject to how each member state has implemented the rules. Law-firm commentary reads the text the same way, but confirm this with counsel for your own position.

The main exemption is for microenterprises providing services, under Article 4(5). Under Article 3(23), a microenterprise has fewer than 10 persons employed and either an annual turnover or an annual balance sheet total of no more than EUR 2 million. Enforcement is national. Article 30(2) requires member states to set penalties that are effective, proportionate and dissuasive, so the practical risk depends on which EU country your customers are in.

A practical plan for UK businesses

Accessibility is not a single test you pass. It is a sequence of steps that you can document. Work through this list in order:

1. 1Work out which rules apply. List the services you offer online and who uses them: UK consumers, EU consumers, or both. Check whether you are a microenterprise under the EAA thresholds above.
2. 2Run a baseline audit. An automated scan against WCAG 2.1 and 2.2 AA rules gives you a prioritised list of issues to start from. Automated tools catch only part of the problems, so manual testing is still needed.
3. 3Test the journeys that matter. Work through booking, checkout, account sign-in, contact forms and any document downloads using only a keyboard. Then repeat the key steps with a screen reader such as NVDA on Windows or VoiceOver on Mac and iPhone.
4. 4Fix the code and content, most serious first. Start with issues that stop a customer completing a task, such as unlabelled form fields or a checkout that cannot be used by keyboard. Cosmetic problems can follow.
5. 5Give customers a way to tell you about barriers. Publish a contact route for accessibility problems and respond to it. This is good practice rather than a named legal requirement under the Equality Act, but it helps you show that you took reasonable steps when a customer raised a problem.
6. 6Keep dated records. Save each audit report, a log of fixes, the decisions you made and the reasons for any changes you did not make. Records of reasonable steps are the evidence you will need if a claim is made.
7. 7Re-test after every major change. A redesign, a new checkout or a new plug-in can add new barriers. Review the whole site at least once a year.

Tools can support this work but do not do it for you. InclusiveWeb helps you find and fix WCAG issues and lowers risk, but automated checks catch only part of the picture. Our Autofix feature (beta) turns audit findings into fixes that you review and switch on. Our accessibility panel adds 32 tools and 8 visitor profiles to adjust contrast, text size and more, with a 7-day free trial. The panel is an extra layer on top of fixing the code, not a substitute for it.