Detailed guide: Understanding accessibility requirements for public sector bodies

Government Digital Service

February 18
15:51 2020

Understanding accessibility

Making a website or mobile app accessible means making sure it can be used by as many people as possible.

This includes those with:

  • impaired vision
  • motor difficulties
  • cognitive impairments or learning disabilities
  • deafness or impaired hearing

At least 1 in 5 people in the UK have a long term illness, impairment or disability. Many more have a temporary disability.

Accessibility means more than putting things online. It means making your content and design clear and simple enough so that most people can use it without needing to adapt it, while supporting those who do need to adapt things.

For example, someone with impaired vision might use a screen reader (software that lets a user navigate a website and read out the content), braille display or screen magnifier. Or someone with motor difficulties might use a special mouse, speech recognition software or on-screen keyboard emulator.

Why making your public sector website or mobile app accessible is important

People may not have a choice when using a public sector website or mobile app, so its important they work for everyone. The people who need them the most are often the people who find them hardest to use.

Accessible websites usually work better for everyone. They are often faster, easier to use and appear higher in search engine rankings.

Most public sector websites and mobile apps do not currently meet accessibility requirements. For example, a recent study found that 4 in 10 local council homepages failed basic tests for accessibility.

Common problems include websites that are not easy to use on a mobile or cannot be navigated using a keyboard, inaccessible PDF forms that cannot be read out on screen readers, and poor colour contrast that makes text difficult to read - especially for visually impaired people.

You may be breaking the law if your public sector website or mobile app does not meet accessibility requirements.

Meeting accessibility requirements

The accessibility regulations came into force for public sector bodies on 23 September 2018. They say you must make your website or mobile app more accessible by making it perceivable, operable, understandable and robust. You need to include and update an accessibility statement on your website.

The full name of the accessibility regulations is the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018.

The accessibility regulations build on your existing obligations to people who have a disability under the Equality Act 2010 (or the Disability Discrimination Act 1995 in Northern Ireland). These say that all UK service providers must consider reasonable adjustments for disabled people.

For example, somebody might ask for information in an alternative, accessible format, like large print or an audio recording. There are a number of factors that determine what makes something a reasonable adjustment.

Intranet and extranet websites are covered by the accessibility regulations. These are internal websites which disabled employees working in or with the public sector may use.

Your website or mobile app will meet the newer legal requirements if you:

The best way of doing this is firstly to check how far your website or mobile app currently meets WCAG 2.1, and where there are problems. Then, make a plan to fix the problems youve found. Your web team should use the guide to making your website accessible and publishing an accessibility statement.

The deadline for meeting the requirements and the steps you need to take depend on whether you have:

  • a new website (published on or after 23 September 2018)
  • an existing website
  • intranet and extranet websites
  • a mobile app

Who has to meet the 2018 accessibility regulations

All public sector bodies have to meet the 2018 requirements, unless they are exempt.

Public sector bodies include:

  • central government and local government organisations
  • some charities and other non-government organisations

When you may be exempt from accessibility regulations

All UK service providers have a legal obligation to make reasonable adjustments under the Equality Act 2010 or the Disability Discrimination Act 1995 (in Northern Ireland).

The following organisations are exempt from the accessibility regulations:

  • non-government organisations like charities - unless they are mostly financed by public funding, provide services that are essential to the public or aimed at disabled people

  • public sector broadcasters and their subsidiaries

The following organisations are partially exempt from the accessibility regulations:

  • primary and secondary schools or nurseries - except for the content people need in order to use their services, for example a form that lets you outline school meal preferences

Partially exempt organisations would need to publish an accessibility statement on their website.

Check with your legal adviser (if you have one) if youre not sure whether the new accessibility rules apply to you.

When complying with accessibility regulations might be a disproportionate burden

Some organisations are not exempt but may not need to fully meet accessibility standards. This is the case if the impact of fully meeting the requirements is too much for an organisation to reasonably cope with. The accessibility regulations call this a disproportionate burden.

You need to think about disproportionate burden in the context of whats reasonable to do right now. If your circumstances change, youll need to review whether somethings still a disproportionate burden.

If you want to declare that making particular things accessible is a disproportionate burden, youre legally required to carry out an assessment. In your assessment you weigh up, roughly speaking:

  • the burden that making those things accessible places on your organisation
  • the benefits of making those things accessible

When making your assessment, you need to think about:

  • your organisations size and resources
  • the nature of your organisation (for example, do you have services aimed at people who are likely to have a disability?)
  • how much making things accessible would cost and the impact that would have on your organisation
  • how much disabled users would benefit from you making things accessible

You might judge that the benefits of making some things accessible would not justify the cost to your organisation. In that case, you can claim it would not be reasonable for you to make those things accessible because its a disproportionate burden.

You cannot take things like lack of time or knowledge into account in your assessment - or argue that making things accessible is a disproportionate burden because youve not given it priority.

Example 1

You might be able to argue its a disproportionate burden to meet all the requirements if doing so would use up most of your organisations budget for the year and leave you unable to do any of your other work - and would significantly improve things for disabled users.

Example 2

A simple code change that improves your website or apps colour contrast is relatively low cost and would improve things for a lot of people with sight impairments. You might not be able to argue that changing this is a disproportionate burden.

Youre less likely to be able to claim disproportionate burden for services that:

  • are specifically aimed at disabled people, for example apply for a blue badge
  • enable people to participate in society, like register to vote or find a job

In many cases youll need to work out what it is reasonable for you to fix now, and what youll be able to fix in the future.

If you decide that fixing something would be a disproportionate burden, youll need to say so in the accessibility statement you publish on your website or mobile app

Related Articles


  1. We don't have any comments for this article yet. Why not join in and start a discussion.

Write a Comment

Your name:
Your email:

Post my comment

Recent Comments

Follow Us on Twitter

Share This

Enjoyed this? Why not share it with others if you've found it useful by using one of the tools below: