Website accessibility in the UK: what the Equality Act asks of a small business

If you run a business website in the UK, you may have heard that it "must be accessible", or that a particular standard is the law. The real position is more specific, and less frightening, than the headlines suggest. This note explains what the Equality Act 2010 asks of a private business, what WCAG is and why it keeps coming up, and where to start. It is general information, not legal advice; for a specific situation, speak to a solicitor.

What the law actually says

For most businesses, the main rule is the Equality Act 2010. Under section 20, a business that provides services to the public must make reasonable adjustments, so that disabled people are not put at a substantial disadvantage compared with people who are not disabled. The duty can apply to the way you provide a service online as well as in a shop. The duty also looks ahead: it is not enough to wait for a complaint.

Two points are worth noting:

• The Act does not name a technical standard. There is no clause that says "meet WCAG 2.2 level AA". It says "reasonable", which depends on what you do, how big you are and what it would cost.
• Reasonableness is judged case by case, so a sole trader with a simple brochure site is not in the same position as a national online shop.

Public sector bodies are in a different position. They have specific rules, including an accessibility statement requirement, for their websites and apps.

Why everyone talks about WCAG

The Web Content Accessibility Guidelines, published by the W3C, are the widely used technical benchmark. WCAG 2.2 is the current version, and level AA is the usual target. Because the Equality Act leaves "reasonable" open, WCAG 2.2 AA is what most auditors, procurement teams and public bodies use as the yardstick. Meeting it is a strong way to show you took the duty seriously, even though the Act itself does not require that exact standard.

If you sell to people in the EU

The European Accessibility Act began to apply on 28 June 2025. It covers certain products and services, including e-commerce, when sold to consumers in the EU. Some obligations differ for very small businesses: there is an exemption for micro-enterprises that provide services. If you sell into the EU, check whether it applies to you; the Irish consumer regulator's overview is a readable starting point.

A practical starting list

You do not need a huge project to improve. These checks catch the most common barriers.

• Use the keyboard. Put the mouse away and press Tab through your pages. Can you reach every link, button and form field, in a sensible order, and see where you are? A visible focus mark is part of WCAG 2.2.
• Check contrast. Normal text needs a contrast ratio of at least 4.5 to 1 against its background; large text and the edges of controls need 3 to 1. Light grey text on white is the usual failure.
• Describe images. Meaningful images need short alternative text that says what they show or do. Decorative images should have an empty alt attribute so screen readers skip them.
• Label forms. Every field needs a visible label tied to it in the code, and error messages should say what is wrong and where, not just turn a box red.
• Use real headings and landmarks. One main heading, then a logical order. Screen reader users navigate by heading.
• Make targets big enough. WCAG 2.2 adds a minimum target size of 24 by 24 CSS pixels for small controls, and a focused item must not be hidden behind a sticky header or banner.
• Respect reduced motion. Offer a way to stop moving content, and honour the visitor's system setting.
• Do not rely on colour alone, for example a red border as the only error signal.
• Write plainly. Short sentences and clear link text ("Read the refund policy", not "click here") help everybody.

Automated tools are a start, not a verdict

Free tools such as browser accessibility checkers will find missing alt text, low contrast and unlabeled fields quickly. They cannot judge whether alt text is meaningful, whether the reading order makes sense, or whether a flow is usable with a screen reader. Plan for a manual pass: keyboard only, then a screen reader such as NVDA on Windows or VoiceOver on a Mac or phone, on your most important journey, such as enquiry or checkout.

Publish an accessibility statement

An accessibility statement is not required of private businesses, but it is good practice. Say what standard you aim for, what you have checked, what you know is not yet fixed, and how to ask for help. Being honest about known gaps builds more trust than a claim of perfection, and it gives a person who hits a barrier a way to tell you.

Where to begin this week

1. Tab through your home page and your main enquiry or purchase flow.
2. Run an automated checker on those pages and fix what it finds.
3. Check contrast on your brand colours once, then fix the palette, not each page.
4. Add an accessibility statement with a contact route.
5. Put accessibility on the checklist for every new page, so the problem does not come back.