Website Accessibility & the Equality Act 2010: A Guide

The Equality Act 2010 prohibits discrimination against people with disabilities, including in the provision of services. Since websites are a means of providing services, the Act has direct implications for website owners and developers. This guide explains the key legal requirements and practical steps for ensuring website accessibility.

The Equality Act 2010

The Equality Act 2010 consolidated previous anti-discrimination legislation, including the Disability Discrimination Act 1995. It establishes a broad framework prohibiting discrimination on grounds of protected characteristics, one of which is disability.

Two provisions are particularly relevant to websites:

• Section 20 — Reasonable adjustments. Where a provision, criterion, or practice puts a disabled person at a substantial disadvantage compared to a non-disabled person, there is a duty to take reasonable steps to avoid that disadvantage. This includes providing information in accessible formats and ensuring that auxiliary aids are available where needed.
• Section 29(7) — Services and public functions. Service providers must not discriminate against a person by failing to provide a service, or by providing it on worse terms, because of a protected characteristic. Since websites constitute a means of providing services, this obligation extends to the online environment.

The duty is anticipatory

An important feature of the reasonable adjustments duty is that it is anticipatory and ongoing. This means website owners should not wait for a complaint before taking action. They are expected to consider the needs of disabled users proactively and to review their websites regularly to ensure accessibility is maintained as content and functionality change.

What constitutes a "reasonable" adjustment depends on several factors, including the financial resources of the organisation, the resources already expended on accessibility, and the disruption that further adjustments would cause.

WCAG as the benchmark

The Web Content Accessibility Guidelines (WCAG), published by the World Wide Web Consortium (W3C), are widely regarded as the benchmark for website accessibility. The current version is WCAG 2.2, which is organised around four principles:

• Perceivable — information and interface components must be presentable in ways that users can perceive (for example, providing text alternatives for images).
• Operable — interface components and navigation must be operable by all users (for example, ensuring full keyboard navigation).
• Understandable — information and operation of the interface must be understandable (for example, using clear and consistent language).
• Robust — content must be robust enough to be interpreted reliably by a wide variety of user agents, including assistive technologies.

WCAG 2.2 Level AA is generally considered the appropriate target for compliance. While the guidelines do not have direct legal force in the UK, they are likely to be treated by courts as a strong indicator of what constitutes reasonable adjustments.

The European Accessibility Act

The European Accessibility Act (EAA), which took effect in June 2025, introduced accessibility requirements for a wide range of products and services sold in the EU. While the EAA does not apply directly in the UK following Brexit, UK businesses that serve EU customers may need to comply with its requirements. The Act reinforces the global trend towards mandatory web accessibility standards.

Common accessibility barriers

Common accessibility issues that website owners should address include:

• Missing or inadequate alternative text for images
• Poor colour contrast between text and background
• Content that cannot be navigated using a keyboard alone
• Videos without captions or transcripts
• Inaccessible PDF documents
• Text embedded in images that cannot be read by screen readers
• Complex navigation structures that are difficult to understand
• Forms without proper labels or error messages

Enforcement

The Equality and Human Rights Commission (EHRC) has the power to investigate organisations suspected of failing to comply with the Equality Act. Enforcement measures include issuing unlawful act notices and seeking court orders. Individuals may also bring claims for discrimination under the Act.

Practical steps

Website owners should consider conducting an accessibility audit of their website against WCAG 2.2 Level AA, involving users with disabilities in testing where possible, training staff responsible for content creation and web development, and establishing an accessibility statement that sets out the steps taken and any known limitations. Accessibility should be treated as an ongoing commitment rather than a one-off exercise.