Web Accessibility: What UK Businesses Need to Know

This article is general information about how accessibility duties are commonly understood in the UK. It is not legal advice. Whether a particular obligation applies to your organisation, and what counts as reasonable in your circumstances, depends on facts we cannot see from here. If you need certainty, take advice from a solicitor.

With that said, a great deal of what UK businesses are told about this subject is imported wholesale from the United States and does not describe the position here at all.

Two different regimes, often confused

The UK has two distinct sets of rules, and most confusion comes from treating them as one.

Public sector bodies — central and local government, the NHS, schools, universities and similar organisations — are covered by the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018. These are specific and prescriptive. They point at a defined technical standard, they require a published accessibility statement setting out how accessible the service is and where it falls short, and compliance is monitored. Government guidance for public sector services now sets the bar at WCAG level AA, with monitoring against version 2.2 having begun in late 2024.

Private businesses are not covered by those regulations. Their obligations arise chiefly under the Equality Act 2010, which is a general anti-discrimination statute rather than a technical specification. It contains no mention of WCAG, no conformance levels, and no audit regime.

This matters because a lot of marketing material tells private UK companies they must “comply with the accessibility regulations”. Usually they must not, because those regulations are not addressed to them. That does not leave them with no duties — it leaves them with a differently shaped one.

What the Equality Act actually asks of you

The relevant concept is the duty to make reasonable adjustments for disabled people. For service providers offering goods, services or facilities to the public, that duty is generally understood to be anticipatory. You are expected to think ahead about barriers disabled customers might face, rather than waiting for an individual to complain and then reacting.

Two consequences follow.

The first is that “nobody has ever complained” is a weak position. The duty is not triggered by a complaint. It is also worth remembering that someone who cannot use your site usually just leaves and buys elsewhere, so silence is not evidence of accessibility.

The second is that “reasonable” is doing real work in that phrase. What is reasonable for a national retailer with an in-house development team is not what is reasonable for a six-person firm with a template site. Cost, practicality and the resources available are relevant. There is no fixed threshold, which is uncomfortable, but it also means proportionate, documented effort counts for something.

Note the difference in framing from the US Americans with Disabilities Act. Both aim at non-discrimination, but the case law, the enforcement culture and the litigation risk are not comparable, and advice written for a US audience should be read with that in mind.

Where WCAG fits

If the Equality Act does not name a standard, why does everyone reference one?

Because the Web Content Accessibility Guidelines are the recognised benchmark, and in practice they are how you demonstrate that you took the question seriously. WCAG 2.2 level AA is the version and level most commonly used as a reference point in the UK. Meeting it is not, in itself, a statutory requirement for a private business. It is the most credible available evidence that you made a reasonable effort.

There is also a separate point worth checking if you sell into Europe. The European Accessibility Act has applied since June 2025 and can reach businesses outside the EU that offer covered products or services to consumers within it. There are thresholds relating to organisation size and turnover, and transitional periods for services already on the market. If you have meaningful EU consumer trade, that is a question for your legal adviser rather than your web developer.

The failures that matter most

Full WCAG conformance is a large piece of work. If you are starting from nothing, a short list of issues accounts for a disproportionate share of real-world exclusion.

Images without meaningful alternative text. Decorative images should carry an empty alt attribute so screen readers skip them. Informative ones need a description of what they convey. “image1.jpg” helps nobody.

Colour contrast that fails. WCAG 2.2 AA asks for a contrast ratio of at least 4.5:1 for normal body text and 3:1 for large text. Pale grey on white is the most common failure in modern brand design, and it affects far more people than screen reader issues do.

Keyboard traps and invisible focus. Try navigating your site using only the Tab key. Can you reach every link and control? Can you see where you are? Custom-styled components frequently remove the focus outline for aesthetic reasons and never replace it.

Form fields without labels. A placeholder is not a label. It vanishes when typing starts and is often not announced properly by assistive technology.

Video without captions. If you publish video, captions are the highest-value single addition.

Colour as the only signal. “Fields in red are required” excludes anyone who cannot distinguish the red.

How to approach it without pretending

Automated checkers — the accessibility panel in browser developer tools, or tools such as axe and WAVE — reliably catch contrast failures, missing alt attributes and unlabelled fields. They cannot judge whether your alt text is any good or whether your page makes sense in reading order. Automated testing finds a minority of real issues. Treat it as triage, not as a pass.

Manual keyboard testing and a screen reader pass on your three most important pages will tell you more than any scan. So will asking someone who uses assistive technology daily.

Be careful with overlay widgets that promise instant compliance from a single line of JavaScript. They are contested within the accessibility community, and several have been criticised by disabled users for interfering with the assistive technology they already rely on. A bolt-on script does not fix underlying markup.

Finally, avoid publishing a statement claiming conformance you have not tested. An honest note describing what you have done, what you know is outstanding and how someone can request help is more defensible than an unfounded claim of full compliance — and considerably more useful to the person reading it.

Accessibility improvements are largely the same work as good build quality: semantic markup, sensible contrast, clear labels and readable copy. That sits between website development, graphic design and content creation. If you want to talk it through, get in touch — and for anything turning on legal exposure, speak to a solicitor first.