Website Accessibility Law and UK Small Businesses

Every few months a small business owner forwards us the same email. It warns that their website is breaking accessibility law, that fines are coming, and that a widget costing a few pounds a month will fix it by tomorrow. Most of it is wrong, and the widget is the part that is most wrong.

Accessibility genuinely matters, and there is real law behind it in the UK. But the law says something rather different from what the scare emails claim, and the work that makes a difference is not the work being sold. Here is the honest version — a plain-English summary rather than legal advice, so if your business sits close to any of the lines below, take proper advice.

What UK law actually requires

The Equality Act 2010 is the one that applies to you. It covers anyone providing a service to the public, private businesses included, and requires reasonable adjustments so disabled people are not put at a substantial disadvantage. A website is part of the service you provide, not something separate from it.

Two things about that duty surprise people. It is anticipatory: you are expected to have thought about disabled customers in advance rather than waiting for one to complain. And it names no technical threshold — nowhere does the Act specify a standard, a version or a score. What counts as reasonable is judged against your size, your resources and how much difference the adjustment would make.

Enforcement is thinner than the emails imply. The Equality and Human Rights Commission can investigate, issue unlawful act notices and seek injunctions, and an individual can bring a discrimination claim in the county court. In practice, UK website accessibility disputes have tended to settle rather than run to judgment, which is why there is so little case law to point at.

The Public Sector Bodies Accessibility Regulations 2018, which do require WCAG 2.1 AA and a published accessibility statement, apply to public sector organisations. Unless you deliver a public service under contract, a supplier quoting them at you has not checked.

The European Accessibility Act: check, but do not panic

The European Accessibility Act — Directive (EU) 2019/882 — has applied since 28 June 2025 and has generated a great deal of alarming marketing aimed at UK businesses. It does not cover all websites. It covers a defined list of products and services: e-commerce, consumer banking, e-books, electronic communications, passenger transport services and access to audiovisual media, among others. A brochure site for a plumber, a clinic or a consultancy is not on that list.

Two things bring a UK business into scope. The first is selling to consumers in the EU — the Act follows the market rather than the company's address, so a UK shop taking orders from Dublin or Berlin can be covered despite Brexit. The second is size: it exempts microenterprises providing services, defined as fewer than ten people with an annual turnover or balance sheet total of no more than two million euros. That exemption covers services only, and stops applying the moment you grow past it.

So, the honest summary: if you run a UK service business with a normal website and no EU consumer sales, the EAA is not your problem. If you run an online shop selling into the EU and employ ten or more people, it probably is, and it deserves an hour with someone who knows the detail rather than a widget.

WCAG is the yardstick everyone uses, not the law itself

Nothing in UK law names WCAG. But the Web Content Accessibility Guidelines, published by the W3C, are what regulators, procurement forms and expert witnesses reach for when someone has to decide whether a site is accessible. Version 2.2 was published in October 2023, and Level AA is the level people mean when they say a site is accessible.

That makes it the practical answer to the vagueness of reasonable adjustments: if you are ever asked to show you considered disabled users, saying the site was built and tested to WCAG 2.2 AA is a far stronger answer than an intention. The EU technical standard sitting behind the EAA, EN 301 549, currently references WCAG 2.1 AA — which 2.2 builds on, so aiming at 2.2 AA covers both without having to decide which applies.

The overlay widgets do not do what they claim

Overlay tools — the little accessibility button that opens a panel of contrast and font-size controls — are sold on the promise that one line of JavaScript makes a site compliant. It does not, and there is now a regulator's action to point at.

In January 2025 the US Federal Trade Commission announced an order requiring accessiBe to pay one million dollars over its marketing of accessWidget, which had been advertised as automatically making websites conform to WCAG 2.1 AA. The FTC's complaint alleged that the plug-in failed to make basic components accessible, naming navigation menus, form fields and image descriptions, and that the company had paid for endorsements presented as independent reviews. The final order was approved in April 2025; the company settled without admitting the allegations.

That is a US regulator and it binds nobody here, but the substance travels. What overlays fail at is what matters most, and none of it can be repaired from outside the page: a screen reader needs a heading structure that describes the page, a keyboard user needs a focus order that follows the layout, a form needs labels genuinely tied to their inputs. All of that lives in the markup. And the duty stays with you — buying a widget does not move it to the vendor.

What actually helps, in rough order of impact

If you do nothing else, do these. Between them they cover most of the barriers we find on small business websites:

• —Make everything reachable by keyboard alone, with a visible focus outline
• —Use real headings in a sensible order rather than bold text, so a screen reader user can skim the page the way a sighted visitor does
• —Write meaningful alt text for images that carry information, and empty alt text for decorative ones
• —Give every form field a visible label tied to the input — placeholder text that vanishes as you type is not a label
• —Check colour contrast: body text needs 4.5:1 against its background, large text 3:1
• —Never signal anything by colour alone — an invalid field needs words, not just a red border
• —Caption videos and provide a text alternative for anything audio-only
• —Let the page reflow at 200 per cent zoom, and never disable pinch-zoom on mobile

How to check your own site in half an hour

Start with the keyboard. Push the mouse aside, load your homepage and press Tab repeatedly. You should always be able to see where you are, reach every link, button and form field, and open and close the mobile menu without touching the screen. Most small business sites fail in the first minute, usually on a custom dropdown or a cookie banner that traps focus and will not let go.

Then run a free automated checker — Lighthouse is built into Chrome's developer tools, and axe DevTools is a free browser extension. Both are worth running and both are limited: an automated test can tell you an image has no alt attribute, but not whether the alt text you wrote is any use. Treat a clean report as the floor rather than the finish.

Finally, zoom to 200 per cent and read the site on your phone. Overlapping text or a column running off the screen is a permanent experience for some visitors.

The commercial case, without the inflated numbers

You will find no shortage of articles quoting a precise share of the population as disabled and multiplying it by your revenue. We will not, because the number that matters is your own and nobody has measured it.

What can be said plainly is that accessibility barriers are not exotic. They affect people with low vision, people reading a phone in bright sunlight, people whose hands are unsteady, people navigating by keyboard because the trackpad has died. A form nobody can complete is a lost enquiry whatever the reason.

There is a useful overlap, too: proper heading structure, descriptive link text, labelled forms and clean semantic markup are the same things that make a page legible to search engines and quotable by AI answer engines. And accessibility questions now turn up routinely on tender and supplier forms, where "we have not looked at it" is an awkward answer to give.

How we build for this

Every site we build is designed and tested to WCAG 2.2 AA as standard — keyboard operability, contrast, heading structure, labelled forms and the rest — rather than offered as an upgrade afterwards. It costs very little during a build and is tedious to retrofit, which is the whole argument for doing it at the right moment.

If you are not sure where your current site stands, we are happy to run through the checks above with you and tell you plainly what we find. Often the answer is a handful of fixes rather than a project, and when it is, we would rather say so.