Website accessibility law UK: keyboard and screen reader use
At a glance
UK-12MediumEquality Act 2010, ss. 20, 29 and Sch. 2; EHRC Code of Practice: Services, public functions and associations (2026), paras. 5.45, 7.22 and 7.36
Peeky looks for the barriers an automated engine can see on public pages, such as missing alt text, unlabelled fields, weak contrast and keyboard traps.
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The rule
Section 29 of the Equality Act 2010 covers “a person (‘a service-provider’) concerned with the provision of a service to the public or a section of the public (for payment or not)”. Such a provider “must not discriminate against a person requiring the service by not providing the person with the service” (s. 29(1)), and must not discriminate in the terms on which it provides the service or by subjecting the person to any other detriment (s. 29(2)). Section 29(7) adds that “a duty to make reasonable adjustments applies to” a service-provider.
Section 20 sets out what the duty is. The first requirement applies “where a provision, criterion or practice of A’s puts a disabled person at a substantial disadvantage in relation to a relevant matter in comparison with persons who are not disabled”, and asks A “to take such steps as it is reasonable to have to take to avoid the disadvantage” (s. 20(3)). The third requirement asks for an auxiliary aid where a disabled person would otherwise be at that disadvantage (s. 20(5)). Where either relates to information, the reasonable steps “include steps for ensuring that in the circumstances concerned the information is provided in an accessible format” (s. 20(6)). The provider is not entitled to require the disabled person to pay any of its costs of complying (s. 20(7)). For services the applicable schedule is Schedule 2.
The Act does not use the words website, screen reader or WCAG. It works through the general duty, and the Code applies it to online services.
The EHRC’s statutory Code, presented to Parliament in 2026, says goods and services “provided remotely through mediums like websites or apps” are within the Act’s reach (para. 11.74). It also says the duty is anticipatory: providers “must proactively consider the barriers that disabled people could face and take action to address those barriers”, before an individual disabled person tries to use the service (para. 7.22). Its own example is a legal services firm whose website has “all its text embedded within graphics”: blind users cannot change the font size or use text-to-speech software, which “places those with a visual impairment at a particular disadvantage” and, the Code says, “will be indirect disability discrimination unless the provider can justify it” (para. 5.45).
What counts as reasonable “depends on all the circumstances of the case”. The Code lists the type of service, “the nature of the service provider, … its size and resources” and the effect of the disability on the individual (para. 7.36). Factors include whether the step would be effective, whether it is practicable, its cost and disruption, and the resources available (para. 7.37). Size is a factor in the judgment but not an exemption: “no service provider is exempt from duties under Part 3 because of size” (para. 1.22).
No fixed penalty is attached to a website that fails the duty. The consequence is a civil claim, covered below. Neither the Act nor the Code names WCAG or any other technical standard, so what is reasonable is argued case by case. PeekWell tests against WCAG 2.1 level AA because it is the common technical reference, not because the Act requires it. EU-10 explains the standard that sits behind the EU rule.
What PeekWell checks and how
UK-12 asks the same question as EU-10: can an automated engine find barriers for keyboard and screen reader users on the public pages it visited? The answer comes from the page as the browser renders it.
The scan opens key public pages in a headless browser and runs an accessibility engine, axe-core with Pa11y alongside it, against each one. Failed rules are recorded by WCAG success criterion at level AA. It looks for missing alt text, form fields without labels, text with too little contrast, missing landmarks, keyboard traps and a missing page language. The decision comes from the engine’s output, not from a language model. The report frames a finding as claim risk, because the Act attaches no fixed fine.
The scan has limits, and the report says so. It sees the public pages it visited and nothing behind a sign-in. It does not sign in or submit forms. An automated engine finds only part of what a person using a screen reader would find: the axe-core maintainers say it finds on average 57% of WCAG issues, and that it returns elements as “incomplete” where it cannot be certain. It cannot judge whether a step was reasonable for your business, which is the legal question. A Passed means the expected behaviour was observed on the pages scanned. It does not say the site complies.
Why it matters for a company
The consequence in this jurisdiction is a claim, and it is brought by the person affected, not by a regulator checking a list. As of 7 October 2026 we could not confirm any court or regulator decision about a company website under the Act at the court’s or regulator’s own page, so this section rests on the statute and the Code, and names no company.
A person who believes they were discriminated against in the provision of services “may bring civil proceedings”, normally in the county court in England and Wales or the sheriff court in Scotland (paras. 14.6 and 14.7). Court action must start within six months minus one day of the alleged act, as the Code puts it (para. 14.13; s. 118), and the court can extend that where it is just and equitable (s. 118(1)(b); Code, citing s. 140AA). The county court can grant an injunction and award damages, and damages “may include compensation for injured feelings” (paras. 14.46 and 14.47). On damages the Code adds that a claimant should also try to show “some detriment as a result of the breach of duty” (para. 7.56).
Three consequences follow. An injunction is an order to change the site, so the remedy can cost more than the damages. The duty is anticipatory, so “we had no complaint” does not answer what the company had thought about in advance. And section 20(7) bars the company from passing the cost of an adjustment to the disabled person.
We found no UK regulator publication comparable to the Dutch ACM’s survey under the EU rule. The EU position is in EU-10, and the much heavier US litigation record is in US-06.
Smaller companies and larger companies
The Act has no size exemption. The Code says small providers “may have more informal practices, fewer written policies and be more constrained by financial resources”, and that size and resources are part of what is reasonable (paras. 1.22 and 7.36). A small company is not excused, but what it is expected to do is scaled to what it can do.
In a small company the site is usually a theme on a hosted platform with a few plugins. The barriers come from the template and the content: product photos without descriptions, a contact form whose fields have only placeholder text, grey text on a pale background, a menu the Tab key cannot reach. Template edits fix most of it.
In a larger company the same barriers arise from scale. Several teams and suppliers change the site, and a release can undo a fix. The resources factor in paragraph 7.37 cuts the other way: a larger business has more means, so more is reasonable to expect. The gap is usually process, with no accessibility tests in the release pipeline and no record of what was checked and when.
Enforcement cases
Published decisions about other companies, listed for context. Each links to the authority's own page. They say nothing about any particular website.
Larger companies
No decision is listed here yet.
Smaller companies
No court or regulator decision about a company website under the Equality Act could be confirmed at the court's or regulator's own page. The EHRC's own Code gives an example of a website that excludes blind users, but it is an illustration, not a decided case.
How to fix it
- Try your own site with the keyboard. Put the mouse away and press Tab through the home page, a product or service page and your contact or checkout form. Note where you cannot reach a control, cannot see where you are or cannot leave a pop-up. WCAG 2.1.2 asks that focus can always move away, and 2.4.7 that the focus indicator is visible.
- Give every picture and control a name. Meaningful images need a text alternative (WCAG 1.1.1), and form fields need a visible label tied to the field, not placeholder text alone.
- Check contrast. WCAG 1.4.3 asks for a ratio of at least 4.5:1 for normal text and 3:1 for large text. Browser developer tools show the ratio for any element.
- Set the page language. WCAG 3.1.1 asks that the language of each page can be determined by software.
- Offer a way to tell you about a barrier. Add a contact route on every page, and keep a record of what you changed in response. A written trail shows what the business considered in advance.
- Re-scan. Run a scan after each change. A finding should disappear once the engine stops reporting that rule. Then test with a screen reader yourself or with people who use one, because the engine will not catch everything.
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<input id="phone" name="phone" type="tel" autocomplete="tel">Whether the steps you take are reasonable for your business is a question for your legal adviser, and Peeky reports only what it sees.
Questions
Is website accessibility a legal requirement in the UK?
For a business that serves the public, yes, through the duty to make reasonable adjustments in the Equality Act 2010. The EHRC Code says services provided remotely through websites or apps are covered.
There is no separate statute for private sites that sets a technical standard. The rule has the wording.
Is WCAG a legal requirement in the UK?
Not by name. Neither the Equality Act nor the EHRC Code mentions WCAG.
A court asks whether you took the steps it was reasonable to take. WCAG is a common technical reference and testing tools report against it, which is why Peeky does too.
Does the European Accessibility Act apply in the UK?
It is EU law, so it does not govern a site that only serves visitors in the UK. It can reach a UK business that offers services to consumers in the EU.
The Directive defines a service provider as anyone who provides a service on the Union market or makes offers to consumers in the Union. EU-10 has the detail.
What are reasonable adjustments for a website?
They are the steps it is reasonable for your business to take so that disabled visitors are not at a substantial disadvantage. The EHRC Code says this depends on the service, the provider's size and resources, and how the disability affects the person.
For a developer it usually starts with keyboard use, text for images, labels on fields and readable contrast.
Can someone take a UK business to court over an inaccessible website?
Yes. A disabled person can bring a civil claim, normally in the county court in England and Wales or the sheriff court in Scotland.
The time limit is six months minus one day from the act, which a court can extend. The court can order an injunction and award damages, and damages can include compensation for injured feelings.
Filed with
The rule
Equality Act 2010, ss. 20 (duty to make adjustments), 29 (service providers) and Schedule 2
Read the rule (Equality Act 2010, ss. 20 (duty to make adjustments), 29 (service providers) and Schedule 2)Sources
- Equality Act 2010, section 20, Duty to make adjustments (legislation.gov.uk)
- Equality Act 2010, section 29, Provision of services, etc. (legislation.gov.uk)
- EHRC, Statutory Code of Practice: Services, public functions and associations (Crown copyright 2026, presented to Parliament under section 14 of the Equality Act 2006)
- Directive (EU) 2019/882 (European Accessibility Act), Official Journal L 151, 7.6.2019, Art. 3(4)
- W3C, Web Content Accessibility Guidelines (WCAG) 2.1, Recommendation
- Deque, axe-core README (rules, WCAG coverage and incomplete results)
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For information only. Not legal advice.