Equality Act 2010 · public sector regulations · WCAG 2.2 AA in procurement
The UK position: no single web law, and a duty that still binds you.
British businesses often conclude there is nothing to comply with, because no statute says websites must meet WCAG. The conclusion is wrong in a way that only becomes visible in two places: a tender that scores you on accessibility, and a claim brought by somebody who could not use your service. This page sets out what the Equality Act actually asks of a digital service, what the public sector regulations add, what buyers require in practice, and what evidence looks like.
Signed by REP27 LTD, company number 17385889.
Two regimes, not one
Most confusion in the UK comes from treating one set of rules as if it covered everybody. It does not: the private and public sectors sit under different instruments, with different triggers and different consequences.
| Private sector | Public sector | |
|---|---|---|
| Instrument | Equality Act 2010 | 2018 accessibility regulations |
| Obligation | Reasonable adjustments, anticipatory | Conformance to the standard, with exceptions |
| Statement | Not prescribed, expected in practice | Prescribed form and content |
| Standard | WCAG 2.2 AA by convention | Named in guidance |
| Enforcement | Individual claims, procurement scoring | Monitoring body and reporting |
| Practical trigger | A tender or a complaint | A monitoring cycle |
A private company supplying the public sector effectively inherits the second column through the contract, which is why so many accessibility questions arrive attached to a procurement pack rather than from a regulator.
What makes the Equality Act unusual online
Two features change how the duty behaves on a website. The first is that it is anticipatory: a service provider is expected to consider in advance what disabled people will need, not to wait for a request. On a physical premises that means thinking about the step at the entrance before somebody arrives at it. Online it means testing the checkout before the customer who uses a screen reader finds it.
The second is that the test is reasonableness, which is contextual rather than absolute. Size, resources, the cost of the change and the effect of the disadvantage all matter. That cuts both ways: a small firm is not expected to rebuild its platform, and a large retailer is not excused for leaving an unlabelled payment button in place for two years because nobody escalated it.
What both features reward is the same thing: knowing what your barriers are, having made a considered decision about each, and being able to show when you did it.
What buyers ask for, in order
- A WCAG conformance report, dated, naming the version and level, and stating how testing was carried out.
- Who tested it. External testing scores better than self-assessment, and a named company better than an anonymous tool.
- Known issues. Honest lists score higher than blanket claims, because blanket claims are checked and fail.
- A remediation plan with dates, which turns open findings into a managed position rather than an unanswered question.
- A route for users to report problems, with a response time you actually meet.
These are the same five elements that make a good accessibility statement, which is why the two documents come out of one audit. The formats differ; the underlying evidence does not, as described on the VPAT comparison page.
If a complaint arrives
The sequence is usually informal before it is formal: an email, sometimes from the person, sometimes from a charity or an advocate acting for them. What happens next depends almost entirely on the answer.
An answer that acknowledges the barrier, offers an alternative route to complete the task now, gives a date for the fix and references the testing already underway generally ends the matter. An answer that denies the problem, or that arrives three weeks late because nobody owns the mailbox, converts a technical issue into a dispute about how the organisation treats disabled customers, which is a much worse conversation and a much more expensive one.
This is why the hosted feedback channel is part of the plan rather than an extra. A route that reaches a named person quickly is worth more than any paragraph in a statement.
What we do for a British company
REP27 LTD, registered in England under company number 17385889, signs the UK report. The testing is the manual audit described on the audit page: keyboard, screen reader, contrast, forms, zoom and reflow across the flows that matter to your business, with a written findings report and a conformance position against WCAG 2.2 AA.
Alongside it you receive the public statement if you want one published, the feedback channel, monthly re-testing and five years of records. If you also sell into the European Union the same testing supports the statement required there, described on the EAA checklist, and if you employ people in Ontario, the record described on the Ontario page.
Timing, and why waiting is expensive
Accessibility work in the UK is almost always triggered by an external date: a bid closing, a customer audit, a complaint with a deadline for reply. The problem with that pattern is that the testing takes five days and the fixing does not. A finding that takes a developer two hours costs nothing in a normal sprint and becomes a crisis when the bid closes on Friday. Organisations that run the audit before they need it answer procurement questions from a file rather than from a panic, and the difference in cost is entirely in the scheduling, not in the work.
The honest summary
If you run a small British site that sells nothing to the public sector and nothing into the European Union, the legal pressure on you is low and diffuse, and anyone telling you otherwise is selling something. What is not low is the chance that a customer somewhere cannot complete a task on your site, and that you will never hear about it.
If you tender, if you supply enterprise customers, or if you sell to consumers in the EU, the picture changes completely: the question arrives in writing, it has to be answered in writing, and the answer is either a dated report from an external tester or an admission that nobody has looked. The audit costs a fixed amount and takes five business days. The alternative is discovering the position during a bid, with a deadline.
Where the duty bites in ordinary British businesses
The abstraction becomes concrete in four places, and they are the same four in almost every sector we test.
Booking and appointments. Restaurants, clinics, garages and salons increasingly take bookings only through a widget embedded from a third party. If that widget cannot be operated without a mouse, the service is effectively closed to a group of customers, and the fact that the code belongs to a supplier is not an answer to the person who cannot book.
Application forms. Recruitment is the area where a barrier is most likely to be raised formally, because a candidate who cannot apply has an obvious and documented disadvantage. Employment claims are also where legal advice arrives fastest.
Account and self-service. Utilities, insurers and subscription services push customers towards self-service and then withdraw the phone line. When the portal is unusable and the alternative has been removed, the disadvantage is squarely of the provider's own making.
Documents. Statements, invoices and policy packs delivered as untagged files are a recurring complaint in financial services, and one of the easier things to correct.
Scotland, Wales and Northern Ireland
The Equality Act applies across Great Britain, and Northern Ireland has its own parallel disability discrimination legislation with the same practical effect for a service provider. For a business operating across the United Kingdom this rarely changes what you do: test the service, remove the barriers, document the position. It matters mainly in procurement, where devolved bodies run their own frameworks and their own questionnaires, and where a report naming the standard and the testing method travels better than one written for a single buyer.
The alternative channel question
A common instinct is to answer a barrier with a phone number. That can be a legitimate adjustment, and while remediation is in progress it is the right thing to offer. It is weaker than it looks as a permanent position, for two reasons. If the online route is the cheaper, faster, always-open one and the alternative is a queue during office hours, the disadvantage has been reduced rather than removed. And if the phone line is itself hard to use, or staffed by people who have not been told the alternative exists, it fails in practice on the first call.
The workable version is specific: a named route, a stated response time, staff who know about it, and a date by which the online path will work. That is a managed position. A phone number in small print at the bottom of a page is not.
UK questions, answered carefully
Is there a UK law that says websites must be accessible?
There is no single web statute for private businesses. The Equality Act 2010 imposes a duty to make reasonable adjustments, and that duty covers digital services.
What about public sector bodies?
They are covered by the 2018 accessibility regulations, which require conformance and a published accessibility statement in a prescribed form.
Did the EAA apply in the UK?
No. The Directive applies in the European Union. A British company selling to consumers in the EU is still covered for that market.
Which standard is used in practice?
WCAG 2.2 level AA. It appears in procurement documents, supplier questionnaires and public sector guidance.
What is a reasonable adjustment online?
Anything that removes a substantial disadvantage: an accessible alternative to a barrier, a usable form, an alternative channel for a task that cannot yet be completed.
Is the duty anticipatory?
Yes. Service providers are expected to think ahead rather than wait for an individual to ask, which is what makes testing before a complaint the sensible order.
Who enforces it?
There is no regulator issuing fines to private sites. Enforcement comes through claims brought by individuals and through procurement decisions.
What happens in a claim?
The question is what adjustments were made and whether they were reasonable. Dated evidence of testing and remediation is the practical answer.
Do buyers really ask for this?
Constantly in public procurement, and increasingly in enterprise sales where the customer is passing down their own obligations.
Do I need a published statement?
Not by statute if you are a private business, but buyers ask for one and users benefit from it. Publishing an honest one costs nothing and settles the question.
Who signs your UK report?
REP27 LTD, company number 17385889, registered in England.
What does the report contain?
The pages and flows tested, the assistive technology used, the date, findings by criterion with severity, and a conformance position.
How long does it take?
Five business days from a complete form.
What does it cost?
1,990 € a year for the plan covering the EU, the UK and Canada with one renewal date.
Do you provide legal advice?
No. We provide testing, documentation and a signed report. Legal questions go to a solicitor.
Does an overlay satisfy the duty?
A script does not remove the barrier underneath, so it is unlikely to count as a reasonable adjustment where the task still cannot be completed.
How often should we re-test?
Monthly is included in the plan, which matters because the duty is continuing rather than a one-off.
Where do we start?
Free scan, then the audit.