Website Accessibility and UK Law: What Small Businesses Must Do
Website accessibility law in the UK explained: the Equality Act duty, who the 2018 regulations cover, the EU Accessibility Act and steps that cut risk.
Under website accessibility law in the UK, a private small business has no specific website regulation to follow, but it is still covered by the Equality Act 2010. If your website is how you provide a service to the public, you must not discriminate against disabled customers and you must make reasonable adjustments so they are not put at a substantial disadvantage. In practice that means a site people can use with a keyboard, a screen reader or zoomed text, a way to get help when something does not work, and a record that you took the issue seriously.
Key takeaways
- The Equality Act 2010 applies to private business websites as part of the service you provide, even though it never mentions websites.
- The Public Sector Bodies Accessibility Regulations 2018, with their accessibility statement requirement, apply to public bodies, not ordinary small firms.
- The law sets no technical standard for private sites; WCAG 2.2 level AA is the practical benchmark to measure against.
- If you sell online to consumers in the EU, the European Accessibility Act may apply, unless you qualify as a microenterprise.
- Overlay widgets do not make a site accessible; fixing the underlying code and content does.
Does the Equality Act apply to my website?
Yes, if you provide goods, facilities or services to the public. Section 29 of the Equality Act 2010 says a service provider must not discriminate against a person who wants to use the service, whether it is paid for or free. A shop selling online, a salon taking bookings, a solicitor's enquiry form and a cafe's menu page are all part of a service. The Act does not need to name websites, because the website is one of the ways the service is delivered.
Section 29 also applies the duty to make reasonable adjustments to service providers. That duty is set out in section 20, and it has three parts. Where the way you do things, a physical feature, or the lack of an auxiliary aid puts disabled people at a substantial disadvantage, you must take reasonable steps to avoid it. Two details matter for websites:
- Accessible formats. Where the disadvantage involves information, reasonable steps include providing it in an accessible format.
- No charge. You cannot pass the cost of the adjustment on to the disabled person.
What counts as "reasonable" for a small business?
The Act does not list website features, and there is no fixed budget threshold. What is reasonable depends on your size and resources, how much the change would help, how practical it is, and how central the website is to your service. A courier who takes all bookings online carries a heavier expectation than a plumber whose site is one page with a phone number.
Some changes are reasonable for almost every business because they are cheap and make a large difference:
- Text that can be enlarged without breaking the layout.
- Enough colour contrast between text and background.
- Forms with proper labels that a screen reader announces.
- Everything usable with a keyboard alone, with a visible focus outline.
- Alt text on images that carry meaning.
- Captions on videos that explain your service.
- A phone number and email shown clearly, so anyone who cannot use part of the site has another route.
Rebuilding a whole booking system may or may not be reasonable for a very small firm. Offering the same booking by phone, at no extra cost, often is. Whatever you decide, write down why: a short note of what you checked, what you fixed and what alternative you offer is your best evidence that you took the duty seriously.
Which accessibility laws apply to which organisations?
A lot of online advice mixes up the rules for councils, universities and NHS bodies with the rules for private firms. This table separates them.
| Law | Who it covers | What it requires |
|---|---|---|
| Equality Act 2010 | All service providers in Great Britain, including private businesses and charities | No discrimination; reasonable adjustments; no fixed technical standard |
| Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 | Public sector bodies and some publicly funded organisations | Meet WCAG 2.2 AA, publish an accessibility statement, justify any disproportionate burden |
| European Accessibility Act (EU Directive 2019/882) | Businesses providing covered services, including e-commerce, to consumers in the EU | Accessible products and services from 28 June 2025; microenterprises providing services are exempt |
The gov.uk guidance on accessibility requirements for public sector websites sets out the 2018 rules. If you are a private company that is not mainly publicly funded, they do not apply to you directly, but they are a useful model of good practice, and some public sector clients will ask suppliers to meet them in contracts.
Does the European Accessibility Act affect UK businesses?
It can. The European Accessibility Act covers services provided to consumers in the EU after 28 June 2025, and e-commerce services are named among them. It is EU law, enforced by each member state, and it does not apply because you are a UK business. It may apply if you actively sell to consumers in EU countries through your website.
There is an important exemption: microenterprises providing services, meaning businesses with fewer than 10 staff and an annual turnover or balance sheet total of no more than 2 million euros, are exempt from the service requirements. If you are above that size and EU sales matter to you, get specific advice about your position.
WCAG 2.2 AA: the standard to measure against
Because the Equality Act has no technical standard, you need a yardstick to decide whether your site works. The Web Content Accessibility Guidelines, currently WCAG 2.2, are that yardstick. Level AA is what the public sector regulations require and what most accessibility audits check against. Meeting it is the clearest way to show your site does not put disabled users at a disadvantage.
WCAG is long, but small business sites tend to fail on the same handful of points. Common failures include:
- Low-contrast text, often pale grey on white or white text over photos.
- Form fields with placeholder text but no label.
- Menus and pop-ups that cannot be opened or closed with a keyboard.
- Images of text, such as offers baked into a banner graphic.
- Buttons and links too small or too close together to tap reliably.
- Cookie banners that trap keyboard focus or hide content.
- Links that just say "read more" with no context.
Good navigation design and a mobile-first build fix several of these at once, because the same habits that make a site easy on a phone make it easier with assistive technology.
Do accessibility overlay widgets make my site compliant?
No. Overlays are scripts that add a toolbar for changing font size or contrast, and some claim to fix problems automatically. They do not change the underlying code, so a screen reader still meets the same unlabelled buttons and broken forms. Disabled users often already have their own settings and tools, and an overlay can clash with them. Buying a widget does not show that you made reasonable adjustments; fixing the site does.
A practical plan to reduce your risk
You do not need a large budget to make real progress. Work through it in this order:
- Test the key journeys yourself. Using only the Tab and Enter keys, try to find a service, fill in the contact form and, if you sell online, buy something. Note where you get stuck.
- Run an automated check with a free tool such as the accessibility panel in your browser's developer tools. Automated tools catch only part of the problems, but they find contrast and labelling errors fast.
- Fix the cheap, high-impact issues first: contrast, form labels, alt text, focus outlines and link text.
- Offer and advertise an alternative route. A clear phone number and email for anyone who has trouble using the site.
- Publish an accessibility statement. It is not legally required for private firms, but a short page saying what standard you aim for, known issues and how to ask for help shows good faith.
- Build accessibility into the next redesign. It costs far less to design and code it in than to retrofit it, which is why contrast, keyboard use and form labelling belong in the brief for any website design project.
- Keep a record of what you tested, changed and offer instead.
Frequently asked questions
What should I do if a customer says they cannot use my website?
Thank them, find out exactly where they got stuck, and offer to complete what they needed another way straight away, by phone or email, at no extra cost. Then fix the barrier on the site and tell them when it is done. Responding quickly and practically is both good service and evidence that you take the reasonable adjustments duty seriously.
Is an accessibility statement legally required for a private company?
Not under UK law. The accessibility statement requirement comes from the 2018 regulations, which cover public sector bodies. For a private business it is optional good practice. It helps customers understand what to expect and how to get help, and it shows you have considered your duty under the Equality Act.
Does the law say my website must meet WCAG 2.2?
Not for private businesses. The Equality Act sets an outcome, no substantial disadvantage for disabled customers, rather than a technical standard. WCAG 2.2 level AA is the accepted way to measure whether you meet that outcome, and it is what auditors, public sector buyers and most developers work to.
Are small businesses with one-page websites covered?
Yes, the Equality Act applies regardless of size, but what is reasonable scales with the business. A simple site with readable text, good contrast and clear contact details may already do most of what is needed. The bigger the role the website plays in delivering your service, the more you are expected to do.
How long does it take to make a website accessible?
For a small brochure site, fixing the common issues can take days rather than weeks. Complex sites with booking, checkout or customer accounts take longer, because each journey needs testing. The age and build quality of the site decide most of it: sometimes a rebuild on a modern theme is cheaper than patching an old one.
Get your website checked
If you are not sure where your site stands, we can review the key journeys against WCAG 2.2 AA and give you a prioritised list of fixes, then make them if you want us to. Start a project or contact us. This article explains the law in general terms; for advice on a specific complaint, speak to a solicitor.
