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.
The UK is a very large e-commerce market outside the EU post-Brexit, which creates a two-sided obligation for sellers. Domestically, the Equality Act 2010 imposes a reasonable-adjustments duty on service providers and PSBAR 2018 binds the public sector, both to WCAG 2.1 AA. Separately, the EAA follows the consumer, not the seller: a UK-established store that sells to EU consumers still has to clear the EAA bar on those transactions, so a UK Shopify store with German or French customers effectively faces both the Equality Act at home and the EAA abroad.
What the law actually requires
Equality Act + PSBAR sets the technical bar at WCAG 2.1 Level AA. On top of it, Equality Act 2010 + Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 lists these operational duties:
- 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.
The UK does not use market-surveillance fines for private-sector accessibility. Instead, the Equality and Human Rights Commission (EHRC) enforces the Equality Act, but the primary route is individual civil claims, where damages are uncapped per claim and a well-established body of case law (such as the RNIB v BMI Baby matter) underpins the duty. The Cabinet Office / GDS monitors public-sector conformance under PSBAR. This litigation-plus-regulator model is structurally different from the EU's administrative-fine regimes, so a UK seller faces claim risk at home and separate EAA enforcement by an EU member state for its EU-facing sales.
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.
Reading the Equality Act + PSBAR at the source
The law is cited as Equality Act 2010 + PSBAR 2018 (Equality Act 2010 + Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018). Enforcement: Equality and Human Rights Commission (EHRC) + Cabinet Office GDS. Key date: In force; UK companies selling into EU must also meet EAA from 28 June 2025. For the exact wording, read the 3 official references for United Kingdom listed under Sources below.
Sources
- Equality Act 2010 (legislation.gov.uk)
- Public Sector Bodies Accessibility Regulations 2018 (legislation.gov.uk)
- GOV.UK Service Manual: accessibility
- European Accessibility Act (Directive (EU) 2019/882) · European Commission
Links checked 12 October 2026. Not legal advice. Methodology · About Certvo
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.