Website Accessibility Under the Equality Act 2010: What UK Businesses Owe

UK website accessibility law is not the European Accessibility Act. That is an EU Directive that became enforceable across EU member states from June 2025. The UK left the EU in 2020, and British businesses are not subject to it for their UK domestic activities. What applies instead is the Equality Act 2010, a civil-rights statute that has required service providers to make reasonable adjustments for disabled people since it came into force.

To check your site for the barriers that most commonly appear in Equality Act claims, run a free accessibility scan at /uk/en/scan.

Why the Equality Act applies to websites

The Equality Act 2010 makes it unlawful for service providers to discriminate against disabled people in the provision of services. Section 29 prohibits treating a disabled person less favourably because of their disability in the terms on which a service is provided, or by failing to make a reasonable adjustment.

A website is a service. The Equality Act's definition of "services" covers any service that is offered to the public or a section of the public, whether for payment or not. An e-commerce store, a restaurant booking site, a financial services portal, a professional services firm website: all are services in this sense.

Section 20 imposes what the legislation calls an "anticipatory duty." A service provider must not wait until a disabled person requests an adjustment before making it. If an accessibility barrier is one that could reasonably have been anticipated, the obligation to remove it arises before any individual complains. A website that has never received a complaint from a disabled user is not exempt.

The relationship between sections 20 and 29 is that section 20 defines the duty and section 29 makes failure to comply unlawful. Together they mean that a business with a website accessible only to non-disabled people is, in principle, in breach of primary legislation.

What reasonable adjustments mean in practice for a website

Reasonableness under the Equality Act is not a fixed standard. It depends on the size and resources of the service provider, the nature and cost of the adjustment, and whether the adjustment would fundamentally alter the service. A large financial institution is held to a higher standard than a two-person sole trader.

For websites, the adjustments that are most commonly relevant fall into a small number of categories.

Images without alternative text are probably the most common barrier. Screen readers read out the alt attribute to describe images. A decorative banner image needs an empty alt attribute so screen readers skip it. A product image, an informational diagram or a button image must have descriptive alt text. This is a zero-cost fix for any developer and is therefore always reasonable.

Videos without captions exclude deaf and hard-of-hearing users. Adding captions to video content is low-cost using tools like YouTube's automatic captioning or third-party services. Courts and the EHRC treat the absence of captions as an adjustment that a reasonably sized organisation should have made.

Forms without correct labels are inaccessible to screen-reader users because the form fields cannot be programmatically identified. A <label> element correctly associated with each input field is a one-line code change. It is almost never reasonable to omit this.

Keyboard navigability is required for users who cannot use a mouse. Dropdown menus that only open on hover, modal dialogs that trap keyboard focus, and interactive widgets that require precise mouse control all exclude users relying on keyboard navigation.

Contrast ratios affect people with low vision and colour-related visual impairments. The WCAG 2.2 AA standard specifies a minimum contrast ratio of 4.5:1 for normal text and 3:1 for large text. This is measurable with free tools.

The reasonableness test also looks at whether the adjustment was technically available at the time and whether making it would have imposed a disproportionate financial or operational burden. For the barriers above, no reasonable court or the EHRC would accept that any of these is disproportionate for any business with a functioning web presence.

Who can bring a claim

Any person who has been disadvantaged by a failure to make a reasonable adjustment can bring a civil claim in the county court under Part 9 of the Equality Act 2010. The claimant does not need to be a customer. A job applicant who could not complete an online application form because it was inaccessible could bring a claim. A person who could not access a service because the website lacked captions or alt text could bring a claim for injury to feelings plus any financial loss.

The Equality and Human Rights Commission (EHRC) also has standing to take enforcement action on behalf of groups of people or in the public interest under the Equality Act 2006. The EHRC's approach is strategic, focusing on systemic failures or sectors where inaccessibility is widespread rather than pursuing individual cases. Formal EHRC investigations and unlawful-act notices are rare but possible for organisations with persistent, documented accessibility failures.

How claims work in practice

Equality Act disability discrimination claims for services (not employment) are brought in the county court, not the Employment Tribunal. The county court can award damages for financial loss caused by the discrimination, injury to feelings, and in aggravated cases an uplift where the respondent's conduct was particularly unreasonable.

Damages for injury to feelings follow the Vento bands, guidelines established in Vento v Chief Constable of West Yorkshire Police [2002] EWCA Civ 1871 and updated annually by Presidential Guidance published at judiciary.uk. For 2025/2026 the lower band covers less serious cases, the middle band more serious ones, and the upper band cases involving deliberate or sustained discrimination. See Equality Act damages and Vento bands explained for current figures.

The large majority of accessibility-related EA 2010 disputes do not reach judgment. They are resolved through early engagement, adjustment of the website, and settlement. The threat of a county court claim with a realistic damages range, combined with adverse publicity, is sufficient to drive resolution in most cases. This means the published case law base specifically on website accessibility under the EA 2010 is thin, but the statutory obligation is clear. Where cases do proceed to judgment, courts have applied the reasonable adjustments framework to digital access barriers in the same way they apply it to physical ones. The anticipatory nature of the duty means that a business cannot argue it was unaware of a particular user's disability: the obligation is to anticipate that disabled users will attempt to use the service and to remove barriers before they arrive.

In Paulley v FirstGroup plc [2017] UKSC 4, the Supreme Court confirmed that the section 20 reasonable adjustments duty in service provision is an anticipatory, not a reactive, obligation. Although that case concerned physical access on buses, the reasoning applies to websites: the duty arises before any individual complains.

WCAG 2.2 AA as evidence of reasonableness

The Equality Act 2010 does not name WCAG or any other technical standard. It requires reasonable adjustments, and reasonableness is assessed on the facts of each case.

In practice, WCAG 2.2 AA has become the benchmark that courts, the EHRC and expert witnesses use when assessing whether a website is accessible. For public sector bodies, WCAG 2.2 AA is legally mandated under PSBAR 2018. The adoption of the same standard by the government digital service creates a strong inference that compliance with WCAG 2.2 AA satisfies the reasonable adjustments duty for private sector organisations as well. Non-compliance with WCAG 2.2 AA on a public-facing issue creates an obvious inference that an adjustment that should have been made was not.

Businesses that can demonstrate WCAG 2.2 AA conformance have a strong evidential position if an Equality Act claim is brought. Businesses that cannot demonstrate conformance, and where failures are on the list of common reasonable adjustments, face the reverse inference. For more on how WCAG 2.2 interacts with the EA 2010 legal framework, see WCAG 2.2 AA in UK law.

How UK law differs from the EU EAA

The EU Accessibility Act (Directive 2019/882) is a regulatory regime with sector-specific requirements, administrative enforcement by national regulators, and specific obligations around accessibility statements. It applied to most private-sector services targeting EU consumers from June 2025.

The Equality Act 2010 is a rights-based civil-law statute. There is no sectoral regulator with administrative enforcement powers comparable to the EU national accessibility authorities. Enforcement comes through individual court claims and EHRC strategic action. The obligations are framed around "reasonable adjustments" rather than technical conformance with specific standards.

For UK businesses with EU customers, both regimes may apply simultaneously to different parts of the same operation, and compliance with one does not automatically satisfy the other. The UK-facing website must meet EA 2010 reasonable-adjustments obligations. The EU-facing service must comply with the EAA in the jurisdictions where EU customers are based.

For a cross-jurisdiction comparison with data-protection compliance, see UK GDPR fines under the ICO.

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This is technical analysis, not legal advice. Consult a solicitor for specific guidance on Equality Act obligations affecting your organisation.