Rules and ethics
Part of Web accessibility checklist for UK agency buyers
Web accessibility checklist for UK agency buyers
A practical web accessibility checklist for UK agency buyers, covering legal duties, WCAG tests, named tools, accessibility statements and agency evidence.
What to take away
- In the UK, accessible website design must account for web accessibility duties under the Equality Act 2010, with separate rules for public sector sites.
- WCAG 2.2 level AA is the benchmark most UK briefs name, even where the law does not.
- Ask for the audit method, the tooling and the named owner of every fix.
- Treat accessibility as a running control with dates, not a launch task.
Where the duty sits for accessible website design in the UK
The Equality Act 2010 applies in England, Scotland and Wales. Service providers must make reasonable adjustments for disabled people, and a site that blocks a disabled customer is difficult to defend. Northern Ireland works under the Disability Discrimination Act 1995.
Accessibility duty by UK nation
England, Scotland, Wales
- Main law
- Equality Act 2010
- Public sector rules
- PSB Regs 2018
- Standard
- EN 301 549
- WCAG target
- WCAG 2.1 AA
Northern Ireland
- Main law
- Disability Discrimination Act 1995
- Public sector rules
- Not stated
- Standard
- Not stated
- WCAG target
- Not stated
The Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 add a stricter standard. Public bodies must publish an accessibility statement and meet EN 301 549, which points at WCAG 2.1 level AA.
Government Digital Service (GDS), part of the Cabinet Office, monitors compliance with the 2018 Regulations. For Equality Act service-provider duties, the Equality and Human Rights Commission (EHRC) has an enforcement role; people can also bring service-discrimination claims in court. Public-sector users who cannot resolve an accessibility complaint can use the Equality Advisory and Support Service (EASS) route set out in the statement.
Private businesses often assume the Equality Act 2010 stops at employment. It does not: Part 3 covers services and public functions, so a shop, a solicitor or a hotel selling online is in scope.
Reasonable adjustments still turn on cost, practicality and the size of the business. A two-person studio and a national retailer will not be judged the same way, and individual cases need a qualified adviser.
A WCAG compliance checklist for a UK web project
The Web Content Accessibility Guidelines (WCAG) come from the World Wide Web Consortium and cover four areas: whether content can be perceived, operated and understood, and whether it works with assistive technology.
Use this checklist when reviewing the pages and templates in an agency’s audit:
- Check that informative images have text alternatives and decorative images are handled appropriately.
- Check text and interface contrast, and make sure colour is not the only way information is conveyed.
- Navigate every interactive control by keyboard; check that focus is visible and users do not get trapped.
- Check that page titles, headings, links and controls describe their purpose, and that controls expose an accessible name, role and state.
- Check that form fields have labels and instructions, and that errors are identified and explained.
- Check that content remains usable when enlarged or reflowed, and that video and audio have appropriate captions or alternatives.
- Run an automated first pass with axe, WAVE, Lighthouse or Pa11y, then manually check the site with a keyboard and screen readers such as NVDA, JAWS or VoiceOver. Automated scans alone cannot establish compliance.
WCAG 2.2 AA project checklist
- Name accessibility owner and client counterpart
- Fix written targetWCAG 2.2 AA
- Scan automatically, then audit manually
- Log failures with owner and retest date
- Write meaningful alt text
- Test colour contrast on real content
- Re-test after template or plugin changes
Consent and privacy sit in the same review
Accessible design and data protection overlap more than they appear to. A consent banner that cannot be reached by keyboard fails WCAG and weakens the record you need for compliance.
The ICO guidance on cookies and similar technologies sets out what counts as consent, and it governs the same interface your audit covers.
Privacy notices, error messages and session timeouts belong in the same pass. The ICO guide to the UK GDPR is the reference when you test whether a form is usable and lawful at once.
How to test an agency WCAG compliance claim
Start with method. A supplier that cannot describe its audit process, tooling and evidence format is selling an intention, so settle the questions to ask a web design agency before you sign before any deposit moves.
Ask to see a redacted report from a comparable site, ideally one in your sector. Look for severity ratings, screenshots of each failure and a retest column that has actually been filled in rather than left blank. Vague summaries are not evidence.
Weak answer
- Which audit method?
- We run an audit at the end
- Who writes alt text?
- The developer will handle it
- How is the level set?
- We aim for accessibility
- What happens after launch?
- We will always help
Evidence to request
- Which audit method?
- Manual test script and a sample report
- Who writes alt text?
- Workflow with client sign-off and dates
- How is the level set?
- Written target of WCAG 2.2 AA per component
- What happens after launch?
- Support terms with retest cadence and rates
For a public-sector site, use the Government Digital Service (GDS) model accessibility statement. It is a compliance record and a route for users to report barriers, not proof that the site is accessible; include:
- The standard used and the site’s compliance status.
- The date the statement was prepared and last reviewed.
- Any content that does not meet the requirements, why it is inaccessible and any planned remedy, including content covered by a disproportionate-burden claim or outside the Regulations’ scope.
- A contact and feedback route for reporting barriers or requesting information in an accessible format, with an explanation of what happens next.
- The enforcement procedure and the route to the Equality Advisory and Support Service if a complaint is not resolved.
Then check the paper trail: company records, insurance, subprocessors and any accessibility subcontractors, covered by vendor due diligence on a web supplier.
Finally, ask who fixes what after launch and at whose cost. Live-site accessibility is maintenance, so it belongs in the retainer, not in a goodwill clause.
Common questions
Does UK law require WCAG compliance?
Not by name. The Equality Act 2010 sets the duty to make reasonable adjustments, and the public sector accessibility regulations point at EN 301 549, which references WCAG. Most agencies adopt WCAG 2.2 level AA as the working target.
Can an automated tool prove WCAG compliance?
Automated scans catch only some failures, such as missing alt attributes and contrast errors, and miss most keyboard and screen reader problems. Treat them as a first pass before manual testing.
Who owns accessibility after launch?
The agency owns fixes while defects are traceable to its build; the client owns content, alt text and any third-party widgets added later. Put the split, review arrangements and support responsibilities in the agreement.
