UK Website Accessibility Law: Equality Act & PSBAR

The Equality Act 2010 and Websites

The Equality Act 2010 is the anti-discrimination law covering England, Wales, and Scotland; Northern Ireland relies on the Disability Discrimination Act 1995 instead. Two provisions do the work for websites. Section 29 prohibits discrimination in the provision of services. Section 20 sets the duty to make reasonable adjustments, and for service providers that duty is anticipatory: you must plan adjustments for disabled people generally, in advance, rather than reacting after an individual has already been excluded.

That anticipatory framing matters more than any technical rule. A business cannot wait for a blind customer to complain that the checkout is unusable with a screen reader; the duty exists before any specific customer arrives. An inaccessible website is, in effect, a failure to make adjustments that should already have been made.

The Act names no technical standard for websites. It is outcome-based: the legal question is whether disabled people can access the service, not whether a checklist was completed. In practice, WCAG 2.2 Level AA (previously 2.1 AA) is the de facto benchmark used by courts, regulators, and the public sector, so it is the sensible target for any UK organisation. Our WCAG 2.2 AA requirements guide explains what the standard actually asks for.

The surrounding guidance was refreshed recently: a new statutory Code of Practice for Services, Public Functions and Associations came into force on 5 August 2026, replacing the 2011 code. Courts must consider it, and it covers the reasonable adjustments duty that underpins digital accessibility claims.

What Reasonable Adjustments Mean for a Website in Practice

Because the Act is outcome-based, “reasonable adjustments” for a website translate into removing the barriers that stop disabled people completing real tasks: reading content, navigating, filling in forms, and paying. In practical terms that means the things WCAG 2.2 AA measures:

• Screen reader compatibility: meaningful alternative text, labelled form fields and buttons, and a heading structure that makes sense when heard rather than seen.
• Keyboard access: every interactive element reachable and operable without a mouse, with a visible focus indicator.
• Readable content: sufficient colour contrast, text that can be resized, and layouts that do not break when it is.
• Robust code: markup that assistive technologies can interpret reliably across browsers and devices.

The anticipatory duty means these belong in your build and procurement processes, not in a reactive fix-on-complaint queue. Working through our WCAG 2.2 checklist is a concrete way to turn the abstract duty into a task list.

PSBAR: The Public Sector Regime

For the public sector, the UK does have a prescriptive regime: the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (SI 2018/952), usually shortened to PSBAR. It requires public sector websites and mobile apps to be perceivable, operable, understandable, and robust, the four WCAG principles, and adds two administrative obligations: publishing an accessibility statement in the model format, and keeping it under review.

Compliance is actively monitored by the Government Digital Service (GDS), whose monitoring now tests against WCAG 2.2 AA. Complaints escalate to the Equality and Human Rights Commission in Great Britain or the Equality Commission for Northern Ireland. The deadlines are long past: existing websites had to comply by 23 September 2020 and mobile apps by 23 June 2021, so PSBAR is fully in force with no transition period left.

PSBAR also reaches beyond the public sector itself. Private companies selling digital products or services to public bodies face accessibility requirements in procurement, so a supplier whose product fails WCAG can lose bids even though PSBAR never names them directly.

The accessibility statement requirement trips up many teams because the model format is specific about structure and content. Our guide on how to write an accessibility statement walks through what a compliant statement needs to say.

Private Companies: Where UK Legal Pressure Actually Comes From

The UK does not look like the United States. There is no statutory per-violation damages figure like California's, and no ADA-style wave of federal filings. Individuals bring Equality Act claims in the County Court in England and Wales or the Sheriff Court in Scotland, where remedies include compensation, including for injury to feelings, plus injunctions. The Equality and Human Rights Commission (EHRC) holds its own enforcement powers on top of individual claims.

In practice, most UK matters settle privately, which is exactly why reported case law is thin. A complaint letter citing the Equality Act, followed by a negotiated settlement and a remediation commitment, is the typical shape of UK enforcement. The UK is a major venue for accessibility pressure through complaints and settlements rather than litigation counts, so the absence of headline lawsuits should not be read as an absence of risk.

Commercial pressure compounds the legal kind: public sector procurement pushes WCAG requirements onto suppliers, and large private buyers increasingly copy the practice. For how the UK regime compares with other jurisdictions, see our accessibility laws tracker.

UK Businesses and the European Accessibility Act

Post-Brexit, the European Accessibility Act does not apply domestically inside Great Britain. But UK businesses selling to consumers in the EU are in scope for those services, and the EAA applies from 28 June 2025. A UK e-commerce site shipping to EU customers, or a UK SaaS product sold to EU consumers, needs to meet EAA requirements for that part of the business, typically evidenced through EN 301 549, the European standard that maps onto WCAG.

The Northern Ireland position under the Windsor Framework is nuanced: NI businesses trading in goods with the EU face additional considerations and should take specific legal advice rather than assuming the GB position applies.

Many UK companies feel the EAA first through their Irish operations or customers; our EAA in Ireland guide covers how the directive lands in the nearest EU market.

Practical Steps for UK Organisations

1. Adopt WCAG 2.2 AA as your target. The Equality Act names no standard, but WCAG 2.2 AA is what courts, regulators, and GDS measure against, so conforming to it is the most defensible position for both private and public sector organisations.
2. Audit your key user journeys. An anticipatory duty means finding barriers before your users do. Our fixed-price WCAG 2.2 AA audits start at $950 and combine automated, manual, and screen reader testing; the sample audit report shows exactly what you would receive.
3. Publish an accessibility statement. Mandatory for public sector bodies under PSBAR, and good practice for everyone else because it evidences the anticipatory planning the Act expects. Our accessibility statement generator produces a solid starting point in minutes.
4. Fix barriers in the code, not with a widget. Overlay tools leave the underlying barriers in place, and the Equality Act cares about actual access. Our accessibility overlays guide explains why they fall short.
5. Set up a working complaints route. Most UK enforcement starts with a complaint. Make sure accessibility feedback reaches someone empowered to act quickly; a fast, genuine response often resolves matters before they become legal ones.
6. Check your EU exposure. If you sell to consumers in the EU, the European Accessibility Act applies to those services from 28 June 2025 regardless of your UK compliance position, so scope that work alongside your Equality Act efforts.

Frequently Asked Questions