United Kingdom accessibility law: Equality Act + PSBAR explained

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

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.

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.

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