If you manage a GP practice website, someone has probably told you it has to be accessible. It might have been NHS England guidance, your website supplier, a patient, or your ICB (integrated care board). What is less clear is whether that is law, contract or advice.
This guide gives practice managers, and the suppliers who build and look after surgery websites, a straight answer on GP practice website accessibility: which standard to meet, and what your accessibility statement has to say. The position differs in Scotland, Wales and Northern Ireland; this post covers England.
The Short Answer
Make your website meet WCAG 2.2 AA (the Web Content Accessibility Guidelines, level AA) and publish an accurate accessibility statement.
NHS England's guidance on creating a highly usable and accessible GP website(opens in new tab) says GP websites must meet the Public Sector Bodies Accessibility Regulations 2018 (often shortened to PSBAR) and must publish an accessibility statement. On the statement, it says: "This is a legal requirement." NHS England also says practices stay legally responsible for their website meeting accessibility requirements, even when a supplier built it.
One honest caveat. That is NHS England's position. The regulations apply to public sector bodies and set their own test for what counts as one. We found no law, regulator or court that has applied that test to a GP practice run as an independent contractor.
It does not change what you should do. The Equality Act 2010 applies to every practice either way, and the steps below are the same.
Under the Equality Act (sections 20 and 29), a practice must make reasonable adjustments so disabled patients are not put at a substantial disadvantage. The regulations link the two: under regulation 12, failing to meet their accessibility requirement is treated as a failure to make a reasonable adjustment. Our overview of UK accessibility law explains how the public sector rules and the Equality Act fit together.
Which Standard: WCAG 2.1 or 2.2?
The regulations themselves do not name a version. Since an amendment that came into force on 26 October 2022, they refer to WCAG "as amended from time to time". A site that meets the level A and AA success criteria is presumed to meet the regulations' accessibility requirement. No version is named and no date is set.
The government's own guidance is more specific. GOV.UK's guidance on making your website accessible(opens in new tab) names WCAG 2.2 AA. The Government Digital Service (GDS), which monitors public sector websites, has tested sites against WCAG 2.2 since October 2024.
NHS England's pages say something different. Its GP website guidance, last updated on 26 September 2025, and its digital accessibility standards page both still say WCAG 2.1 AA.
So official sources point at two versions. The practical answer is simple. WCAG 2.2 builds on 2.1, so a site that meets 2.2 AA also meets 2.1 AA for practical purposes. Aim for 2.2 AA and you meet both.
What the Accessibility Statement Has to Say
Regulation 8(opens in new tab) sets out the statement. It must be in an accessible format, published on your website, and kept under regular review. It must cover:
- What is not accessible, and why. The parts of your site that fail, and the reason for each.
- Alternatives. Where it makes sense, how a patient can get the same thing another way.
- How to contact you. A way for patients to tell the practice about access problems.
- The enforcement procedure. A link to what a patient can do if they are not happy with your response.
GOV.UK publishes a sample statement with the expected wording, including whether your site is fully, partially or not compliant.
A statement is only useful if it is true. The most common problems are not missing wording. They are statements that are hard to find, out of date, or copied from a template.
A 2023 Nexer Digital audit of 50 GP practice homepages(opens in new tab) found that 16% had no accessibility statement anyone could find. Of those that did have one, 90% were out of date. That is one small sample from 2023, not a measure of every practice today. But it matches a wider pattern. GDS's monitoring of public sector websites from 2022 to 2024, which was not specific to GP practices, found many statements were out of date or copied from the template.
A template is a fine place to start. It is not a description of your site. A statement copied from a template can say your site meets a level that nobody has checked.
Who checks, and what can happen
The regulations name the Equality and Human Rights Commission (EHRC) as the enforcement body in Great Britain. A patient who raises an access problem and gets no response, or is not satisfied, can complain. The Equality Advisory and Support Service (EASS) handles those complaints in Great Britain. GDS monitors public sector sites, and the government can publish the name of a body that fails an assessment of its statement.
The regulations contain no fines. We found no case of GDS or the EHRC monitoring, naming or taking action against a GP practice. That is not a reason to wait. A practice with an accurate statement and evidence behind it has nothing to explain to a patient or an ICB.
Who Is Responsible When a Supplier Built the Site?
The practice. The regulations place the duty on the public sector body, not on the company that built the website. NHS England says practices stay legally responsible even when the site is outsourced. We found no source that puts the regulations' duties on a supplier directly.
What your supplier does for you, and who pays to fix problems, is set by your contract with them. That makes the contract worth reading, and it makes the right questions worth asking. Ask your supplier for:
- evidence the site was checked against WCAG 2.2 AA, and when
- what failed in that check
- what was fixed, and what is still outstanding
- an accessibility statement that matches those results
If you are a supplier, those four things are the straight answer a practice needs from you.
Be wary of anything sold as a one-step fix. Nexer found accessibility overlays (add-on widgets that sit on top of a site) on 26% of the sites it sampled, and it advises against relying on them. An overlay does not replace fixing the site.
What the GP Contract Does and Does Not Say
The GP contract has its own website rules, and they are easy to confuse with accessibility. Under regulation 73 of the GMS Regulations 2015, a practice must have a practice website or an online practice profile. It must publish the information from the practice leaflet, review it at least once every 12 months and keep it accurate. It must also show prominent links on the home page to its online consultation tool and to NHS resources such as the NHS website symptom checker.
The 2026/27 contract changes add one more: practices must display opening times for every way patients can access the practice.
None of this mentions WCAG or an accessibility statement. The accessibility duties on a practice website come from the regulations, which NHS England says apply, and from the Equality Act. They do not come from the contract.
A Checklist for This Week
You can work through most of this in an afternoon.
- Find your statement. Start on your home page and see how quickly you can reach it. If you struggle, so will a patient.
- Check the date. When was it last reviewed? If nobody knows, it needs reviewing now. Then set a date for the next review.
- Read it against regulation 8. Does it say what is not accessible and why, offer alternatives, give a contact route and link to the enforcement procedure?
- Check it matches the site today. If it was copied from a template, or claims a level nobody tested, it needs redoing. A website accessibility audit against WCAG 2.2 AA gives you the results to write it from.
- Include real testing. Make sure the check covers keyboard use and testing with assistive technology such as a screen reader, not only an automated scan.
- Ask your supplier the four questions. Evidence of a check, what failed, what was fixed, and a statement that matches.
- Test the contact route. Send a message through the contact option in your statement and see who answers, and how fast.
How AUDITSU Helps
Your website and your statement belong to your practice. AUDITSU helps you check one and keep the other accurate.
AUDITSU takes you through an audit of your site against WCAG 2.2 AA. A person on your team reviews every finding, and nothing counts until they accept it. Failures become a fix list you can hand to your supplier. Your accessibility statement is built from those results, so when you fix something and recheck it, the statement updates with it. That works for one practice, and a supplier looking after many practice sites can run the same process for each. If you would rather an independent tester did the checking, a manual audit is available too.
If you want to talk through where your practice website stands, book a call.