United Kingdom · GB

United Kingdom accessibility law: Equality Act + PSBAR explained

Post-Brexit, UK domestic accessibility law remains intact: the Equality Act 2010 imposes a reasonable-adjustments duty on service providers, and PSBAR 2018 binds the public sector to WCAG 2.1 AA. UK businesses that sell to EU consumers still fall within the EAA's territorial reach for those transactions, so a UK-based Shopify store with EU customers needs to clear both bars.

Primary law
Equality Act 2010 + Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018
In force from
In force; UK companies selling into EU must also meet EAA from 28 June 2025
Standard
WCAG 2.1 Level AA
Enforcement
Equality and Human Rights Commission (EHRC) + Cabinet Office GDS

Who has to comply

Public-sector covered by PSBAR; private-sector under the Equality Act's reasonable-adjustments duty. UK firms selling to EU consumers also fall under the EAA.

If your service reaches consumers in United Kingdom, EAA enforcement applies the same way it does to a domestic provider. The "country of consumption" rule means a Shopify store run from outside the EU but selling into United Kingdom is covered. There is no carve-out for non-EU sellers.

What the law actually requires

The technical baseline is WCAG 2.1 Level AA. EN 301 549 references WCAG 2.1 Level AA in full and adds a few requirements specific to mobile apps and documents. Beyond the technical bar, United Kingdom requires the following operational items, which auditors check first because they are simple to verify:

  • WCAG 2.1 AA for public sector via PSBAR

  • Reasonable-adjustments duty for private sector

  • EAA conformance for goods/services sold into the EU

Penalties and how enforcement actually works

Civil claims under the Equality Act; uncapped damages on individual claims.

Equality and Human Rights Commission (EHRC) + Cabinet Office GDS runs the audits. They start with the largest covered services and move down. The first cycle of EAA audits in 2025–2026 will focus on visible non-compliance — missing accessibility statements, obvious WCAG violations on the homepage, lack of feedback channel — because those are cheap to detect. Deep technical audits come later.

Most enforcement starts with a complaint or a routine sweep. The first signal is usually a written notice giving you 30–60 days to remediate before fines kick in.

Public-sector obligations

United Kingdom also has a separate public-sector law: Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018. It predates the EAA and remains in force for government and public-funded sites. Public bodies must publish a conformance statement and re-audit periodically.

Practical first steps for a United Kingdom site

If you are starting now and want to land before enforcement, run an automated audit, fix the high-impact issues (contrast, labels, keyboard, focus), publish an accessibility statement, and set up a feedback inbox. That sequence covers 80% of what auditors look for in a first sweep.

  • Run a baseline scan to know your current score

  • Fix critical and serious issues in priority order — these are the ones cited in complaints

  • Publish a public accessibility statement on a stable URL (United Kingdom regulators expect this discoverable)

  • Add a feedback channel and answer within the country-specified window

  • Re-scan after every major release; track regressions

Frequently asked questions

Does Brexit exempt UK firms from the EAA?

For goods or services sold to EU consumers, no. The EAA follows the consumer, not the seller. UK firms with EU customers must meet EAA requirements on those transactions.

Has anyone been sued under the Equality Act for an inaccessible website?

Yes. The most-cited case is Royal National Institute of Blind People v BMI Baby (2012, settled). The duty is well-established; volume of cases is lower than the US but rising.

Accessibility law in nearby jurisdictions

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