Web Accessibility Law in the UK: A Compliance Guide for Businesses

Web accessibility law in the UK requires any business serving customers online to remove barriers that put disabled people at a substantial disadvantage. The Equality Act 2010 sets that duty in Great Britain, and the Disability Discrimination Act 1995 sets it in Northern Ireland. ProfileTree builds client websites to WCAG 2.2 AA, the benchmark used to judge both.

Many owners assume the rules reach only councils and government departments, leaving private sites open to complaints from customers who cannot finish a purchase. The coding faults that block a screen reader user also tend to hold a site back in search, so the cost of ignoring the law is rarely only legal.

This guide explains which legislation applies in each part of the UK, what changed with WCAG 2.2, how enforcement works and where the commercial case lies. It closes with the practical steps for bringing a live site into line.

What Web Accessibility Law Covers in the UK

Every UK accessibility law points back to one technical standard, so it makes sense to understand that standard before reading any statute. This section explains what the standard is, how it is organised and which level a business should aim for.

WCAG Is the Standard behind the Law

The Web Content Accessibility Guidelines (WCAG) are published by the World Wide Web Consortium (W3C), the body that sets technical standards for the web. They describe how to build pages that work for people using assistive technology, meaning software or hardware such as screen readers, magnifiers and switch controls that help disabled people use a computer.

WCAG is not legislation in its own right. UK law refers to it directly for public bodies and indirectly for everyone else, because it is the obvious yardstick for deciding whether a reasonable adjustment has been made. WCAG 2.1 arrived in June 2018, and WCAG 2.2 followed on 5 October 2023 with new criteria aimed at keyboard, mobile and cognitive accessibility.

The Four Principles Every Page Has to Meet

WCAG groups its requirements under four principles, often shortened to POUR. Content must be perceivable, so images carry text alternatives, videos carry captions, and body text has a contrast ratio of at least 4.5:1 against its background. It must also be operable, which means every link, menu and form works from the keyboard alone and the selected element shows a visible focus outline.

The third principle asks for understandable content. The page declares its language so speech software pronounces words correctly, and form errors name the field at fault and explain how to correct it. The fourth, which W3C calls robust, asks for clean semantic HTML (code that labels headings, lists and buttons for what they are) so assistive technology can interpret the page today and as browsers change.

The people who rely on these principles start using assistive tools long before they become customers. LearningMole’s guide to assistive technologies in inclusive education shows how screen readers and text-to-speech software support pupils with visual impairments or dyslexia, and those pupils grow into adults who expect the same tools to work on a business website.

Why Level AA Is the Practical Target

Each WCAG criterion sits at one of three levels. Level A covers the basics, Level AA adds the requirements most disabled users depend on, and Level AAA sets a stricter bar that W3C itself advises against requiring across whole sites, because some content cannot meet it.

Level AA is what GOV.UK requires of public bodies and the level most often treated as the benchmark for private ones. For a commercial website, WCAG 2.2 AA makes the sensible target, with individual AAA criteria adopted where they cost little to meet.

Which UK Accessibility Laws Apply to Your Business

No single accessibility statute covers the whole UK. The law that applies depends on where the business operates and on whether it is a public body or sells into the European Union, and much of the published guidance gets that distinction wrong.

The Equality Act 2010 in England, Scotland and Wales

The Equality Act 2010 is the main law for private businesses in Great Britain. Section 29 makes it unlawful to discriminate against a disabled person in providing a service, and section 20 places a duty on service providers to make reasonable adjustments where a disabled customer would otherwise be put at a real disadvantage compared with other customers.

A website, an app and an online booking system are all ways of providing a service, and the Equality and Human Rights Commission (EHRC) treats them that way in its guidance for service providers. The duty is anticipatory, so a business has to plan for disabled customers in advance and cannot wait for a complaint before it acts.

Reasonableness is judged against the size and resources of the business. A sole trader with a five-page brochure site carries a lighter burden than a national retailer, but both are expected to remove barriers that are practical to remove, and an unusable checkout or contact form rarely passes that test.

The Disability Discrimination Act 1995 in Northern Ireland

Equality law is devolved, so the Equality Act 2010 largely does not extend to Northern Ireland. Private businesses there are covered by the Disability Discrimination Act 1995, as amended, which imposes the same core duties: not to treat disabled customers less favourably, and to adjust the way a service is provided so that disabled people can use it.

The Equality Commission for Northern Ireland (ECNI) gives guidance and supports complainants, the role the EHRC holds in Great Britain. For a business in Northern Ireland planning a new site, this is the Act that matters, and it belongs in any brief for web design in Northern Ireland next to the WCAG 2.2 AA target.

Public authorities in Northern Ireland carry an additional duty under Section 75 of the Northern Ireland Act 1998, which requires them to have due regard to promoting equality of opportunity, including between people with and without a disability. Suppliers to those authorities often find that duty written into their contracts.

The Public Sector Accessibility Regulations

The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 apply to public bodies across the UK, from councils and universities to NHS trusts. They require websites, intranets and apps to meet the accessibility requirements and to publish an accessibility statement explaining any content that falls short.

GOV.UK’s guidance on accessibility requirements for public sector bodies now names WCAG 2.2 AA as the standard, replacing the WCAG 2.1 AA level that applied when the regulations came in. The Government Digital Service (GDS) monitors compliance for the government, while the EHRC in Great Britain and the ECNI in Northern Ireland handle enforcement.

Private companies sit outside the regulations unless they deliver a service on behalf of a public body. The regulations still matter to them commercially, because tenders frequently ask suppliers to show that anything they build will meet the same standard.

The European Accessibility Act for Businesses Selling into the EU

The European Accessibility Act (EAA) has applied in EU member states since 28 June 2025. It covers a defined set of products and services, including e-commerce, consumer banking, ebooks and passenger transport, and it reaches UK businesses that sell those services to consumers in the Republic of Ireland or elsewhere in the EU.

The Act relies on the harmonised standard EN 301 549, which draws on WCAG 2.1 AA, so a site built to WCAG 2.2 AA is already well placed. Microenterprises providing services are exempt, and ProfileTree’s guide to the European Accessibility Act sets out the scope and the obligations in more detail. The table below summarises how the frameworks compare.

What WCAG 2.2 Changed for Business Websites

WCAG 2.2 added nine success criteria to version 2.1 and removed one, 4.1.1 Parsing, which modern browsers had made redundant. Six of the new criteria sit at Level A or AA, and they fall into groups worth checking on any existing site.

A site that passed a WCAG 2.1 AA audit in 2022 can now fail several of these criteria without a single line of its code changing, so an older accessibility report is no longer proof of compliance. The W3C summary of what is new in WCAG 2.2 lists each criterion with examples.

Focus Visibility and Sticky Headers

Focus Not Obscured (Minimum), an AA criterion numbered 2.4.11, says the element a keyboard user has selected must not be entirely hidden by other content. Sticky headers and cookie banners are the usual culprits, because they sit on top of the page and cover the focused link as the user tabs down it.

A related criterion, Focus Appearance (2.4.13), sets size and contrast rules for the focus outline. It sits at Level AAA and is not needed for AA conformance, but it is worth meeting on a business site, since a thin browser-default outline is close to invisible for people with low vision.

Target Sizes and Dragging Movements

Target Size (Minimum), criterion 2.5.8 at Level AA, asks for interactive targets of at least 24 by 24 CSS pixels, unless the targets are spaced far enough apart or an equivalent larger control exists on the page. Icon-only social links and tightly packed mobile menus are the elements that fail it most often.

Dragging Movements (2.5.7, also AA) requires a single-pointer alternative for anything that relies on dragging. A price slider or a sortable gallery needs buttons or a tap-based option as well, so that a person with a tremor or limited grip can still complete the task.

Help, Forms and Login Screens

Two Level A criteria deal with support and forms. Consistent Help (3.2.6) says contact details, a chat widget or a help link must appear in the same relative position on every page that offers them, and Redundant Entry (3.3.7) stops a multi-step form from asking again for information the user has already given, such as a delivery address re-entered at billing.

Accessible Authentication (Minimum), criterion 3.3.8 at Level AA, says a login must not depend on a cognitive test, such as recalling a password or solving a puzzle, unless an alternative or some assistance is available. Letting password managers fill the field, or offering a sign-in link by email, satisfies it, whereas a distorted-text CAPTCHA with no alternative does not.

Enforcement, Legal Risk and the Commercial Case

Formal enforcement against private websites is uncommon in the UK, yet the risk is real, and the commercial argument for accessible design is stronger than the legal one. The subsections below cover both.

How a Claim Is Brought in Each Part of the UK

In England and Wales, a disabled person who cannot use a service can bring a discrimination claim in the County Court, and in Scotland the claim goes to the Sheriff Court. The usual time limit is six months from the act complained of, and the court can award compensation, including for injury to feelings, as well as ordering the business to act.

In Northern Ireland, claims under the 1995 Act are heard by the county courts, with the ECNI able to advise and support the person bringing the claim. The EHRC can also open formal investigations in Great Britain and issue unlawful act notices, although it uses those powers sparingly.

Most disputes never reach a courtroom. A solicitor’s letter or a public complaint from a disability organisation is the more likely trigger, and an urgent fix made under that pressure usually costs more than building the site correctly in the first place.

Accessibility in Public Sector Contracts and Tenders

For agencies and software firms that supply councils and health trusts, accessibility is a commercial requirement written into the contract. Tender documents commonly ask suppliers to confirm WCAG 2.2 AA conformance and to provide an accessibility statement or audit evidence for their own work.

Consider a Northern Ireland firm that builds an appointment booking system for a health trust. If the booking screens fail keyboard testing, the trust inherits the failure under the 2018 regulations, and the supplier risks losing the contract at renewal, whereas building and testing to the standard from the first release costs far less than retrofitting it later.

Accessibility, Search Visibility and Enquiries

Accessible code and search-friendly code are largely the same code. Search engine crawlers read a page in much the way assistive software does, relying on text alternatives for images, a logical heading order, descriptive link text and HTML that labels each element properly.

A page that meets those basics is easier to index and easier for AI assistants to quote, and ProfileTree’s article on SEO and accessibility explains where the two disciplines overlap. The gain shows up in enquiries too, because a contact form that works by keyboard and gives clear error messages is easier for every visitor to complete.

Meeting the Law without Losing the Brand

Accessible design does not mean a black-and-white website. The contrast rules apply to text and to interface controls such as buttons and form borders, so a brand palette can stay distinctive as long as text sits on backgrounds with enough contrast: 4.5:1 for normal text and 3:1 for large text, meaning 18-point, or 14-point bold.

Typography follows the same logic. WCAG sets no minimum font size, but text must stay readable when zoomed to 200 per cent, which a well-built responsive layout already handles. Where design and compliance do clash, the cause is usually a development choice, such as an animation that cannot be paused or a pop-up that traps keyboard focus, and both can be fixed without touching the visual identity.

ProfileTree’s website design process sets contrast, focus styles and target sizes in the design system at the wireframe stage, so the build starts compliant and stays on brand. Ciaran Connolly, founder of ProfileTree, explains the thinking behind that approach.

“The brief I push back on most at ProfileTree is the one that starts with the design. Start with what the website has to do for the business, who in Northern Ireland has to find it and use it, including people who rely on a keyboard or a screen reader, and what you want them to do when they land. The WordPress design follows from that, and it is a better design for it.”

How to Bring an Existing Website into Line

Most businesses come to accessibility with a site already live, so the job is remediation, meaning the process of finding and fixing barriers on an existing site. The order of the work decides how quickly the site improves and how much the fixes cost.

Start with an Audit That Ranks the Fixes

An audit should combine automated scanning with manual testing, because automated tools catch only some WCAG failures and miss problems such as a confusing reading order or vague link text. Manual checks include working through every important journey by keyboard alone and testing with screen reading software such as NVDA or VoiceOver.

The output that matters is a ranked fix list with an effort estimate against each item, so the business can decide what to fix now and what to schedule. ProfileTree is a Belfast web design and digital marketing agency, founded in 2011 and based at the McSweeney Centre, and its accessibility audits are quoted on request and follow that format, starting with the journeys that produce revenue.

Those journeys differ by sector. For a law firm, they usually include the client intake form and downloadable PDF documents, both common sources of failure, while for an online retailer the checkout and any CAPTCHA on account creation come first.

Fix the Templates before the Pages

On a WordPress site, most accessibility faults live in the theme and the page builder blocks, not in individual pages. Fixing the header, menu, footer and form templates once corrects the fault everywhere those components appear, which is why the ProfileTree team starts there and leaves page-level content fixes until the shared components pass.

Where the theme itself is the problem, a rebuild can cost less than repeated patching. Targeted fixes are billed by the hour, and a new WordPress website from ProfileTree starts at £4,000 plus VAT with WCAG 2.2 AA written into the brief from the outset.

Publish an Accessibility Statement

An accessibility statement is a page that sets out the standard a website aims for, the known gaps and a contact route for anyone who meets a barrier. Public bodies must produce one in the format GOV.UK sets out, and although private businesses are not legally required to do so, a statement shows customers and tender panels that the business treats its duty with care.

The statement works best when it is candid. Listing a known issue with a planned fix date is far better than claiming full compliance that an audit would disprove, and the contact route gives the business a chance to resolve a problem before it turns into a complaint.

Train the People Who Publish Content

A compliant launch slips back within months if the people adding pages do not know the basics. Missing alt text and links that read “click here” are the faults that creep in after handover, and neither is a developer problem.

Short, practical training closes that gap. ProfileTree’s digital training covers accessible content for the editors who run a site day to day, and the basics of web accessibility guide gives teams a working checklist for scheduling regular reviews.

Getting Your Website Checked against WCAG 2.2

Web accessibility law in the UK expects every business website to work for disabled customers, whether the duty comes from the Equality Act 2010 or the Disability Discrimination Act 1995. WCAG 2.2 AA is the level to build and test against, and gaps found early are far cheaper to close than gaps found through a complaint. ProfileTree’s website development team can audit your site, rank the fixes and carry them out, so ask the team for a review.

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