Website accessibility law in the UK: a guide for private businesses

Last checked: October 2026. If you run a private business in England, Scotland or Wales, the law that governs the accessibility of your website is the Equality Act 2010. It does not prescribe a technical standard, but it does require you to make reasonable adjustments so that disabled customers are not put at a substantial disadvantage – and the Equality and Human Rights Commission (EHRC) has long said that this covers websites.

Two other regimes often come up. The Public Sector Bodies Accessibility Regulations 2018 (PSBAR) set a firm WCAG standard, but for public sector bodies rather than ordinary companies. The EU’s European Accessibility Act (EAA) can matter if you sell online to consumers in EU countries. Here is how the three fit together, and what we would do on a typical business site.

It is written by a web agency as technical and practical guidance, not legal advice. If you are facing a complaint or a claim, speak to a solicitor.

Section 29 of the Act covers anyone who provides a service to the public or a section of the public, whether it is paid for or free. A service provider must not discriminate against a person who requires the service by not providing it, in the terms on which it is provided, by ending it or by subjecting them to any other detriment. Section 29 also applies the duty to make reasonable adjustments to service providers.

The three requirements

Section 20 sets out the duty in three parts. Where a provision, criterion or practice puts disabled people at a substantial disadvantage, you must take reasonable steps to avoid it. The same applies to physical features, and to providing an auxiliary aid where its absence causes that disadvantage. Under section 21, failing to comply is itself discrimination. For services, the supporting detail sits in Schedule 2.

Online, the first and third requirements do most of the work. A checkout that only works with a mouse, or a menu published only as an image, is the kind of barrier that can put disabled customers at a disadvantage.

The duty is anticipatory and continuing

The EHRC’s statutory Code of Practice for services, in its 2026 edition, describes the duty as anticipatory. You are expected to think about the barriers disabled people could face before an individual tries to use your service, and the duty applies whether or not you know that a particular customer is disabled. The Code also treats it as a continuing duty to keep under regular review, and you cannot charge disabled customers for the cost of the adjustments.

What counts as “reasonable” depends on the circumstances. The Code lists factors such as how effective a step would be, how practicable it is, its financial and other costs, the disruption it causes and the provider’s resources. A sole trader and a national retailer have very different resources, and the factors reflect that – but neither can ignore the duty.

That 2026 Code came into force on 5 August 2026, and the 2011 Code was revoked on the same date. The Code states that it does not itself impose legal obligations and is not an authoritative statement of the law, but it can be used in evidence in proceedings under the Act. It also uses a website as an example: a legal services site with all its text embedded in graphics, which visually impaired people cannot enlarge or read with text-to-speech software.

What the EHRC says about websites

The EHRC’s summary guidance for service providers says businesses should make reasonable adjustments so that their website is accessible to disabled people. Its examples include people who use text-to-speech software and people who cannot use a mouse. That guidance dates from 2014, so treat it as background rather than the latest word.

No named technical standard

PSBAR sets a technical accessibility standard, but its scope is narrow: regulation 4(1) applies the Regulations to a website or mobile application of a public sector body, and the Regulations define that term as the State, regional or local authorities, bodies governed by public law and associations of them. An ordinary company is none of these. For its website, the legal yardstick is the reasonable-adjustment duty described above.

Claims about services under the Equality Act go to the county court in England and Wales or to the sheriff in Scotland. They are brought by the person who says they were discriminated against – in a website case, typically a disabled customer who could not complete a purchase, booking or enquiry.

Under section 118, proceedings must normally start within six months of the act complained of, although the court can allow a longer period it considers just and equitable. If a claim succeeds, section 119 allows the court to award damages, which can include compensation for injured feelings, alongside other remedies.

In practice the risk starts well before court: a customer who gives up, a complaint, and remediation done in a hurry.

With a few exceptions, the Equality Act 2010 does not form part of the law of Northern Ireland, because equal opportunities and discrimination are transferred matters there. Disability discrimination in Northern Ireland is still governed by the Disability Discrimination Act 1995, which remains in force for Northern Ireland.

If you have customers there, the practical goal – a website disabled people can actually use – is the same. The legal framework is different, and the relevant equality body is the Equality Commission for Northern Ireland.

The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 apply to public sector bodies: the state, regional and local authorities, and “bodies governed by public law”. Part of that definition is being established to meet needs in the general interest, not having an industrial or commercial character. Some websites are excluded altogether: those of public service broadcasters, and those of non-governmental organisations unless their services are essential to the public or specifically meant for disabled people.

An ordinary company selling to the public is therefore generally outside PSBAR. It still matters: if you supply digital services to a council or another public body, their obligations will flow into your contract, and it is the clearest statement of what “accessible” means in UK practice.

What PSBAR requires

• Meet WCAG 2.2 level AA – the standard set out in GOV.UK guidance for public sector websites and apps. WCAG 2.2 was published on 5 October 2023.
• Publish an accessibility statement that says whether the site is fully, partially or not compliant, which parts are not accessible and why, and how users can contact you about problems.
• Publish the statement as an HTML page, ideally linked from every page (for example in the footer), and review it regularly.

Who checks

The Government Digital Service (GDS) monitors public sector websites and apps and has tested against WCAG 2.2 levels A and AA since October 2024. It passes its findings to the EHRC in England, Scotland and Wales or to the Equality Commission for Northern Ireland, which decide whether further action is needed.

One finding from GDS’s 2022–2024 monitoring report is useful for any business: colour contrast (WCAG 1.4.3) was the most common failure in its detailed tests. It is also one of the cheapest things to fix.

Directive (EU) 2019/882, the European Accessibility Act, required EU member states to apply their national accessibility rules from 28 June 2025. Its scope includes e-commerce services provided to consumers after that date, and the e-commerce obligations apply to the online sale of any product or service.

The microenterprise exemption

Microenterprises that provide services are exempt from the service accessibility requirements. The Directive defines a microenterprise as one that employs fewer than 10 persons and has an annual turnover or an annual balance sheet total of no more than €2 million. The recitals add that, to benefit, businesses must genuinely meet the criteria of the Commission’s SME Recommendation 2003/361/EC, which are aimed at preventing circumvention.

Why a UK seller may be in scope

The EAA works through national law. Each member state designates authorities to check services, handle complaints and follow up non-compliance, and sets its own penalties, which must be effective, proportionate and dissuasive. The Directive defines a service provider as anyone who provides a service on the Union market or offers to provide one to consumers in the Union; in the Directive text we checked, we found no specific exemption for providers based outside the EU.

In practice, if your shop actively sells to consumers in EU countries – euro pricing, EU delivery, local-language pages – assume the accessibility law of those countries may be applied to you, and check the national rules for your main markets with an adviser there. If you sell only to UK customers, the Equality Act remains your main concern.

Service providers under the EAA must also make information available, in an accessible form, on how their service meets the accessibility requirements. A well-written accessibility statement already does most of that job.

This is the order we would work in on a typical brochure site or online shop, whichever of the three laws applies to you.

1. Pick a benchmark: use WCAG 2.2 AA. There is no private sector standard in UK law, so the standard the government applies to its own sites is the most defensible yardstick.
2. Map your key journeys: navigation, search, product or service pages, basket and checkout, booking, contact forms and account login.
3. Test with real assistive technology: keyboard only, a screen reader such as NVDA on Windows or VoiceOver on iPhone and Mac, browser zoom and voice control. Automated scanners help, but cannot tell you whether a person can finish a task.
4. Fix the common failures first: colour contrast, missing form labels, unhelpful link text, images without text alternatives, invisible keyboard focus and error messages that are not announced.
5. Publish an accessibility statement: not required of most private businesses, but good practice. Say what you tested, what is known not to work, which alternatives exist and how to report a problem.
6. Offer and honour alternatives: make sure staff know how to handle an accessibility request quickly – the duty is anticipatory, so the process should exist before anyone asks.
7. Put accessibility into contracts: when you commission a website, theme, booking tool or payment widget, require WCAG 2.2 AA conformance, accessibility testing before sign-off and a duty to fix defects.
8. Review regularly: after redesigns, new features or a change of platform, and at least once a year.

We build websites and online shops with WCAG 2.2 AA as the default, and we can review an existing site’s key journeys, fix templates and components, and draft an accessibility statement that reflects what was actually tested. Our services page lists what that work covers.

If you want a scoped estimate for an accessibility review or rebuild, request a quote; for a quick question first, get in touch.

• Equality Act 2010, section 29 – Provision of services, etc.
• Equality Act 2010, section 20 – Duty to make adjustments
• Equality Act 2010, section 21 – Failure to comply with duty
• Equality Act 2010, section 118 – Time limits
• Equality Act 2010, section 119 – Remedies
• Equality Act 2010, section 114 – Jurisdiction
• Equality Act 2010 – Explanatory Notes, paragraph 19 (territorial extent)
• GOV.UK – Equality Act 2010: Code of Practice for services, public functions and associations, 2026 (in force 5 August 2026)
• GOV.UK – EHRC Code of Practice for services, public functions and associations, 2026 (HTML text)
• EHRC – Equality Act 2010: Summary guidance on services, public functions and associations
• Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 – Part 1
• Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 – Regulation 4
• GOV.UK – Understanding accessibility requirements for public sector bodies
• GOV.UK – Make your website or app accessible and publish an accessibility statement
• GOV.UK – Accessibility monitoring of public sector websites and mobile apps from 2022 to 2024
• Directive (EU) 2019/882 on the accessibility requirements for products and services (legislation.gov.uk copy of the EU text)