UK Accessibility Laws: The Post-Brexit Landscape
The rules have diverged. Public bodies face strict enforcement, while private businesses must navigate the Equality Act (2010). And if you sell to consumers in the European Union, the European Accessibility Act (EAA) still applies.
The "Two Laws" (Public vs. Private)
Post-Brexit, UK accessibility law operates on two distinct tracks: strict regulations for public bodies, and case-law-driven requirements for private businesses.
Public Sector (The Hard Regs)
Law: Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018.
The Mandate: Strict compliance with WCAG 2.1 AA.
The Deadline: Passed. Enforcement is active via the Central Digital and Data Office (CDDO).
Requirement: You must publish a specific accessibility statement.
Private Sector (The Equality Act)
Law: Equality Act 2010.
The Mandate:You must make "reasonable adjustments" to ensure services are accessible to disabled users.
The Risk:While there is no specific "web deadline," failure to make adjustments is unlawful discrimination.
Financial Services: The Extra Regulatory Layer
Most private-sector firms answer only to the Equality Act. Financial services is the exception: it is the one private sector with a conduct regulator layered on top. No statute names a technical standard for banks or fintechs. But the FCA's expectations and court-enforced equality duties point the same way.
The Baseline: An Anticipatory Duty
Sections 20 and 29 of the Equality Act 2010 require service providers to make reasonable adjustments for disabled customers. The duty is anticipatory. It is owed to disabled people at large, so firms must anticipate needs rather than wait for a complaint. Websites and apps count as service provision, and the duty is enforced through county court claims and the EHRC.
The Duty Is Court-Enforced
In Royal Bank of Scotland Group plc v Allen [2009] EWCA Civ 1213, the Court of Appeal upheld a reasonable-adjustments breach over wheelchair access to a Sheffield branch. RBS was ordered to install access and pay compensation. That case was about physical access, and no UK court has yet decided a case about a bank's app or website. The precedent still matters: the duty is real, and courts will enforce it.
The FCA Layer
Vulnerable customers guidance (FG21/1, February 2021): firms must identify and respond to vulnerability, and disability sits under its health driver. It applies across all retail channels, including digital self-serve journeys. It names no technical accessibility standard.
Consumer Duty (PRIN 2A): in force since 31 July 2023 for open products and 31 July 2024 for closed products. The consumer understanding and consumer support outcomes require communications and support that work for customers with characteristics of vulnerability (see the FCA's FG22/5 guidance).
March 2025 vulnerability review: the FCA cited a firm improving its website accessibility as good practice. It flagged firms presenting the same design and format to all customers, without considering accessibility needs, as poor practice.
The Financial Ombudsman Service also hears complaints where a bank discriminates on disability or fails to make reasonable adjustments.
Where the FCA names WCAG: in one place only. Handbook guidance at COBS 4.12A.37G and 4.12A.41G says firms should "take account of the latest version of" WCAG when designing digital financial promotions and risk warnings for high-risk investments. The scope is narrow, but the direction is clear.
The takeaway:no single statute hands private financial firms a named standard. But the Equality Act duty and the FCA's vulnerable-customer expectations point the same way. WCAG 2.1 AA is the baseline regulators and courts recognise, and the strong, defensible line to build to. For EU-facing operations, the European Accessibility Act and EN 301 549 also apply (see the next section).
Do You Sell to the EU?
Many UK businesses erroneously believe Brexit exempts them from the European Accessibility Act (EAA).
The Reality: If you sell products or services into the EU market, you must comply with the EAA.
Northern Ireland is not understood to be in scope of the EAA: it sits outside the Windsor Framework's goods-alignment annex, and the UK government's position is that the Equality Act and Northern Ireland's own disability legislation already cover this ground.
The Link: Read our EAA Survival Guide to check your export liability.
UK Laws Explicitly Cover Mobile Apps
The 2018 Regulations were updated specifically to bring mobile applications into scope as of June 2021.
The Risk: The Government Digital Service (GDS) actively audits public sector apps. For the private sector, apps are often the primary target for discrimination claims because they are harder to use with assistive tech than websites.
Tech Note:"Compliance requires testing with VoiceOver (iOS) and TalkBack (Android), not just automated web scanners."
The Solution: Accessibility Statements
Required by Law for Public Sector
If you are a public body (or funded by one), a compliant Accessibility Statement is mandatory. For private companies, it is your primary defense against Equality Act claims.
Audit your website freeImplementation Roadmap
Step 1: Check your Market (UK only vs. EU Export)
Determine whether you sell exclusively within the UK or also export to the EU. If you export, the EAA applies regardless of Brexit.
Step 2: The "Reasonable Adjustment" Audit
Fix barriers that prevent access. For public bodies, this means full WCAG 2.1 AA compliance. For private businesses, focus on removing barriers in your most critical user journeys first.
The Business Upside:
Accessibility improves usability for everyone, not just disabled users. If you are looking to attract and retain more customers, we recommend aligning to WCAG 2.1 AA as a quality standard. Better accessibility often leads to higher conversion rates and better SEO.
AUDITSU's Audit Toolkit gives your team a structured workflow to identify barriers and track fixes, without needing accessibility expertise.
Step 3: Publish your Statement
Define your roadmap to transparency. Beyond compliance, an Accessibility Statement is a critical trust signal. Many disabled users check for this document beforedownloading an app or starting a purchase to ensure they won't be blocked at the final hurdle. Use it to set expectations and invite feedback.
Don't Guess on Compliance
Whether it's the Equality Act or the EAA, a structured audit is your first step.