Website accessibility for UK small businesses: Equality Act and WCAG 2.2

The legal duty: the Equality Act 2010

In England, Scotland and Wales, section 29 of the Equality Act 2010 makes it unlawful to discriminate against disabled people when providing services to the public, whether paid or free. Part of that is the duty to make reasonable adjustments in section 20. If the way you provide a service puts disabled people at a substantial disadvantage, you must take reasonable steps to avoid it, which can include providing information in an accessible format.

For service providers the duty is anticipatory (Schedule 2). The Equality and Human Rights Commission’s statutory code of practice for services explains that you should think about the barriers disabled people could face before anyone asks, rather than waiting for a complaint. The EHRC’s updated code came into force on 5 August 2026. It doesn’t create new law, but courts must take relevant parts of it into account.

What counts as “reasonable” depends on your size, your resources, the cost and how much difference the change makes. A sole trader isn’t expected to do what a bank does. Small, cheap fixes that remove real barriers, such as labelled forms, readable contrast and a site that works with a keyboard, are hard to argue are unreasonable.

In Northern Ireland, the equivalent duties are in the Disability Discrimination Act 1995.

Public sector rules don’t apply to you, but they set the benchmark

Public sector bodies have a specific legal duty, under the 2018 accessibility regulations, to meet WCAG 2.2 AA and publish an accessibility statement. Private businesses are not covered by those regulations. Even so, WCAG 2.2 AA is the standard UK government, auditors and most accessibility professionals measure against. That makes it the most sensible yardstick if you ever need to show you took reasonable steps.

WCAG 2.2 in plain English

The Web Content Accessibility Guidelines 2.2 are published by the W3C. They are built on four principles: content must be perceivable, operable, understandable and robust. Level AA means meeting all the Level A and AA success criteria. GOV.UK’s overview of WCAG 2.2 is a readable summary.

The criteria added in 2.2 that most often affect small business sites (see the W3C’s What’s new in WCAG 2.2):

Focus not obscured (2.4.11, AA): a sticky header, chat bubble or cookie banner mustn’t completely hide the item a keyboard user has moved to.
Target size (2.5.8, AA): buttons and links should be at least 24 by 24 CSS pixels, or have enough space around them.
Dragging movements (2.5.7, AA): anything done by dragging, such as a slider, needs a single-tap alternative.
Consistent help (3.2.6, A): if you offer contact details or a help link, keep it in the same place on each page.
Redundant entry (3.3.7, A): don’t make people type the same information twice in one process.
Accessible authentication (3.3.8, AA): don’t rely on memory or puzzle tests to log in. Allow password managers and pasting.

If you sell to customers in the EU

The European Accessibility Act (Directive 2019/882) has applied in EU countries since 28 June 2025. It covers e-commerce services, among others, and can apply to UK businesses selling online to EU consumers. Microenterprises providing services (fewer than 10 staff and annual turnover or balance sheet of no more than €2 million) are exempt from the service requirements. If EU sales matter to you, check how the rules apply in the countries you sell into.

Overlays and widgets

An accessibility “overlay” or toolbar does not by itself make a site accessible. The barriers are in your templates and content: missing labels, poor contrast, broken heading order, keyboard traps. Fixing those directly is what makes the difference. Automated scanners help, but they catch only some issues. Manual checks with a keyboard and a screen reader find the rest.

Quick checklist

Every image that carries meaning has alt text; decorative images have empty alt
Body text has at least 4.5:1 contrast with its background (3:1 for large text, buttons and form borders)
You can reach and use every link, menu, button and form with the Tab and Enter keys alone
A visible focus outline shows where you are, and no sticky bar or cookie banner hides it
Each page has one H1, and headings follow in order
Every form field has a visible label, and errors say what went wrong and how to fix it
Buttons and links are at least 24×24 pixels, or well spaced
Videos have captions; audio has a transcript
The page still works zoomed to 200%, and reflows on a narrow phone screen
Link text makes sense out of context (no lone “click here”)
Log-in allows paste and password managers, with no puzzle tests
Contact or help links stay in the same place on every page

FAQ

Is website accessibility a legal requirement for UK small businesses?

There’s no UK law that names WCAG for private websites. But the Equality Act 2010 requires service providers, including those providing services online, to make reasonable adjustments for disabled people, and that duty is anticipatory. WCAG 2.2 AA is the usual benchmark for showing you’ve taken reasonable steps.

Do I need an accessibility statement?

The legal requirement to publish one applies to public sector bodies. For a private business it’s optional, but a short statement saying what you’ve done and how to ask for help or an alternative format is good practice.

Is WCAG 2.1 still acceptable?

WCAG 2.2 builds on 2.1 and adds new criteria, so meeting 2.2 AA also meets 2.1 AA. UK public sector monitoring now tests against 2.2, so it’s the sensible target.

Will an accessibility widget make my site compliant?

No widget can guarantee that. Most barriers sit in the site’s code and content, so they need fixing there.

Is this legal advice?

No. It’s a general summary of the rules with links to official sources.

Official sources

Laws and guidance change. Check the sources above for the latest position. For advice on your own circumstances, consult a solicitor.

Website accessibility for UK small businesses: the Equality Act, WCAG 2.2 and a quick checklist