Accessibility Compliance for Businesses
Verified against 4 sources
- Equality Act 2010 (service providers duty)
- Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018
- EHRC guidance on disability and the Equality Act
- WCAG 2.1 (W3C, 2018)
The Equality Act 2010 requires businesses providing goods, services, or facilities to make reasonable adjustments to ensure disabled people are not put at a substantial disadvantage compared to non-disabled people. The duty is anticipatory — you must act in advance, not just when a disabled person complains.
Key points
- Service providers must make reasonable adjustments for disabled customers — this duty is anticipatory, not reactive.
- Employers must also make reasonable adjustments for disabled employees — failure to do so is unlawful discrimination.
- Public sector bodies and some private sector organisations must comply with the Public Sector Bodies Accessibility Regulations for websites and apps.
- The Equality and Human Rights Commission (EHRC) can investigate and enforce, and individuals can bring claims in county court or employment tribunal.
The Duty to Make Reasonable Adjustments
Under the Equality Act 2010, service providers (shops, restaurants, banks, professional services firms, and all other businesses providing goods or services to the public) have a duty to make reasonable adjustments to ensure disabled people can access their services. The duty has three limbs: adjusting provisions, criteria, or practices that put disabled people at a disadvantage; adjusting or removing physical features that create barriers; and providing auxiliary aids or services (such as information in large print, hearing loops, or accessible websites).
Critically, the duty is anticipatory — you must think in advance about the range of disabled customers you might serve and make adjustments proactively, without waiting for a disabled person to ask. You do not need to carry out structural works that are disproportionate to your resources, but you are expected to find alternative ways to provide service (bringing the service to the ground floor, for example) if making the physical feature accessible is not reasonable. Whether an adjustment is "reasonable" depends on the size and resources of the business, the cost of the adjustment, and its practicality.
Physical Premises and Digital Accessibility
For physical premises, reasonable adjustments may include: installing a ramp at an entrance; providing seating for those who cannot stand; offering assistance to customers who need it; ensuring aisles are wide enough for wheelchairs; providing large-print menus; installing hearing loops in reception areas; and training staff in disability awareness. A business does not have to make every adjustment if cost is genuinely disproportionate — but it must make those that are reasonable given its size and resources.
For digital accessibility, public sector bodies in the UK must comply with the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018, which require websites and apps to meet the Web Content Accessibility Guidelines (WCAG) 2.1 AA standard. Private sector businesses are not directly subject to these Regulations, but the Equality Act applies — a website that is inaccessible to a disabled person may put them at a substantial disadvantage and require adjustment. Consumer-facing websites and apps should aim to meet WCAG 2.1 AA as a baseline.
Enforcement and Practical Compliance
Individuals who have suffered discrimination can bring a claim in the county court (for service provider cases) within six months of the act complained of. They can claim compensation for financial loss and injury to feelings. Unlike employment tribunal claims, there is no cap on county court discrimination awards. The Equality and Human Rights Commission (EHRC) can also conduct formal investigations, issue unlawful act notices, and take enforcement action against organisations with systematic failures.
For practical compliance, start with an accessibility audit of your premises and website. Prioritise adjustments that address the most common barriers for disabled customers. Train customer-facing staff. Keep a record of adjustments made. For websites, use free tools such as the WAVE Web Accessibility Evaluation Tool to identify issues, and engage a developer familiar with WCAG to address them systematically. Small changes — alt text on images, sufficient colour contrast, keyboard navigation — can make a significant difference for disabled users at minimal cost.
Website Accessibility: WCAG Standards and the ICO Position
The Web Content Accessibility Guidelines (WCAG) 2.1 at Level AA represent the current standard for accessible websites. WCAG 2.1 AA covers four principles: content must be perceivable (text alternatives for images, captions for video, sufficient colour contrast); operable (keyboard navigation, no seizure-inducing content, sufficient time to read); understandable (readable text, predictable navigation, error identification); and robust (content can be interpreted by assistive technologies).
For public sector bodies, compliance with the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 is mandatory. Public bodies must publish an accessibility statement and fix any known accessibility issues. The Government Digital Service (GDS) and the Central Digital and Data Office (CDDO) monitor compliance. Enforcement initially fell to the Cabinet Office; following the 2024 revised guidance it has been strengthened.
Private sector businesses are not directly covered by the 2018 Regulations, but the Equality Act 2010 applies to their websites and apps. The ICO's position — set out in its guidance on accessible information — is that organisations subject to the Equality Act must ensure their digital services do not put disabled people at a substantial disadvantage. This includes screen reader incompatibility, lack of keyboard navigation, and absence of alt text. A disabled customer denied access to your website to make a purchase or access a service could bring a county court discrimination claim. For consumer-facing businesses, WCAG 2.1 AA compliance is therefore the prudent standard to aim for regardless of whether the 2018 Regulations technically apply.
Frequently asked questions
Does my small business have to make physical alterations to become accessible?
What is disability under the Equality Act?
Are there any financial incentives for improving accessibility?
Does our website need to meet WCAG 2.1 AA even though we are a private business?
Can the EHRC take action against our business for poor accessibility?
What to do next
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Official bodies and resources
Information Commissioner's Office
RegulatorThe UK's independent authority for data protection and information rights, enforcing the UK GDPR and Data Protection Act 2018.
Advisory, Conciliation and Arbitration Service
GovernmentProvides free, impartial advice on workplace relations and employment law, and offers early conciliation before tribunal claims.
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