Equality Act 2010

The Equality Act 2010 is the main anti-discrimination law applying in England,
Scotland and Wales. It protects people from discrimination in employment, services,
public functions, education, associations and other areas of public life.

Website accessibility is relevant because organisations increasingly provide
information, purchases, banking, bookings, applications and customer support through
digital services. When a digital barrier places a disabled person at a substantial
disadvantage, the organisation may need to take reasonable steps to remove or reduce
that disadvantage.

The Act does not create a simple rule stating that every private website must achieve
a particular automated score. Accessibility should instead be managed as part of the
organisation’s wider duty not to discriminate and, where applicable, to make
reasonable adjustments.

Where does the Equality Act 2010 apply?

The Equality Act 2010 applies in:

• England.
• Scotland.
• Wales.

Northern Ireland has separate anti-discrimination legislation, including the
Disability Discrimination Act 1995.

What is disability under the Equality Act?

In general, a person is disabled under the Act when they have a physical or mental
impairment that has a substantial and long-term adverse effect on their ability to
carry out normal day-to-day activities.

Whether an individual meets the legal definition depends on their circumstances.
Organisations should not assume that disability is always visible or permanent.

How does the Act protect disabled people?

The Equality Act contains several forms of protection that may be relevant to digital
services and employment.

What is the reasonable-adjustment duty?

Reasonable adjustments are changes intended to prevent disabled people from being
placed at a substantial disadvantage compared with people who are not disabled.

Depending on the situation, an adjustment may involve:

• Changing a policy, process or method of providing a service.
• Removing or working around a physical or digital barrier.
• Providing information in an alternative accessible format.
• Providing an auxiliary aid or service.
• Offering an accessible alternative method for completing a task.

For a website or digital service, this might mean correcting an inaccessible form,
providing an accessible document, supporting keyboard use or ensuring that a customer
can obtain the same information through an accessible channel.

Does the Equality Act apply to websites?

The Act is not written as a website-development standard. However, organisations
providing goods, facilities or services must consider whether the way their digital
service is designed or operated disadvantages disabled people.

A website may therefore be relevant when it is the method through which a person:

• Purchases goods or services.
• Books an appointment or ticket.
• Applies for a job.
• Accesses banking or account information.
• Completes a government or public-service transaction.
• Contacts customer support.
• Receives important documents or instructions.
• Participates in education or training.

If inaccessible design prevents or seriously hinders access to the service, the
organisation should assess what reasonable steps can be taken.

Examples of digital barriers

• A form cannot be completed using a keyboard.
• Buttons have no meaningful accessible name.
• Error messages are shown visually but not announced to screen readers.
• Text has insufficient contrast against its background.
• Important content is available only in an inaccessible PDF.
• A video contains essential speech but has no captions.
• A checkout process prevents screen-reader users from completing payment.
• Text cannot be enlarged without content overlapping or disappearing.
• A user becomes trapped inside a menu or dialog.

Is WCAG legally required?

For most private-sector organisations, the Equality Act does not simply state that
a website must conform to a specific version of WCAG.

WCAG is nevertheless widely used as the recognised technical framework for assessing
web accessibility. It gives organisations, developers and auditors testable criteria
for areas such as keyboard access, contrast, forms, structure and assistive-technology
compatibility.

Meeting WCAG can provide valuable evidence of a structured accessibility process,
but accessibility should not be reduced to a checklist. Organisations must also
consider real user journeys, content, documents, support processes and reasonable
adjustments requested by individuals.

Learn more about the
Web Content Accessibility Guidelines.

Public-sector websites and mobile applications

Public-sector bodies are subject to additional requirements under the Public Sector
Bodies (Websites and Mobile Applications) Accessibility Regulations 2018.

Government guidance currently states that covered public-sector websites and mobile
applications should:

• Meet WCAG 2.2 level AA.
• Publish an accessibility statement.
• Keep the statement accurate and updated.
• Provide accessible alternatives when necessary.
• Respond appropriately to accessibility requests and complaints.

These regulations operate alongside the Equality Act rather than replacing it.

Private businesses and service providers

Businesses that provide services to the public should consider accessibility before
a disabled customer encounters a barrier. The duty to make reasonable adjustments
is generally anticipatory for service providers, meaning organisations should think
in advance about barriers that disabled people may face.

Relevant organisations can include:

• Online retailers.
• Banks and financial-service providers.
• Travel and transport providers.
• Healthcare and booking services.
• Education and training providers.
• Hospitality and leisure businesses.
• Professional-service firms.
• Membership organisations and associations.

Employment and recruitment websites

The Equality Act also applies to employment and recruitment. Employers must avoid
disability discrimination and make reasonable adjustments for disabled applicants
and workers.

Digital recruitment barriers may include:

• An application form that cannot be completed with assistive technology.
• An online assessment that has an inaccessible time limit or interaction method.
• Documents that cannot be read by a screen reader.
• Interview-booking tools that cannot be operated by keyboard.
• No accessible method for requesting an adjustment.

Employers should include accessibility in recruitment platforms, internal systems,
training portals and workplace software.

What makes an adjustment reasonable?

Reasonableness is assessed according to the circumstances. Factors may include:

• How effective the adjustment would be.
• The practicality of making it.
• The organisation’s size and resources.
• The financial and operational cost.
• The seriousness of the disadvantage.
• The availability of alternative solutions.
• Whether external assistance or funding is available.

A business should not assume that a change is unreasonable merely because it requires
work. Many accessibility corrections are relatively straightforward when addressed
through shared components, templates and design systems.

Alternative formats are not a complete substitute

Providing telephone support or an alternative document can sometimes be an important
reasonable adjustment. However, an alternative should not automatically be treated
as equivalent when it is slower, less private, available only during limited hours or
prevents the user from completing the same task independently.

The preferred approach is generally to make the primary digital service accessible
while maintaining accessible support options for users who need them.

Accessibility statements

An accessibility statement is mandatory for many public-sector websites and mobile
applications. Private organisations may also publish one voluntarily as part of
their accessibility programme.

A useful statement can explain:

• The organisation’s accessibility commitment.
• The standards or methods used for testing.
• Known accessibility limitations.
• How users can request an accessible format or adjustment.
• How to report an accessibility problem.
• When the statement and website were last reviewed.

A statement should be honest and kept up to date. It should not claim full compliance
unless that claim is supported by current evidence.

How to reduce digital-accessibility risk

1. Identify essential services:
   list the digital journeys people rely on to access information, goods, employment
   or support.
2. Audit representative journeys:
   combine automated checks with keyboard, screen-reader and manual testing.
3. Prioritise substantial barriers:
   address issues that prevent users from completing critical tasks.
4. Assign responsibility:
   route findings to design, development, content, product or QA.
5. Correct shared components:
   resolve repeated problems at template or design-system level.
6. Verify corrections:
   confirm that each barrier has actually been removed.
7. Provide an adjustment process:
   give users a clear way to request help or an alternative format.
8. Monitor ongoing changes:
   review accessibility after releases, redesigns and content updates.

Automated testing is not enough

Automated scanners can identify many technical issues, but they cannot determine
every legal or usability question.

Manual review is still needed to assess:

• Whether alternative text communicates the correct meaning.
• Whether keyboard focus follows a logical path.
• Whether form errors are understandable.
• Whether a screen-reader user can complete an entire transaction.
• Whether an alternative process provides genuinely equivalent access.
• Whether an adjustment is reasonable in the organisation’s circumstances.

Documenting accessibility work

Organisations should maintain clear evidence of their accessibility process,
including:

• Audit scope and dates.
• Pages, components and user journeys tested.
• Findings and affected users.
• Remediation decisions and responsible owners.
• Completed corrections.
• Verification results.
• Known limitations and planned improvements.
• Requests for reasonable adjustments and how they were handled.

Documentation does not remove legal responsibility, but it helps demonstrate that
accessibility is being managed through a deliberate and ongoing process.

How Pluro supports accessibility management

Pluro is an accessibility workflow platform that helps organisations manage
findings from detection through verified remediation.

Teams can use Pluro to organise automated and manual findings, preserve behaviour
evidence, assign responsibilities, provide remediation guidance and record
verification history.

Pluro is not an overlay, legal adviser or one-click compliance solution. It supports
the operational work needed to identify barriers, coordinate corrections and maintain
accessibility as websites change.

Equality Act digital-accessibility checklist

• Identify digital services used by customers, applicants and employees.
• Consider accessibility before users report a barrier.
• Provide a clear reasonable-adjustment process.
• Test critical journeys with keyboard and assistive technologies.
• Use WCAG as a technical assessment framework.
• Correct barriers in shared templates and components.
• Provide accessible documents and support channels.
• Verify fixes before closing findings.
• Review third-party services and plugins.
• Monitor accessibility after future changes.

Important notice

This page provides general information and does not constitute legal advice.
The application of the Equality Act depends on the organisation, service and
individual circumstances. Obtain advice from a qualified UK legal professional
when assessing specific legal duties, disputes or reasonable adjustments.

Read the official

Equality Act 2010
.

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