Website Accessibility: What the Equality Act Actually Requires

If a step at your front door kept a wheelchair user out, you'd notice, and most owners would sort it without being asked. On a website the same thing happens silently. A visitor who can't read your grey-on-white opening times, or can't tab to the booking button, just leaves, and no bell rings. UK law has a view on this, and it's clearer than most owners realise: your website is a service, and the Equality Act 2010 applies to it the same way it applies to your premises.

Think of this as a companion to our guide to GDPR and the DUAA, in the same spirit. The law sounds scarier than it is, the list of things you genuinely need to do is short, and most of it is what a decent business would want to do anyway. The difference with accessibility is that the commercial case is far bigger than the legal one, so we'll be honest about both. As ever, this is general guidance rather than legal advice.

What the law actually says

Section 29 of the Equality Act 2010 says that anyone providing a service to the public must not discriminate against a person requiring the service (Equality Act 2010, s.29). It applies whether the service is paid for or free, and it doesn't matter how the service is delivered. A booking page, an online menu, a contact form: all of it counts as providing your service, which is why the Equality and Human Rights Commission's guidance treats websites as squarely covered (EHRC).

Sitting underneath that is the duty to make reasonable adjustments. Where something about the way you operate puts disabled people at a substantial disadvantage, you have to take reasonable steps to remove it. For a physical shop that might mean a ramp or a lower counter. For a website it means text people can read, forms people can fill in, and buttons that work without a mouse.

The detail that catches people out is that for service providers this duty is anticipatory. You owe it to disabled customers in general, in advance, not to one named person after they've complained (EHRC). You're expected to have thought about access before anyone gets stuck, exactly as you'd build the ramp before the first wheelchair arrives at the door. Waiting for a complaint and then fixing things is already too late as far as the Act is concerned.

Luckily, the word "reasonable" matters a lot here. What's reasonable for a high-street bank with a development team is different from what's reasonable for a café with a five-page site. Nobody expects you to commission a specialist audit of your Sunday roast menu. They do expect the basics, and as we'll see, the basics are cheap.

Enforcement is rare

In the United States, web accessibility suits under the ADA are an industry, with thousands of cases filed every year. The UK has nothing like that. Equality Act claims about websites are brought by individuals in the county court, they're rare, and the ones that happen tend to settle quietly. The best-known example is from 2012, when the RNIB took legal action against the airline bmibaby on behalf of two blind customers who couldn't book flights after a site redesign. The case settled out of court, with the airline agreeing to make its site accessible (Civil Society). There was no big judgment or headline fine, just a letter, some negotiation and a fix that should have happened years earlier.

So an inaccessible café website is very unlikely to land you in court, and we won't pretend otherwise. The duty is still real, though, and you'd be on the wrong side of it if a claim ever came. And while you're weighing up that small legal risk, you're losing customers every day, which is the cost we'd pay more attention to.

WCAG: the standard everyone actually uses

The Equality Act never tells you what an accessible website looks like. The gap is filled by the Web Content Accessibility Guidelines (WCAG), an international standard published by the W3C, the body that maintains web standards. The current version, WCAG 2.2, was published in October 2023 (W3C).

WCAG has three levels: A, AA, and AAA. Level AA of WCAG 2.2 is the de facto benchmark. It's the level UK public sector websites are legally required to meet (GOV.UK). Large companies also put it in their procurement contracts, and it's what any competent developer means when they say "accessible". For a private business it isn't written into law, but if you ever had to show a court you'd made reasonable adjustments, meeting WCAG 2.2 AA is how you'd do it.

Without the spec language, AA mostly asks for ordinary things: text dark enough to read against its background, a description on images that carry meaning, forms with proper labels, and a site you can use from the keyboard alone, with a visible marker showing where you are. None of it limits how good a site can look, and plenty of beautiful sites pass while plenty of ugly ones fail.

The customers you never see leaving

So why does nobody notice? When a disabled visitor hits a barrier on your site, they almost never tell you. The Click-Away Pound survey, the UK's main study of disabled online shoppers, found that only 8% of disabled customers who have difficulty with a site contact the owner about it, and the rest just leave. In fact 69% click away from sites they find difficult to use, and they took an estimated £17.1 billion of UK online spending with them (Click-Away Pound 2019). From your side of the counter, it looks like a quiet Tuesday.

The wider figure is bigger still. There are around 16 million disabled people in the UK, and the combined spending power of households with at least one disabled member, often called the Purple Pound, is estimated at £274 billion a year (We Are Purple). They're loyal customers too. The same Click-Away Pound survey found 86% of shoppers with access needs would pay more on an accessible site than buy the identical product cheaper on a hard-to-use one, and 83% limit their shopping to sites they already know work for them. Win them once and they keep coming back, partly because so few of your competitors have bothered.

It also reaches more people than you might picture. Accessibility helps the customer with arthritis who finds small tap targets fiddly, the older regular who browses with text zoomed, anyone reading your menu on a phone in bright sunlight. When you build for those visitors, everyone else gets a better site as well.

The four failures behind almost every broken site

Each year WebAIM, a research group at Utah State University, runs an automated accessibility check across the home pages of the top million websites. The 2026 edition found detectable WCAG failures on 95.9% of them, averaging 56 errors per page, and 96% of all the errors fell into just six categories (WebAIM Million 2026). Four of those six are the ones that matter for a small business site, and every one has a cheap fix.

Text you can barely read

Low-contrast text appeared on 83.9% of home pages, making it the most common failure by a distance (WebAIM Million 2026). It's the pale grey body text on a white background, the white headline laid over a busy photo. Designers love it, but anyone with ageing eyes or a cheap screen in daylight can't read it at all. The fix costs nothing: paste your text and background colours into WebAIM's free contrast checker and aim for the 4.5:1 ratio AA requires for body text. Usually it means nudging a grey two shades darker, and your brand will be fine.

Images with no text alternative

Missing alternative text turned up on 53.1% of home pages (WebAIM Million 2026). Alt text is a short written description attached to an image, and it's what a screen reader speaks aloud to a blind visitor. Without it, a screen reader says nothing useful about the photo of your specials board. The fix is a sentence per image, written into the image settings of whatever builds your site: describe what matters ("today's specials: leek and potato soup, fish pie"), and leave the description empty for purely decorative photos so screen readers skip them. As a side benefit, Google reads alt text too.

Form fields with no label

Unlabelled form inputs appeared on 51% of home pages (WebAIM Million 2026). This one's sneaky, because the field often has grey placeholder text inside it that looks like a label. To a screen reader it's just "edit text, blank", with no clue whether it wants a name, an email, or a party size, and the placeholder vanishes the moment you start typing. The fix is to use a real, visible label above each field. A quick test: click the label text itself, and if the cursor jumps into the field, it's wired up properly.

Links that say nothing

Empty links were found on 46.3% of home pages (WebAIM Million 2026), and their cousin, the "click here" link, is everywhere. Screen reader users often pull up a list of every link on a page to get around quickly, and a list that reads "click here, click here, read more, here" doesn't help them at all. The fix is link text that describes the destination: "view our menu", "book a table", "directions to the salon". It reads better for everyone and search engines prefer it too.

What to ask your web developer for

You don't need to learn the spec, you just need one sentence in your next brief and a few good questions.

1. Put "built to WCAG 2.2 Level AA" in the brief, and in writing. A developer who knows their trade will nod, and if one looks blank, that tells you something useful.
2. Ask them to demonstrate the site keyboard-only before handover. Menu, booking, contact form, the lot, without touching the mouse.
3. Ask for the contrast check at design stage, when your brand palette is chosen and before anything's built.
4. Ask them to run the free WAVE checker on the finished site and fix what it flags. It catches the four failures above in seconds.
5. Be sceptical of accessibility "overlay" widgets, the one-line scripts that promise instant compliance. They sit on top of broken code and leave it broken, and the underlying duty is about whether disabled people can actually use the service.

If you're commissioning a new site anyway, accessibility done at build time costs close to nothing, and it's fixing things afterwards that gets expensive.

The free ten-minute self-check

You can audit the basics yourself tonight, in the same spirit as our ten-minute website speed audit. You won't need any tools or jargon.

1. Put the mouse down. Press Tab repeatedly and move through your homepage with the keyboard alone. Can you always see which link or button you're on? Can you open the menu, reach the contact form, and submit it? If a cookie banner or popup appears, can you close it? If you get stuck or lost, so does anyone who can't use a mouse.
2. Zoom to 200%. Hold Ctrl (or Cmd on a Mac) and press + a few times. Text should reflow and stay readable. If columns overlap, words get chopped off, or buttons vanish, your low-vision visitors have the same problem at normal zoom.
3. The squint test. Lean back and squint at the screen until it blurs. Whatever fades from view first, often pale grey text and washed-out buttons, is what visitors with imperfect eyesight lose all the time. If your phone number or "book now" button disappears, that's your priority.

Those three checks take ten minutes, and you'll know more about your site's accessibility than most owners ever learn. Whatever fails, send this article to whoever looks after your site, with the WebAIM list, and ask them to fix the four big ones first.

The ramp you build before anyone asks

The anticipatory duty is really the hospitality instinct written into law. You hold the door before the pram reaches it, without waiting to be asked. Owners who think that way offline usually only get it wrong online because nobody told them the step was there.

The same care that produces an accessible site, with real labels, readable text and links that say where they go, is the care that produces a fast, well-built one. So accessibility is a good way to judge build quality without reading any code. Run the ten-minute test on your own site this week, and the next time someone pitches you a redesign, run it on theirs.

References

• Equality Act 2010, section 29 (Provision of services), legislation.gov.uk
• Terms used in the Equality Act, Equality and Human Rights Commission (reasonable adjustments and the anticipatory duty)
• Web Content Accessibility Guidelines (WCAG) 2.2, W3C (published October 2023)
• Understanding accessibility requirements for public sector bodies, GOV.UK (WCAG 2.2 AA as the public sector legal standard)
• The WebAIM Million, 2026 report, WebAIM (failure rates: 95.9% of pages, low contrast 83.9%, missing alt text 53.1%, missing form labels 51%, empty links 46.3%)
• The Click-Away Pound Report 2019, Rica and Freeney Williams (69% click away, £17.1bn, 86% pay more, 8% contact the owner)
• The Purple Pound, We Are Purple (£274bn household spending power, 16 million disabled people)
• RNIB launches legal action over accessibility of bmibaby website, Civil Society News (2012, settled out of court)