Equality Act 2010 (UK)

The Equality Act 2010 is the primary anti-discrimination legislation in
England, Scotland, and Wales. While it does not reference websites or digital
services explicitly, it has been interpreted to require that organisations
providing services to the public make reasonable adjustments to ensure those
services are accessible to disabled people — including digital services.
^[1]

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Protected characteristics

The Equality Act protects people with disabilities, defined as a physical or
mental impairment that has a substantial and long-term adverse effect on the
ability to carry out normal day-to-day activities. This definition covers a
wide range of conditions including visual impairments, hearing loss, motor
disabilities, cognitive disabilities, and mental health conditions.

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The duty to make reasonable adjustments

Under the Equality Act, service providers have a duty to make reasonable
adjustments to remove barriers that put disabled people at a substantial
disadvantage compared to non-disabled people. For digital services this means:

• Making websites operable by keyboard for users who cannot use a mouse
• Providing alternative text for images for screen reader users
• Ensuring sufficient colour contrast for users with low vision
• Providing captions for video content for deaf users
• Ensuring forms are labelled correctly for screen reader users

^[2]

What counts as reasonable depends on the size and resources of the organisation,
the cost of the adjustment, and how much it would improve access. However,
many accessibility improvements are low cost relative to the barriers they
remove, making the reasonable adjustment threshold relatively easy to meet
for most digital accessibility requirements.

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Who is affected

The duty to make reasonable adjustments applies to anyone providing a service
to the public — public sector bodies, private businesses, charities, and
voluntary organisations. It applies regardless of whether the service is
provided free or for payment.

Employers also have obligations under the Equality Act in relation to
internal digital tools and systems used by employees with disabilities.
^[1]

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Public sector equality duty

Public sector organisations in England, Scotland, and Wales are subject to
an additional Public Sector Equality Duty (PSED) requiring them to actively
advance equality of opportunity. For digital services, this reinforces the
expectation that public sector websites and applications are accessible,
complementing the separate Public Sector Bodies Accessibility Regulations.

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Public Sector Bodies Accessibility Regulations

The Public Sector Bodies (Websites and Mobile Applications) Accessibility
Regulations 2018 are UK law transposing the EU Web Accessibility Directive
into domestic law. Post-Brexit, this legislation continues to apply in the UK
independently of the EU directive. It requires public sector websites and
mobile apps to meet WCAG 2.1 Level AA and publish accessibility statements.
^[3]

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Enforcement

Individuals who experience discrimination on the basis of disability can bring
claims under the Equality Act in the county court. The Equality and Human
Rights Commission (EHRC) also has powers to investigate and take action against
organisations that fail to comply with their equality duties.

Enforcement specifically relating to public sector website accessibility is
overseen by the Cabinet Office, which monitors compliance with the Public
Sector Bodies Accessibility Regulations.

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References

1. UK Government. Equality Act 2010. https://www.legislation.gov.uk/ukpga/2010/15/contents ↑
2. Equality and Human Rights Commission. Equality Act 2010: guidance. https://www.equalityhumanrights.com/equality/equality-act-2010 ↑
3. UK Government. Understanding accessibility requirements for public sector bodies. https://www.gov.uk/guidance/accessibility-requirements-for-public-sector-websites-and-apps ↑