Web design
No UK law names WCAG for private businesses, but the Equality Act 2010 still applies to your website. What the law expects, when EU rules reach UK firms, what WCAG 2.2 AA means in practice and what an audit costs.
For a UK business, website accessibility is a legal duty in practice even though no statute names a technical standard. The Equality Act 2010 requires anyone providing services to the public, online included, to make reasonable adjustments so disabled people are not put at a substantial disadvantage, and the duty is anticipatory: you are expected to remove barriers before someone complains. WCAG 2.2 level AA is the benchmark regulators, auditors and courts use to judge that. Public sector bodies have explicit duties under the Public Sector Bodies Accessibility Regulations 2018, and if you sell online to consumers in the EU, the European Accessibility Act may apply directly. This guide explains each in plain English, then covers what to test, what to fix first and what it costs. It is general information, not legal advice.
| Organisation | Main law | Technical standard | Accessibility statement |
|---|---|---|---|
| Private business serving the public (England, Scotland, Wales) | Equality Act 2010, reasonable adjustments | Not named; WCAG 2.2 AA is the accepted benchmark | Not required, but good practice |
| Business in Northern Ireland | Disability Discrimination Act 1995 (as it applies in NI) | Not named; WCAG 2.2 AA as benchmark | Not required, but good practice |
| Public sector body (councils, NHS bodies, schools, universities, most government) | Public Sector Bodies Accessibility Regulations 2018, plus Equality Act | WCAG 2.2 AA (monitored by GDS) | Required, in a set format |
| UK business selling in-scope services, such as e-commerce, to EU consumers | European Accessibility Act, through each EU country’s national law | EN 301 549, aligned with WCAG AA | Accessibility information required |
| Microenterprise providing services (fewer than 10 staff, ≤ €2m turnover or balance sheet) | Exempt from the EAA service requirements; Equality Act still applies | WCAG 2.2 AA as benchmark | Good practice |
According to the Department for Work and Pensions’ Family Resources Survey, around a quarter of people in the UK report a disability. That includes people who are blind or partially sighted, deaf or hard of hearing, who have motor impairments, dyslexia, autism or long-term conditions that affect how they use a screen. Add an ageing population, people with a broken wrist, and anyone squinting at a phone in bright sunlight, and accessible design simply means a site more people can use.
There is a commercial side too. A checkout a keyboard user cannot finish is lost revenue, and an enquiry form a screen reader cannot read is a lost lead. Accessible sites also tend to be better built: real headings, labelled forms, descriptive links and lean code, the same qualities that help search engines understand your pages.
The Equality Act applies in England, Scotland and Wales to anyone providing goods, facilities or services to the public, whether over a counter or through a website or app. Northern Ireland has its own disability discrimination legislation with similar duties.
Service providers must make reasonable adjustments where a disabled person would otherwise be at a substantial disadvantage. The key point is that the duty is anticipatory. You are expected to think ahead about the barriers disabled people in general may face, not wait for an individual to ask. For a website that means things like:
It depends on the size and resources of the business, the cost and practicality of the change and how much difference it makes. A sole trader in Swansea is not expected to match a high-street bank. But fixing contrast, labels and keyboard access on a brochure site is cheap, so “it was too expensive” will rarely hold up for those basics.
Individuals can bring claims in the county court, or the sheriff court in Scotland, and the Equality and Human Rights Commission has enforcement powers. Website claims have been far rarer in the UK than in the United States, where accessibility lawsuits are routine. Don’t read that as permission. The duty is real, complaints and claims do happen, and the reputational cost of turning disabled customers away is immediate.
If you are a public sector body, or you build sites for one, the rules are explicit. The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 require websites and apps to:
Most charities and other non-governmental organisations fall outside the regulations unless they provide services essential to the public or aimed specifically at disabled people. If you are a supplier building for a council in Leeds or a university in Glasgow, the contract will usually require WCAG 2.2 AA anyway.
The European Accessibility Act (Directive (EU) 2019/882) has applied since 28 June 2025. It sets accessibility requirements for certain products and services sold to consumers in the EU, including e-commerce services, consumer banking, e-books, and passenger transport booking and ticketing, plus some hardware such as computers, smartphones and payment terminals.
The UK is not bound by it, but it applies to services offered to consumers in EU member states, wherever the business is based. If your online shop actively targets customers in Ireland, France or Germany, with euro pricing, EU delivery and local-language pages, you may well be in scope. Each member state enforces it through its own law, and the harmonised standard, EN 301 549, is closely aligned with WCAG at level AA. Some existing services have transition periods, but new and redesigned services are expected to comply now.
Microenterprises providing services, meaning fewer than 10 employees and annual turnover or balance sheet total of no more than €2 million, are exempt from the service requirements. Larger UK retailers selling into the EU should treat it as a live obligation.
The Web Content Accessibility Guidelines are published by the W3C. Version 2.2 was published in October 2023 and is built on four principles: content must be perceivable, operable, understandable and robust. Each success criterion has a level: A is the minimum, AA is the target almost every regulation and contract points to, and AAA is aspirational and not expected for whole sites.
WCAG 2.2 added nine success criteria to WCAG 2.1, six of them at levels A and AA, and removed the old Parsing criterion. The six that matter for AA:
Nothing exotic. On UK business sites, audits keep turning up the same problems:
Accessibility overlay widgets promise compliance with one line of script. They cannot fix missing labels, broken structure or inaccessible custom components in the underlying code, and some interfere with the assistive technology disabled people already use. Many disabled users actively dislike them. They do not make a site meet WCAG, and we would not rely on one as evidence of reasonable adjustments.
If two or more of those went badly, a proper audit is worth doing.
A meaningful audit covers your key templates and journeys (home, a service or product page, contact, booking or checkout) against WCAG 2.2 AA, with automated tests plus manual keyboard and screen reader testing, and gives you a prioritised list of fixes. Typical scopes at our rates:
| Job | Typical hours | Calculation (excl. VAT) | Total incl. VAT |
|---|---|---|---|
| Audit of a 10–20 page brochure site (UI/UX £55/h) | 10 h | £550 − 5 % = £522.50 | £627 |
| Fixes on a WordPress brochure site (£50/h) | 10 h | £500 − 5 % = £475 | £570 |
| Fixes on a larger WordPress site or shop (£50/h) | 20 h | £1,000 − 15 % = £850 | £1,020 |
Hours never expire, and you can pay in full or with a 50 % deposit when you book online. If the audit shows that the theme itself is the problem, a rebuild can be cheaper than patching: every site on our fixed-price packages is built to WCAG 2.2 AA from the start, from the £750 + VAT Pro Website upwards.
We target WCAG 2.2 AA on every template, alongside Lighthouse 95+. Our hand-built WordPress themes use semantic structure, keyboard-friendly navigation and forms, sufficient contrast and visible focus states, and we test with a keyboard and screen readers before launch. We also produced an accessibility-led redesign concept for WWF. Accessibility and performance tend to improve together; see Core Web Vitals explained.
For larger redesigns, see our UX design and web development services. Our team is based in St Albans and works with organisations across the UK, remotely or in person in London and the Home Counties. If you’re not sure where your site stands, an audit is the quickest way to find out.
For businesses serving the public, yes in effect. The Equality Act 2010 requires reasonable adjustments so disabled people are not put at a substantial disadvantage, and that covers websites and apps. The law does not name a technical standard for private businesses, but WCAG 2.2 AA is the accepted benchmark.
It can. Since 28 June 2025 it applies to in-scope services, including e-commerce, offered to consumers in the EU, wherever the business is based. Microenterprises providing services, with fewer than 10 staff and turnover or balance sheet of no more than €2 million, are exempt from the service requirements.
Public sector bodies must publish one under the 2018 regulations. Private UK businesses are not generally required to, but a short statement with a contact route for people who hit a barrier is good practice, and services in scope of the European Accessibility Act must provide accessibility information.
No. Overlay widgets cannot fix underlying problems in the code, such as missing labels, poor structure or inaccessible forms, and some create new barriers for assistive technology users. Accessibility has to be built into the design and code.
WCAG 2.2, published in October 2023, adds nine success criteria, six of them at A and AA: focus not obscured, dragging alternatives, minimum target size, consistent help, redundant entry and accessible authentication. It also removed the old Parsing criterion.
Building it in from the start adds little. For an existing site, an audit of a typical 10–20 page brochure site takes around 10 hours (£522.50 + VAT at our UI/UX rate after discount), and fixes often take 10 to 20 hours at £50/h + VAT, depending on the theme.
Photo: Tima Miroshnichenko via Pexels
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