UK businesses should aim for WCAG 2.2 level AA. The Equality Act 2010 requires service providers, including online ones, to make reasonable adjustments for disabled people. Public sector websites must meet WCAG 2.2 AA by law and publish an accessibility statement, and businesses selling to EU consumers may fall under the European Accessibility Act. If you also serve US customers, the Americans with Disabilities Act (ADA) is regularly used in lawsuits over inaccessible business websites. The Justice Department's guidance says the ADA applies to the websites of businesses open to the public, and WCAG AA is the usual benchmark.
This guide sets out which rules apply to you, then gives a practical checklist you can work through. It is general information, not legal advice.
Key takeaways
- UK businesses should aim for WCAG 2.2 level AA, the accepted benchmark for the Equality Act's reasonable adjustments duty.
- Public sector websites must meet WCAG 2.2 AA by law and publish an accessibility statement.
- Businesses selling online to EU consumers may fall under the European Accessibility Act unless they qualify as a microenterprise.
- Automated scans catch only part of the problems, so also test with a keyboard, at 200% zoom and with a screen reader.
Which accessibility laws apply to a UK business website?
| Rule | Who it covers | What it expects |
|---|---|---|
| Equality Act 2010 (Disability Discrimination Act 1995 in Northern Ireland) | Every UK organisation providing goods, services or facilities to the public, online or offline | Reasonable adjustments for disabled people. No specific technical standard is named, but WCAG 2.2 AA is the accepted benchmark |
| Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 | Central and local government, NHS bodies, universities, most publicly funded organisations | Meet WCAG 2.2 AA and publish an accessibility statement. Monitored by the Government Digital Service |
| European Accessibility Act (Directive (EU) 2019/882) | Businesses selling certain products and services, including e-commerce, to consumers in EU countries | Accessible services from 28 June 2025. Service providers with fewer than 10 employees and turnover under €2 million are exempt |
Does the Equality Act apply to websites?
Yes. The duty covers services provided online, and it is anticipatory: you are expected to think ahead about the barriers disabled people commonly face, not just respond when someone complains. The Equality and Human Rights Commission enforces it in England, Scotland and Wales, and the Equality Commission for Northern Ireland in Northern Ireland. Individuals can also bring claims. There is no UK law that sets a private-sector website standard the way the EAA does, so WCAG 2.2 AA is the practical yardstick.
What does the public sector have to do?
Public sector sites must meet WCAG 2.2 AA, publish and regularly review an accessibility statement explaining what is not yet accessible and why, and handle accessibility requests. Some content is exempt, such as live video and certain older PDFs, and bodies can claim a disproportionate burden only after a documented assessment. If you are a supplier building sites for public bodies, these rules apply to your work. Our guide to the European Accessibility Act for UK online sellers covers the EU side in more depth.
The checklist
Work through each section. Each item maps to WCAG 2.2 AA criteria. Do not assume your site is already fine: WebAIM's 2026 scan of the top one million home pages found detectable WCAG failures on 95.9% of them, with low-contrast text, missing alt text and unlabelled form fields the most common.
Content and images
- Every informative image has alt text describing its purpose; decorative images have
alt="". - Images of text are avoided, except logos.
- Pages use one
<h1>and a logical order of<h2>and<h3>headings. - Link text makes sense on its own ("Download the 2026 price list", not "click here").
- The page language is set (
<html lang="en-GB">). - Writing is clear, with plain-English instructions and explained jargon.
Colour and visual design
- Body text has a contrast ratio of at least 4.5:1; large text at least 3:1. A palette tool with contrast checks helps when choosing colours.
- Icons, input borders and focus indicators have at least 3:1 contrast.
- Colour is never the only way information is conveyed (for example, required fields or form errors).
- Content reflows at 320 CSS pixels wide without horizontal scrolling, and text can be zoomed to 200% without loss.
Keyboard and focus
- Every interactive element can be reached and used with the keyboard alone.
- Focus order follows the visual order.
- A visible focus indicator is always shown.
- Sticky headers, cookie banners and chat widgets do not completely hide the focused element (new in 2.2).
- There are no keyboard traps; menus and pop-ups close with Escape.
- A "skip to main content" link is available.
Forms and transactions
- Every field has a visible, programmatically linked label.
- Errors are described in text, next to the field, with a suggestion for fixing them.
- Users are not asked for the same information twice in one process (new in 2.2).
- Logins allow password managers and pasting, with no memory puzzles or cognitive tests (new in 2.2).
- Anything done by dragging, such as sliders or reordering, has a click or tap alternative (new in 2.2).
- Buttons and links are at least 24 by 24 CSS pixels or adequately spaced (new in 2.2).
Media and dynamic content
- Pre-recorded video has captions; audio has transcripts.
- Nothing flashes more than three times a second, and moving or auto-updating content can be paused.
- Help options, such as a contact link or phone number, appear in the same place on every page (new in 2.2).
Governance
- Publish an accessibility statement (required for the public sector, good practice for everyone): what standard you aim for, known issues, and how to contact you for an alternative format.
- Make accessibility part of your website briefs and supplier contracts, specifying WCAG 2.2 AA.
- Re-test after every redesign, theme change or new plugin.
How do I test against the checklist?
- Run an automated scan, such as the Lighthouse-based checks in a MakeItFlow audit, to catch missing alt text, contrast failures, missing labels and language issues quickly.
- Test with a keyboard: unplug the mouse and complete your key journeys, such as contact, booking and checkout.
- Zoom to 200% and 400% and narrow the window to phone width.
- Try a screen reader: NVDA (free, Windows) or VoiceOver (built into Apple devices).
- Check third-party components: booking widgets, payment pages, cookie banners, maps and chat tools. You are responsible for the journey even if a supplier built part of it.
- For high-stakes sites, commission an expert audit and test with disabled users.
For the techniques behind each fix, with code examples, see how to make a website accessible: WCAG 2.2 basics.
What should an accessibility statement include?
A good statement, public sector or private, covers:
- The standard you are working to (WCAG 2.2 AA).
- How accessible the site currently is, and a plain list of known problems.
- What you are doing to fix them, with rough timescales.
- How to request content in another format or report a problem, with a response time.
- When the site was last tested and by whom.
Public sector bodies must follow the GOV.UK model statement and include the enforcement procedure.
Frequently asked questions
Can a small business be sued over an inaccessible website?
Claims under the Equality Act are possible against any service provider, regardless of size. What counts as a reasonable adjustment depends on factors such as cost and resources, so expectations of a sole trader differ from those of a national retailer. Take legal advice if you receive a complaint.
Does a cookie banner need to be accessible?
Yes. It is often the first thing a user meets, so it must be keyboard-operable, readable by screen readers and not hide focused content. Our article on the Data (Use and Access) Act and cookie consent covers the consent rules.
Is an automated scan enough to prove compliance?
No. Automated tools catch only part of the problems. They cannot judge whether alt text is accurate or whether a checkout makes sense to a screen reader user. Use them as a first pass.
Do PDFs need to be accessible?
Yes, if they contain information people need. Tagged PDFs with headings, alt text and a reading order are acceptable, but an HTML page is usually easier to make accessible.
Does the EAA apply after Brexit?
Not as UK law, but it applies to products and services placed on the EU market. A UK business selling online to EU consumers can be in scope unless it qualifies as a microenterprise.
What to do next
Pick your three most important user journeys and work through the checklist on those first. MakeItFlow runs automated accessibility checks using Lighthouse as part of a free website audit, giving you a quick list of contrast, alt text, label and language issues to fix. It is not a compliance certificate, so combine it with manual testing and, where the stakes are high, an expert audit.
Sources
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Written by the MakeItFlow team
We build the website audit these guides are based on. Every fact is checked against the primary sources listed above and this guide was last reviewed on 30 October 2026 . How we research and check
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