UK accessibility laws: Equality Act 2010, PSBAR 2018 & WCAG

What accessibility laws apply in the UK?

The Equality Act 2010 sets a general duty to make reasonable adjustments and applies across virtually every organisation that provides a service to the public, online or offline. The Public Sector Bodies Accessibility Regulations 2018 adds a specific, technical layer on top of that duty, but only for public sector websites and apps. The European Accessibility Act, by contrast, is EU legislation that UK organisations only need to worry about if they're selling into the EU market.

Each of the three works differently enough that bundling them causes real confusion. A private UK retailer is bound by the Equality Act but not by the 2018 regulations, while a UK public sector body is bound by both.

What is the Equality Act 2010, and how does it affect digital accessibility?

The Equality Act 2010 treats a website or app as a "service," so the same duty that applies to a physical shop or office applies to it: organisations have to make reasonable adjustments so a person with a disability can use the service on an equal footing with everyone else. Section 20 makes this an anticipatory duty — the adjustment has to be made in advance, not only after a specific complaint arrives.

A business that waits for a customer with a disability to complain about an inaccessible checkout form before fixing it is already out of step with the law, because the duty exists to prevent the barrier, not just respond to it.

The Act doesn't name WCAG or any technical standard directly. Courts and the EHRC have consistently treated WCAG conformance as the practical evidence of having met the duty, which is why compliance work still gets measured against WCAG even though the Act itself is standard-agnostic. It applies in England, Scotland, and Wales; Northern Ireland has equivalent protection under the Disability Discrimination Act 1995.

What are the Public Sector Bodies Accessibility Regulations 2018?

These regulations add a specific, enforceable requirement on top of the Equality Act, but only for public sector organisations — central government departments, local authorities, NHS bodies, and most publicly funded organisations. They came into force on 23 September 2018, transposing a pre-Brexit EU directive, and their phased deadlines for existing websites and apps have all now passed.

The regulations define the "accessibility requirement" in functional terms — perceivable, operable, understandable, robust — without naming WCAG by version. In practice, meeting WCAG 2.2 at levels A and AA is treated as satisfying that requirement, which is why UK government guidance points teams straight at WCAG 2.2 AA.

Covered bodies also have to publish and maintain an accessibility statement. The Central Digital and Data Office (CDDO) monitors compliance by testing public sector sites and apps directly, and the Equality and Human Rights Commission (EHRC), or the Equality Commission for Northern Ireland, handles enforcement when a body falls short.

Does the European Accessibility Act apply in the UK?

Not directly. The EAA is EU legislation, and the UK left the EU before it became applicable, so no UK regulator enforces it against a purely domestic UK business. Both frameworks share the same underlying goal but diverge sharply in scope: the EAA reaches specific sectors — e-commerce, banking, transport ticketing — with binding technical requirements, while the UK relies on the broader, standard-agnostic reasonable-adjustments duty in the Equality Act.

The distinction that matters for a UK organisation is whether it sells into the EU market. A UK e-commerce business with EU customers, or a UK company with an EU subsidiary offering covered services, can still fall within the EAA's scope for that part of its operation, since the EAA applies based on where a product or service is offered, not where the company is headquartered.

A UK-only service with no EU customers has no EAA exposure at all, regardless of how large or well-known the organisation is domestically.

Who must comply

Compliance splits cleanly along one line: whether an organisation is a public sector body. Public sector organisations carry both the Equality Act duty and the 2018 regulations' technical requirements; private businesses carry only the former.

• Public sector bodies — central government departments, local authorities, NHS trusts, state schools and universities, and most publicly funded organisations, directly named in the 2018 regulations
• Exemptions under the 2018 regulations — some pre-existing file formats, live audio/video content, and cases assessed (and documented) as a genuine "disproportionate burden"
• Broadcasters and some third-sector organisations that don't perform a public function sit outside the regulations' direct scope, though the Equality Act can still cover them
• Private businesses — not named in the 2018 regulations, but bound by the Equality Act's reasonable-adjustments duty the moment they provide a service to the public, covering essentially every commercial website and app

How WCAG defines accessibility, and what level is required

Neither UK law names a WCAG version, but WCAG is still the standard every compliance conversation ends up at.

Perceivable

Information has to reach the user through some sense they can use — a product video with no captions fails this for a deaf user.

Operable

Every function has to work without a mouse — a pointer-only interface excludes anyone navigating by keyboard or switch device.

Understandable

Content and behaviour have to be predictable — inconsistent form submission behaviour breaks this even though nothing is technically broken.

Robust

Code has to be interpreted reliably by assistive technology — a styled div element acting as a button fails this even if it looks fine to a sighted mouse user.

For public sector bodies, WCAG 2.2 AA is the practical benchmark for the 2018 regulations' requirement, even though the regulations don't name that version. For private businesses, no regulation specifies a level at all — but WCAG 2.2 AA has still become the de facto benchmark, since it's what courts and the EHRC point to as evidence of meeting the Equality Act duty.

What is an accessibility statement, and why is it required?

A published document describing how accessible a site or app currently is, what isn't yet accessible, and how a user can report a problem. Public sector bodies are legally required to publish one under the 2018 regulations; private businesses aren't required to, but it's still treated as good practice.

• Current conformance status — which WCAG success criteria the site meets, and which it doesn't, not a blanket claim
• Non-accessible content, named specifically — which pages, documents, or features fall short, and why
• A contact method — to report a problem or request content in an alternative format
• A link to the enforcement procedure — for public sector statements, directing an unresolved complaint to the Equality Advisory and Support Service (EASS)

For a public sector body, the CDDO can publicly name an organisation that hasn't published a statement or hasn't kept it accurate, feeding into the EHRC's enforcement process. For a private business, there's no direct penalty tied to the statement itself — but without one, a business has no documented evidence of accessibility effort to point to if a discrimination claim arrives.

How organisations ensure compliance

Automated scanning catches structural issues quickly — missing alt text, insufficient contrast, missing form labels — but only surfaces a fraction of WCAG failures. Manual testing fills that gap: navigating with only a keyboard, and separately with a screen reader, catches what requires human judgement. If testing sampled a representative set of pages rather than every page, the report needs to say so explicitly.

Not every issue gets fixed on the same timeline — the deciding factor is impact on a real user. A blocked core task (an unreachable checkout button, a login form with no focus indicator) gets fixed immediately; friction-but-workaround issues get scheduled into normal development. The more durable answer is building accessibility checks into design and development workflows themselves, rather than only ever auditing and remediating after the fact.

The CDDO monitors public sector websites and apps directly, testing against the accessibility requirement and checking statements are published and accurate. The EHRC (or the Equality Commission for Northern Ireland) handles enforcement — investigating, issuing formal notices, or pursuing court action — covering both public sector regulation breaches and general Equality Act claims against private businesses.

What happens when organisations don't meet accessibility requirements

The EHRC can open a formal investigation, issue an unlawful act notice requiring corrective action, or apply for a court injunction — powers that apply to public sector regulation breaches and private sector Equality Act failures alike. Persons with disabilities also have a separate route: they can bring a discrimination claim directly in the county court without going through the EHRC first, and damages have no statutory upper limit.

A documented example: a blind student took legal action against the Student Loans Company after an online form for the Disabled Students' Allowance couldn't be completed with a screen reader. The case was resolved with a financial settlement, and the organisation subsequently fixed the form — illustrating that the exposure isn't hypothetical, and doesn't require a regulator to act first.

Frequently asked questions

Is accessibility a legal requirement in the UK?

Yes — the Equality Act 2010 already requires every organisation providing a public-facing service to make reasonable adjustments, which extends to websites and apps. The duty has applied since 2010, so an organisation that hasn't addressed digital accessibility yet is already potentially exposed.

Is WCAG 2.2 a legal requirement in the UK?

Not by name — neither the Equality Act nor the 2018 regulations name WCAG 2.2 directly. In practice, meeting WCAG 2.2 AA is treated as the strongest available evidence of compliance by regulators and courts.

Who is exempt from accessibility regulations?

Under the 2018 regulations, some pre-existing file formats, live audio and video content, and cases assessed as a genuine "disproportionate burden" fall outside the direct requirement. The Equality Act's broader duty has far fewer carve-outs.

What is the "new" accessibility law in the UK?

There isn't a new standalone UK accessibility law — the framework is still the Equality Act 2010 and the 2018 regulations. The more significant recent development sits outside UK law: the EU's European Accessibility Act, which affects UK businesses only to the extent they sell into the EU market.

What are the rules for disabled access in the UK, for digital services?

Reasonable adjustments under the Equality Act for everyone, plus the specific WCAG-aligned technical requirement and accessibility statement obligation under the 2018 regulations for public sector bodies.

What are common WCAG violations?

Missing or inaccurate alt text, insufficient colour contrast, custom components like dropdowns and modals that can't be operated by keyboard, and form fields without properly associated labels — largely because each involves a custom-built component rather than a native HTML element.

What happens if an organisation does not comply?

The EHRC can investigate, issue an unlawful act notice, or pursue court action, and a person with a disability can separately bring a discrimination claim with no statutory cap on damages. Public sector bodies can also be publicly named by the CDDO as part of its ongoing monitoring.