EAA compliance in United Kingdom
Accessibility law in the UK and EAA relevance for UK businesses
National legislation
National law
Equality Act 2010 and Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (PSBAR)
Reference
Equality Act 2010, c.15; SI 2018/952
Enforcement authority
EHRC (Equality and Human Rights Commission) for Equality Act enforcement, and the Central Digital and Data Office (CDDO) / GDS for monitoring public sector web accessibility under PSBAR
Contact: equalityhumanrights.com / gov.uk/guidance/accessibility-requirements-for-public-sector-websites-and-apps
Penalties
Under the Equality Act, individuals can bring discrimination claims through employment tribunals or county courts, with uncapped compensation. PSBAR enforcement is primarily through monitoring and compliance notices. There are no fixed administrative fines equivalent to EU member state EAA penalties, but litigation risk is significant.
Sectors in scope
The Equality Act applies broadly to all service providers and employers. PSBAR specifically covers public sector websites and mobile applications. For UK businesses selling into the EU, all EAA-scoped sectors apply: e-commerce, banking, telecommunications, transport, audiovisual media, e-books, consumer electronics, and self-service terminals.
Key deadlines
The Equality Act has been in force since 2010. PSBAR has applied to public sector websites since 23 September 2019 and mobile apps since 23 June 2021. UK businesses selling to EU customers have been subject to EAA requirements from 28 June 2025.
United Kingdom-specific requirements
The UK left the EU on 31 January 2020 and is not required to transpose the European Accessibility Act. However, UK accessibility law remains substantial: the Equality Act 2010 requires service providers to make reasonable adjustments for disabled people, which courts have interpreted to include digital accessibility. PSBAR requires public sector websites and apps to meet WCAG 2.1 AA. Critically, UK businesses that sell products or services to customers in EU member states must comply with the EAA for those offerings - the EAA applies based on where products and services are placed on the market, not where the business is headquartered. This means many UK e-commerce businesses, SaaS providers, and exporters need to meet EN 301 549 standards for their EU-facing operations.
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Frequently asked questions
Does the EAA apply to UK businesses?
The EAA does not apply within the UK itself. However, any UK business that places products or services on the EU market must comply with the EAA for those products and services. This includes UK e-commerce sites selling to EU customers, SaaS providers with EU users, and physical products exported to the EU.
What UK law covers digital accessibility?
The Equality Act 2010 requires service providers to make reasonable adjustments for disabled people, which includes digital accessibility. PSBAR (Public Sector Bodies Accessibility Regulations 2018) specifically requires public sector websites and apps to meet WCAG 2.1 AA. There is no direct UK equivalent of the EAA covering private sector digital accessibility requirements.
Can I be sued for an inaccessible website in the UK?
Yes. Under the Equality Act 2010, failing to make reasonable adjustments for disabled users of a website or app can constitute disability discrimination. Individuals can bring claims through county courts, and compensation is uncapped. While there have been fewer high-profile UK web accessibility lawsuits compared to the US, legal risk is real and growing.
What standard should UK businesses follow?
For UK domestic compliance, WCAG 2.1 AA is the accepted standard (as referenced in PSBAR). For EU market compliance under the EAA, the harmonised standard is EN 301 549, which incorporates WCAG 2.1 AA plus additional requirements for non-web products and services. Meeting EN 301 549 will satisfy both UK and EU requirements.
Related resources
Last reviewed: April 2026. Regulatory details are reviewed quarterly for accuracy.