UK website accessibility law: the Equality Act 2010 and PSBAR

This page covers the UK's two main rules for websites and apps and links each to its official text. For other countries, see web accessibility laws worldwide, or use which accessibility laws apply to my website.

The two rules at a glance

The Equality Act 2010: the duty that reaches businesses

Under section 29 of the Equality Act 2010, a service provider "concerned with the provision of a service to the public or a section of the public (for payment or not)" must not discriminate against a person requiring the service. Section 29(7) applies the duty to make reasonable adjustments to service providers. The Act does not mention websites by name: the duty attaches to the service, and a website or app is one of the ways a service is provided.

Section 20 sets out what the duty involves. Where a provision, criterion or practice, a physical feature, or the lack of an auxiliary aid puts a disabled person "at a substantial disadvantage" compared with people who are not disabled, the provider must take "such steps as it is reasonable to have to take" to avoid it. For services, the duty is anticipatory: a business is expected to think about disabled customers in advance, not only when one complains.

What the Act does not do is name a technical standard. There is no clause saying "meet WCAG 2.1" or "meet WCAG 2.2" for a private business. Whether a site has taken reasonable steps is judged case by case. In practice, WCAG 2.2 Level AA, the standard the UK government applies to its own sector, is the clearest benchmark to build to; see which WCAG version you need.

The sections quoted here extend to England, Wales and Scotland. Northern Ireland is outside their extent, and this page does not cover the law that applies there to private businesses.

PSBAR: the public sector regulations

The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (SI 2018/952), usually called PSBAR, came into force for public sector bodies on September 23, 2018. The government's guidance, Understanding accessibility requirements for public sector bodies, says covered websites and apps must "meet the Web Content Accessibility Guidelines (WCAG) 2.2 AA accessibility standard", "although there may be valid legal reasons for not meeting accessibility standards", and publish an accessibility statement explaining how accessible they are, reviewed regularly.

Who is covered and who is exempt

• Covered: central and local government organizations, and some charities and other non-government organizations.
• Exempt: non-government organizations such as charities, unless they are mostly publicly funded, provide essential public services, or are aimed at disabled people. Public sector broadcasters and their subsidiaries are also exempt.
• Partially exempt: primary and secondary schools and nurseries, except for content people need to use their services. Partially exempt bodies must still publish an accessibility statement.

Content exemptions worth knowing

The GOV.UK guidance lists these types of content as exempt from the regulations:

• PDFs and other documents published before September 23, 2018, unless people need them to use a service.
• Pre-recorded audio and video published before September 23, 2020.
• Live audio and video.
• Heritage collections, such as scanned manuscripts.
• Maps, although essential information, such as an address, must be provided in an accessible format.
• Third-party content under someone else's control, if the body did not pay for it or develop it, such as social media "like" buttons.
• Content on intranets or extranets published before September 23, 2019, unless it has a major revision after that date.
• Archived websites, if they are not needed for the organization's services and are not updated.

The accessibility statement has to explain that exempt content has not been made accessible because it is exempt.

Disproportionate burden

A body that is not exempt can still decide that making particular content accessible would be a "disproportionate burden". The guidance says it is then "legally required to carry out an assessment", weighing the burden on the organization against the benefits for disabled users, taking into account its size and resources and the cost. Lack of time or knowledge does not count, and the body must say in its accessibility statement what it has not fixed on that basis.

Our PDF accessibility checker helps with the documents that are not exempt.

Who monitors and who enforces

According to the GOV.UK guidance, the Government Digital Service (GDS) monitors compliance on behalf of the Minister for the Cabinet Office, examining a sample of public sector websites and mobile apps every year. Enforcement sits with the Equality and Human Rights Commission (EHRC) in England, Scotland and Wales, and the Equality Commission for Northern Ireland (ECNI) in Northern Ireland.

UK businesses that sell into the EU

The UK is outside the EU, but the European Accessibility Act applies to covered products and services placed on the EU market regardless of where the provider is established. A UK online store selling to consumers in the EU should check EU accessibility law and our practical EAA guide.

What to do now

1. Work to WCAG 2.2 Level AA

   It is the standard named for the public sector, and each WCAG version keeps the earlier criteria. Our WCAG 2.2 checklist and the list of all 86 WCAG 2.2 criteria are the working references.

2. Find the problems a machine can find

   Run a free scan, then use the contrast checker, heading checker and link text checker on key templates.

3. Check what needs judgment

   Whether an image's alt text is accurate, or whether a page makes sense with a screen reader, needs more than a rule. Our alt text checker and deep audit compare the actual image with its description; why rule scanners miss issues explains the gap.

4. Publish a statement, even where it is optional

   Public sector bodies must publish one. For a business it is a simple way to show the adjustments it has made and to give people a way to report problems. Our accessibility statement generator drafts one.

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