UK Equality Act and PSBAR: Accessibility Obligations for UK Websites

UK website accessibility is governed by two pieces of legislation: the Equality Act 2010(opens in a new tab), which applies to private and public organizations as service providers, and the Public Sector Bodies Accessibility Requirements(opens in a new tab) (PSBAR), which set specific technical requirements for public-sector websites and mobile apps.

Together, they establish the legal framework for digital accessibility in the UK. That’s what we’ll cover below: what each law is, who must comply, what standard they must meet, and who enforces compliance.

Does the Equality Act 2010 Apply to Websites?

Yes. Under the Equality Act 2010, a website is treated as a service, and organizations must make reasonable adjustments so that disabled users can access it on an equal basis with everyone else.

The Equality Act 2010 came into force on October 1, 2010. It consolidated over 100 existing pieces of UK anti-discrimination legislation into a single framework, covering disability, race, gender, and other protected characteristics across public life. The Act applies across England, Scotland, and Wales. In Northern Ireland, equivalent provisions are set out in the Disability Discrimination Act(opens in a new tab) (DDA 1995), which remains in force there.

Part 3 of the Act(opens in a new tab) covers services and public functions, and the Equality and Human Rights Commission(opens in a new tab) (EHRC) has confirmed in its statutory Code of Practice that websites count as a service under Part 3.

That means the reasonable-adjustments duty applies to virtually every organization with a website that serves UK customers, including:

• Private businesses, from large corporations to small enterprises across all sectors

• Public-sector bodies such as government departments, local councils, and other public-sector agencies

• Charities and non-profits, including foundations and third-sector organizations

• Educational institutions, including schools, colleges, and universities

Section 20 of the Equality Act(opens in a new tab) explains the reasonable-adjustment duty in three parts:

1. A provision, criterion, or practice of yours puts a disabled person at a substantial disadvantage; you must take reasonable steps to avoid it

2. A physical feature creates a substantial disadvantage; you must take reasonable steps to remove or alter it

3. A disabled person would be at a substantial disadvantage without an auxiliary aid or service; you must take reasonable steps to provide it

For websites, this translates directly to ensuring your digital content and services are navigable by screen readers, keyboard-only users, and people with cognitive or motor impairments. 

European accessibility symbol in front of a map of Europe and stylized web browser.

What Standard do UK Websites Need to Meet?

The Equality Act 2010 recognizes the Web Content Accessibility Guidelines(opens in a new tab) (WCAG) 2.2 Level AA as the benchmark for demonstrating that a private-sector organization has met its reasonable-adjustments duty. 

The Act itself does not name a specific technical standard. What it requires is an outcome: equal access for disabled people. In practice, WCAG 2.2 Level AA has become the benchmark that courts, regulators, and accessibility professionals use to assess whether reasonable adjustments have been made.

Meeting WCAG 2.2 Level AA means ensuring your website satisfies the POUR principles:

• Perceivable: Content is presented in ways all users can access, including through assistive technology.

• Operable: All functionality is accessible via keyboard and other input methods.

• Understandable: Content and navigation are clear and predictable.

• Robust: Content works reliably across browsers, devices, and assistive tools.

Being compliant with the Equality Act requires more than a one-time audit. It requires accessibility to be built into how your site is designed, developed, and maintained on an ongoing basis. 

What is PSBAR?

The Public Sector Bodies Accessibility Regulations (PSBAR) require UK public-sector websites and mobile apps to meet WCAG 2.2 Level AA and to publish an accessibility statement. 

PSBAR, formerly the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018, came into force on September 23, 2018. It built on the existing obligations under the Equality Act 2010 by adding specific, enforceable technical requirements for public-sector digital services.

PSBAR applies to:

• Central government departments and agencies

• Local authorities and councils

• NHS organizations

• Universities and publicly funded educational bodies

• Some charities with primarily public functions

The law requires three things from applicable organizations: 

1. Bring websites and mobile apps into conformance with WCAG 2.2 Level AA

2. Publish an accessibility statement on each applicable site, following the GDS template

3. Review and update that statement regularly to reflect the current accessibility status of the service

An important note: the WCAG version requirement under PSBAR has been updated since the regulations were introduced. The original 2018 regulations referenced EN 301 549(opens in a new tab), which incorporated WCAG 2.1. The UK Government subsequently amended PSBAR to reference WCAG directly without specifying a version number, meaning the regulations track the latest published version. The Government Digital Service confirmed it began monitoring for WCAG 2.2 compliance from October 2024.

Who Enforces UK Website Accessibility Law?

The EHRC: Enforcement of the Equality Act 2010

The Equality and Human Rights Commission(opens in a new tab) (EHRC) enforces the Equality Act 2010 in England, Scotland, and Wales with powers to investigate organizations, issue unlawful act notices, and initiate court action.

The EHRC is the statutory body responsible for upholding equality rights in Great Britain. Its enforcement powers include:

• Conducting formal investigations into suspected breaches of the Equality Act 2010

• Issuing unlawful act notices that require corrective action

• Applying for court injunctions to prevent further breaches

• Entering into enforceable agreements with organizations that commit to improving compliance

In practice, private-sector website accessibility cases have typically been resolved through complaints and out-of-court settlements rather than through formal enforcement action. The RNIB has brought forward several digital accessibility discrimination claims, resulting in organizations committing to accessibility improvements. In Northern Ireland, equivalent enforcement is carried out by the Equality Commission for Northern Ireland(opens in a new tab) (ECNI).

GDS: Monitoring PSBAR Compliance

The Government Digital Service(opens in a new tab) (GDS) monitors public-sector compliance with PSBAR by auditing a sample of public-sector websites and mobile apps each year and has the power to require organizations to fix identified issues.

GDS conducts two types of audits:

• Simplified checks: A sample of pages tested against key WCAG criteria.

• Detailed audits: Full WCAG 2.2 Level AA testing using assistive technology, expert review, and automated methods.

When GDS identifies accessibility failures, it sends a report to the relevant public-sector body. That organization must acknowledge receipt within seven days and fix the issues on a defined timeline. Persistent non-compliance can result in the organization being publicly named by the Central Digital and Data Office(opens in a new tab) (CDDO). GDS also investigates complaints through the Equality Advisory Support Service(opens in a new tab) (EASS) for public-sector websites in England, Scotland, and Wales.

A checklist with an accessibility symbol at the top of the page, in front of a laptop computer.

Reasonable Adjustments: What This Standard Actually Demands

The reasonable adjustments duty under the Equality Act 2010 is outcome-based, not checkbox-based, which means meeting it requires demonstrating that disabled users can genuinely access your service, not simply that a tool was installed.

This distinction matters. The Equality Act doesn’t ask whether you’ve taken steps, but whether disabled people experience equal access as a result of those steps. That is a fundamentally different standard from a technical checklist.

An automated overlay that intercepts page elements and attempts to fix accessibility issues at the browser level cannot, by itself, satisfy the reasonable-adjustments duty. If screen reader users still encounter broken navigation flows, keyboard traps still exist beneath the overlay, or the underlying code still blocks assistive technology, the duty has not been met. The outcome is what the law evaluates.

Genuine compliance requires understanding where your barriers are and addressing them at the source. That means combining automated detection, which can quickly surface common accessibility issues, with expert audits that catch what automation misses: complex interactions, reading order, screen reader compatibility, and cognitive load. The anticipatory standard, a principle standard established in the EHRC’s statutory Code of Practice on Services, Public Functions and Associations, demands this level of ongoing attention, not a one-time fix. 

Practical Implications for Global Brands

I your organization serves UK customers, the Equality Act applies to you. There is no territorial exemption for businesses based outside the UK. Serving customers across the U.S., EU, and UK means navigating three distinct legal frameworks: the European Accessibility Act, the Americans with Disabilities Act (ADA), and the Equality Act 2010. Complying with one doesn’t necessarily mean compliance with the others.

For multinational organizations, the most defensible position is building to a consistent technical standard, WCAG 2.2 Level AA, across all markets, while ensuring jurisdiction-specific requirements (like PSBAR’s accessibility statement obligation) are met on top of that baseline.

UK Accessibility: A Distinct Challenge with a Proven Solution

UK accessibility law is clear on what it expects. Disabled users must be able to access your service — not approximately, not with workarounds, but genuinely. The Equality Act 2010 sets that standard for every organization serving UK customers. PSBAR defines exactly what that means technically for public-sector bodies. Both laws are asking the same question: can a disabled person actually use your website? 

AudioEye helps you answer that question confidently by combining AI-powered automation with Expert Audits and Custom Fixes, closing the gaps automation alone leaves behind. That’s how we help you meet the outcome-based standard UK law requires, and keep meeting it even as your site changes.

Learn more about AudioEye’s approach for UK organizations. Schedule a demo today.