Website accessibility in the UK sits at the intersection of two legal frameworks: the Equality Act 2010 (which applies to all businesses providing services to the public) and the Public Sector Bodies Accessibility Regulations 2018 (which apply to government and public sector websites with explicit WCAG 2.1 AA requirements). For private sector businesses, the Equality Act is the primary legal driver — and understanding what it actually requires is the starting point for a defensible accessibility position.
The Equality Act duty for service providers
Section 29 of the Equality Act 2010 prohibits service providers from discriminating against disabled people in the provision of services. Section 20 creates the "reasonable adjustments" duty — if a provision, criterion, or practice puts disabled people at a substantial disadvantage compared to non-disabled people, the service provider must take reasonable steps to avoid the disadvantage.
Applied to websites, this means: if your website is inaccessible to a person with a visual impairment, hearing impairment, motor disability, or cognitive disability, you may be failing to make a reasonable adjustment to accommodate them. The Equality and Human Rights Commission (EHRC) has confirmed in its Code of Practice that websites are covered by the service provider provisions of the Equality Act.
The "reasonable" qualifier matters. Not every accessibility improvement is legally required — the cost, practicality, and nature of the adjustment are all relevant factors. A small business with a simple brochure website has a different reasonable adjustment obligation to a large financial services company with a complex online banking portal. But reasonable is not a low bar: the courts have held that adjustments that are clearly practical and affordable but not made can constitute a failure to comply.
WCAG 2.1 AA: the UK benchmark
While the Equality Act does not prescribe a specific technical standard, WCAG 2.1 Level AA has become the de facto UK benchmark for what constitutes a reasonably accessible website in the private sector. This is based on: the public sector regulations explicitly requiring WCAG 2.1 AA; the EHRC's guidance pointing to WCAG standards; and case law and enforcement decisions that treat WCAG conformance as strong evidence of compliance with the reasonable adjustments duty.
Building to WCAG 2.1 AA therefore serves a dual purpose: it satisfies the technical accessibility requirements and creates a defensible record that you have taken reasonable steps. WCAG 2.2, published in 2023, adds further criteria (particularly around cognitive accessibility and focus management) and is increasingly considered best practice even where WCAG 2.1 remains the minimum formal requirement.
Taking a practical approach
For most UK online businesses, a practical accessibility programme consists of three parts: an initial audit to establish the current state of conformance; a remediation plan that prioritises the highest-impact barriers; and an ongoing process to maintain conformance as the site is updated. Supplement this with an accessibility statement published on your website — describing your target conformance level, the date of your last audit, any known issues and planned remediation timelines, and a contact method for users who encounter barriers. An accessibility statement demonstrates good faith and, in the event of a complaint, provides evidence that you are actively engaged with accessibility rather than ignoring it.