UK Equality Act 2010: website compliance, explained

The UK Equality Act 2010 applies to UK service providers; the duty to make 'reasonable adjustments' for disabled users is anticipatory, meaning it applies before anyone complains. It has been in force since 2010, with WCAG conformance treated as the practical benchmark by courts and the EHRC.

The technical benchmark is WCAG 2.1 AA (and 2.2 AA going forward) as referenced in UK government guidance. In practice, that means your site must be perceivable, operable, understandable, and robust for users with disabilities, from screen-reader users to keyboard-only navigation to low-vision users who need sufficient color contrast.

Timeline and current status

The Equality Act consolidated the earlier Disability Discrimination Act in 2010. UK public-sector websites have had explicit WCAG obligations since the 2018 Public Sector Bodies Accessibility Regulations, and government guidance now references WCAG 2.2. For private-sector sites, the anticipatory duty means the safest reading is that WCAG conformance is expected before a disabled user ever complains.

What enforcement actually looks like

Discrimination claims in county court, EHRC enforcement, and reputational damage. Post-Brexit, UK-only traders still face the EAA for EU customers.

What WCAG requires, in plain terms

WCAG (Web Content Accessibility Guidelines) is organized around four principles: content must be perceivable (e.g. images have text alternatives, text has sufficient contrast), operable (everything works with a keyboard, users have enough time, nothing traps focus), understandable (pages are readable, predictable, and help users avoid mistakes), and robust (markup is parseable by assistive technologies like screen readers). Each guideline has testable success criteria at three levels: A (minimum), AA (the level essentially every law references), and AAA (aspirational). Conformance at AA means meeting all A and AA criteria. The current version is WCAG 2.2, published in October 2023, which added nine criteria to WCAG 2.1, including minimum target sizes for buttons and links, visible focus indicators, and easier authentication.

The violations that actually show up on real sites

Across the millions of pages tested in large-scale studies like WebAIM's annual survey of the top one million homepages, the same handful of failures dominate: low-contrast text (found on roughly four out of five homepages), images missing alternative text, form inputs without labels, empty links and buttons, and missing document language. In our own scans of e-commerce sites, we also routinely find keyboard traps in carousels and mega-menus, focus indicators removed with CSS, modal dialogs that screen readers never announce, and touch targets far below the 24 by 24 pixel minimum WCAG 2.2 requires. Most of these are cheap to fix individually. The expensive part is finding them all and keeping them fixed as the site changes, which is exactly what automated monitoring is for.

Why overlays and widgets don't help

Regulators on both sides of the Atlantic have rejected overlay widgets as a compliance shortcut. The US FTC fined a leading overlay vendor $1M in 2025 for deceptive 'one-line-of-code compliance' claims, and the European Commission has stated overlays do not confer conformance. Compliance means fixing your actual markup, and being able to prove you did.

What a defensible position looks like

Enforcement bodies and plaintiffs' lawyers respond to evidence: a documented scan history, a prioritized remediation log, and visible progress. A site with a timestamped record of continuous scanning and fixing is in a categorically stronger position than one with no paper trail, even at the same level of technical conformance. That evidence trail is also what an accessibility statement, a VPAT, or a response to a demand letter gets built from.

Compliance checklist

  • Run an automated WCAG scan of your key pages (home, product/service, checkout or contact)
  • Fix critical and serious violations first, since these carry the most legal and usability weight
  • Keep a dated log of what was found and what was fixed
  • Re-scan on a schedule; every deploy and CMS edit can introduce regressions
  • Add a manual audit for the criteria automation can't check (roughly two-thirds of WCAG)
  • Publish an accessibility statement describing your conformance status and contact route

Frequently asked questions

Does the UK Equality Act 2010 apply to my business?
It applies to UK service providers; the duty to make 'reasonable adjustments' for disabled users is anticipatory, meaning it applies before anyone complains. There is no turnover or headcount exemption for the services duty. The 'reasonable' qualifier scales with organization size, but a broken checkout is rarely defensible at any size.
Which WCAG version does the UK Equality Act 2010 require?
The referenced standard is WCAG 2.1 AA (and 2.2 AA going forward) as referenced in UK government guidance. WCAG versions are backwards-compatible, so building to the current WCAG 2.2 AA satisfies the older versions laws cite and protects you as standards are updated.
What are the penalties for non-compliance?
Discrimination claims in county court, EHRC enforcement, and reputational damage. Post-Brexit, UK-only traders still face the EAA for EU customers.
Does an accessibility overlay or widget make me compliant?
No. Overlay widgets inject a script that tries to repair issues in the browser at display time. Regulators and courts have rejected this approach: the US FTC fined a leading overlay vendor $1 million in 2025 for deceptive compliance claims, the European Commission has stated overlays do not confer conformance, and hundreds of US lawsuits in recent years have been filed against sites that were running an overlay at the time. Real compliance means fixing your actual markup and keeping evidence that you did.
Can an automated scan alone make me compliant?
Not by itself, and any vendor claiming otherwise is misleading you. Roughly a third of WCAG success criteria can be checked by a machine, though those criteria account for the majority of violations found in real audits by volume. An automated scan is the fastest way to find and fix the bulk of your issues and to prove ongoing diligence, but full conformance also requires human judgment for things like alt-text quality, logical reading order, and form error recovery. The strongest position combines automated monitoring with a periodic manual audit.